Overview
To be part of our organization, every employee should understand and share in the YNHHS Vision, support our Mission, and live our Values. These values - integrity, patient-centered, respect, accountability, and compassion - must guide what we do, as individuals and professionals, every day.
The Executive Director, Corporate Compliance and Chief Compliance Officer has the responsibility and authority to oversee all activities related to the development, implementation, and maintenance and functioning of the YNHHS' Corporate Compliance/Privacy Program. As the designated Chief Compliance Officer, the position also has responsibility as the System's HIPAA Privacy Officer for the YNHHS Self-Funded Health Plans and serves as the ACO Compliance Officer.
The Corporate Compliance department is responsible for compliance oversight of all Delivery Networks including all Yale New Haven Health System hospitals, NEMG physicians and practices and other entities within the system to understand and comply with state and federal regulatory obligations. The compliance and privacy function at YNHHS is staffed by over 20 employees. The YNHHS Corporate Compliance department also works closely with departments within Yale University on relevant compliance matters including Yale Medicine, Yale Center for Cancer Initiatives, University Privacy Officer and the Legal office.
The Corporate Compliance Program includes system training and education initiatives, ongoing risk assessment, monitoring and auditing, policy and procedure development and audits or investigations related to compliance risk areas. The goal is to facilitate the sustainability of an organizational culture of compliance, to prevent and detect violations of law and regulations. Serves as a role model for ethical management behavior and promotes an awareness and understanding of the System 's Code of Conduct and Privacy and Corporate Compliance Program. The incumbent serves as a role model for positive ethical and moral principles consistent with the mission, vision and values of the Health System and its Delivery Networks. Advocates and protects patient privacy and serves as a resource to Yale New Haven Health System regarding patient privacy and information access requests or questions under HIPAA.
The Executive Director will report to the Audit Committee of the governing board through the Executive Vice President, General Counsel, and Chief Legal Officer, and will promptly communicate on any matter involving criminal conduct or potential criminal conduct, and no less than annually on the implementation and effectiveness of the compliance program. Prepares and presents reports on corporate compliance activities to System Compliance Committee and other organizational committees.
EEO/AA/Disability/Veteran
Responsibilities
- 1. Lead a robust and forward thinking organization-wide compliance risk management strategy, including the direction of compliance, privacy, general compliance and revenue compliance auditing, internal audit, and risk reduction initiatives, with an understanding of the broader healthcare landscape, regulatory challenges and growth opportunities.
- 2. Oversee formal assessments of strategic and business process risk; using risk assessment results, including the Enterprise Wide Risk Assessment (EWRA), which is managed jointly by the OPCCI and Corporate Finance/Internal Controls, to plan, design and implement an audit and compliance strategy that is an integral part of the annual YNHHS strategic and business planning processes and Business Plan, and that fosters ethical and compliant behavior.
- 3. Expand, design and oversee an organization-wide corporate compliance program, and organization-wide privacy and internal audit programs, that includes managing, recruiting, developing and training professional staff, and engaging and managing outsourced internal auditors, each with sufficient knowledge, skills, experience and professional certifications to meet position requirements.
- 4. Prepare annual work plan/audit plan that addresses high risk areas within the organization in coordination and collaboration with leadership and departments with common goals including Corporate Finance, Internal Controls, Legal & Risk Services Department, Office of Information Security, and others.
- 5. Ensure the timely and effective conduct of investigations, including compliance, fraud and business operations effectiveness investigations, root cause analysis and remediation, and liaising with internal and external experts as appropriate.
- 6. Promote a culture of ethics and compliance with applicable laws and regulations, including through the development and implementation of effective training.
- 7. Stay apprised of emerging trends in industry standards including best practices in healthcare policy, compliance and privacy issues, organizational effectiveness, patient satisfaction, community and population health, legal/government/regulatory landscape. Share best practices and coordinate with relevant stakeholders, including subject matter specific compliance functions. Promote System success by participating in industry conferences as participant and speaker.
- 8. Oversee and administer the YNHHS annual conflict of interest survey, managing disclosures and any management plans, and collaborating as appropriate with the YNHHS Legal & Risk Services Department and the Yale University Conflict of Interest Office with respect to Yale School of Medicine physicians on a YNHHS medical staff.
- 9. In collaboration with YNHHS Legal & Risk Services Department, Human Resources, and operational leaders, monitor all YNHHS physician/hospital financial arrangements for compliance with the Stark Law and Anti-Kickback Statute.
- 10. Responsible for the YNHHS self-funded health plans? compliance with HIPAA Privacy Rules.
- 11. Oversee and manage the YNHHS MCN Policy Database. Provide expertise for policy and procedure redesign and standardization. Collaborate with leaders to Systematize policies to eliminate overlap and inconsistency, provide clarity of purpose and reduce regulatory risk. Evaluate and recommend changes to policies and procedures that promote system integrity.
Qualifications
EDUCATION
Bachelor's degree in a relevant field required. Graduate degree in law (Juris Doctor from an ABA-accredited law school), business/health administration, compliance, or another relevant field required.
EXPERIENCE
Minimum of ten (10) years' progressive experience in hospital/health system corporate compliance, including five (5) years' experience in corporate compliance leadership (at the Manager level or above) required. Prior experience as an acting or designated Chief Compliance Officer strongly preferred.
LICENSURE
Certification in Healthcare Compliance (CHC) within two (2) years of hire required.
SPECIAL SKILLS
Ability to interpret standards and translate them into organizational policy. Ability to analyze compliance problems and develop effective solutions for correction with context of operations. Ability to lead and maintain effective working relationships with all levels of employees, medical staff, and external vendors in a multi-organizational setting. Ability to facilitate consensus among desired stakeholders. Ability to communicate well both orally and in writing . Ability to maintain high ethics and confidentiality of work matters. Ability to effectively work with and coordinate the activities of outside consultants. Ability and skill to influence personnel through a matrix organization as opposed to line management authority. Knowledge of fraud and abuse regulations, healthcare reimbursement, third party payer guidelines, general coding practices and other regulations. Knowledge and experience in information privacy laws , access, release of information, and release control technologies. Knowledge of human resource management functions.
YNHHS Requisition ID
114130