Compliance Officer

UnityPoint Health System Services - Corporate

West Des Moines, IA

Compliance Officer

Position Summary:

The UnityPoint Health Compliance Officer assures the implementation of all aspects of the Compliance Program and the effective operation of system-wide regulatory compliance processes, for UnityPoint Health.

The Compliance Officer shall be accountable to the Board and report to the Board through a direct reporting relationship to the Senior Vice President, Corporate Integrity and General Counsel and the Audit Compliance Committee on compliance matters. The Compliance Officer will have the right and obligation to bring directly to the General Counsel, the President and CEO or Audit Compliance Committee any information on such matters that is reasonably determined at any time should be brought to their attention and full authority to access the Audit Compliance Committee at any time. The Compliance Officer will regularly coordinate with and interface with the General Counsel, who is UPHs primary authority for legal advice.

Responsiblities and Essential Functions:

Compliance Program Management/Maintenance

Oversee, manage and monitor the implementation of the UnityPoint Health Corporate Compliance Program and Code of Conduct (collectively, the Compliance Program) in accordance with the essential elements of an effective compliance program enunciated by the Department of Health and Human Services Office of Inspector General, all applicable laws and regulations, Health Systems mission, vision and values, and all other relevant policies, procedures, guidelines and other regulatory and accreditation standards (collectively, Applicable Laws and Standards);

Select, orient, train, direct and supervise the Compliance Departments staff, who shall report directly to the Compliance Officer;

Develop and manage implementation of the Compliance Program, prospective audits/reviews and, with General Counsel oversight, investigations;

Periodically review and revise the Compliance Program and its policies and procedures in light of changes in Applicable Laws and Standards and what is otherwise in the best interests of UnityPoint Health;

Develop, coordinate and administer a multifaceted program to provide ongoing education and training on the various elements of the Compliance Program and Compliance Program matters for UPH governance, senior management, and all other appropriate employees and contractors as necessary so that they remain aware of, and are sufficiently knowledgeable to comply with, Applicable Laws and Standards;

Provide compliance-related guidance to UPH governance, senior management, other employees and contractors;

Remain fully apprised of relevant changes in Applicable Laws and Standards and communicate such changes to the appropriate UPH constituencies, seeking General Counsel advice and interpretation, as needed;

Serve as a contact person for colleagues and receiving reports of actual and potential compliance issues, including overseeing the operation of the Compliance Hotline, maintain a tracking system for all such reports, and assure that these reports receive timely, complete and appropriate responses;

Subject to the role and authority of the General Counsel, act quickly and appropriately to design and manage implementation of an investigation of compliance issues reported to the Compliance Department or identified by it in the course of prospective Audits/Reviews related to compliance matters, and take necessary and appropriate steps to address the corresponding findings;

Be available as a resource to consult and work closely with the General Counsel on Compliance Program matters for which the General Counsel is responsible, including, without limitation, the investigation, evaluation, assessment and remediation of risk under Applicable Laws and Standards, determination of obligations to report, and the advisability of voluntarily reporting, compliance matters to duly authorized enforcement agencies, interfacing with such authorized agencies, and retaining and interacting with external individuals and organizations (e.g., consultants, legal advisors) with regard to any such matters;

Participate in meetings of the Audit and Compliance Committee, including executive sessions with the Committee and periodic meetings between the Compliance Officer and the General Counsel as reasonable and necessary to maintain appropriate communication and between them on the Compliance Program generally as well as specific compliance matters that arise from time to time; and provide other reports to and attend other meetings with the Senior Vice President, Corporate Integrity and General Counsel, the Audit Compliance Committee and/or the Board as they may request from time to time, in order to keep all of them apprised of Compliance Program Matters;

Perform such other duties as assigned or requested by the Senior Vice President, Corporate Integrity and General Counsel, the Audit Compliance Committee or the Board;

Maintains and implements a privacy compliance program as required by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and related state and federal regulation and has oversight of affiliated entities;

Assures the effective implementation of an information security program. Supports the Chief Information Security Officer in the development of technical and administrative safeguards designed to assure that medical records and other hospital information is secured and protected;

Coordinates a process for the disclosure and management of potential conflicts of interest for members of the boards, leadership and other individuals as required by UPH policy. Develops reports and maintains appropriate records in support of this process;

Assures the development and maintenance of appropriate records to provide information needed by executive management and the Board to continually assess the status and effectiveness of the Corporate Compliance Program;

Acts as an independent review and evaluation body to ensure that compliance issues and concerns within the organization are being appropriately evaluated, investigated and resolved; and

Conducts, when required, under the direction of both the General Counsel, special investigations, audits or other activities deemed necessary to assure compliance with regulatory and accreditation standards and applicable laws and regulations, and oversees a system for uniform handling of potential violations, in cooperation with General Counsel and the Vice President of People Excellence.

Basic UPH Performance Criteria

Demonstrates the UnityPoint Health Values and Standards of Behaviors as well as adheres to policies and procedures and safety guidelines.

Demonstrates ability to meet business needs of department with regular, reliable attendance.

Employee maintains current licenses and/or certifications required for the position.

Practices and reflects knowledge of HIPAA, TJC, DNV, OSHA and other federal/state regulatory agencies guiding healthcare.

Completes all annual education and competency requirements within the calendar year.

Is knowledgeable of hospital and department compliance requirements for federally funded healthcare programs (e.g. Medicare and Medicaid) regarding fraud, waste and abuse. Brings any questions or concerns regarding compliance to the immediate attention of hospital administrative staff. Takes appropriate action on concerns reported by department staff related to compliance.

Requirements:

Education:

J.D. or Masters degree (e.g., healthcare administration, business, or finance) preferred.

Experience:

* Thorough knowledge of and ability to analyze all Applicable Laws and Standards.

* Progressive responsibilities for healthcare compliance in a large and complex health system, and an understanding of the complexities and operational processes of such a health system.

* Demonstrated success integrating compliance into daily health care operations.

* Extensive management experience in a large and complex health system setting. Excellent managerial skills and demonstrated experience leading a team are key. The ability to delegate effectively is critical.

* Strong project management and facilitation skills.

* Strong interpersonal skills are critical to the role.

* The Compliance Officer must be credible, collaborative and highly effective in communicating and interacting with UPH governance and management leadership, compliance team, peer management leadership in the UPH regions, physicians, clinical faculty, employees, contractors and regulatory agency officials, and a highly effective problem solver.

* Demonstrated ability to positively and effectively influence organizational behavior, and to create alignment across disparate groups, with regard to Compliance Program matters.

Demonstration of UPH Values and Standards of Behaviors

Consistently demonstrates UnityPoint Healths values in the performance of job duties and responsibilities

Foster Unity:

Leverage the skills and abilities of each person to enable great teams.

Collaborate across departments, facilities, business units and regions.

Seek to understand and are open to diverse thoughts and perspectives.

Own The Moment:

Connect with each person treating them with courtesy, compassion, empathy and respect

Enthusiastically engage in our work.

Accountable for our individual actions and our team performance.

Responsible for solving problems regardless of the origin.

Champion Excellence:

Commit to the best outcomes and highest quality.

Have a relentless focus on exceeding expectations.

Believe in sharing our results, learning from our mistakes and celebrating our successes.

Seize Opportunities:

Embrace and promote innovation and transformation.

Create partnerships that improve care delivery in our communities.

Have the courage to challenge the status quo.

EOE M/F/V/D