Chief Compliance Officer

Job Role Summary

The Chief Compliance Officer (“CCO”) provides executive leadership for The Health & Hospital Corporation (“HHC”) Compliance Program in support of each HHC division (e.g., Marion County Public Health Department, Eskenazi Health, Indianapolis Emergency Medical Services, Long Term Care). The CCO develops, implements, and manages a comprehensive compliance program tailored to the organization’s diverse needs. The CCO will advise and direct employees with respect to regulatory compliance and work to ensure that internal controls prevent and detect significant instances or patterns of illegal, unethical, or improper conduct by all HHC division employees. This position collaborates regularly with the Eskenazi Health Chief Counsel, the HHC General Counsel, Senior Leadership of HHC and each HHC division, Eskenazi Health CEO, Marion County Public Health Department Director, HHC Treasurer, and HHC President & CEO on compliance matters.

Essential Duties

• Leads the Compliance Program to provide and coordinate appropriate compliance resources for each HHC division to ensure the ongoing effectiveness of the Compliance Program. Monitors state and federal regulatory changes and advises and directs employees with respect to regulatory compliance.
• Establishes and updates compliance policies and procedures and the Code of Conduct
• Works with organization leaders to create a culture of compliance that fosters doing the right thing, teamwork, and collaborative resolutions to problems and issues
• Implements and operates retaliation-free reporting channels, including the anonymous HHC Integrity and Compliance Hotline. Oversees the investigation of and response to Hotline complaints
• Assures that the organization has effective mechanisms to reasonably determine that employees have not violated federal or state laws and regulations or engaged in improper or unethical conduct in their designated areas of responsibility. Responsible for detecting non-compliance by contractors, medical staff, and other HHC agents
• Develops and implements the organization’s compliance risk assessment and audit plan and conducts regular audits and monitoring to identify and mitigate compliance vulnerabilities
• Develops and implements ongoing compliance training programs and ensures specialized staff training in billing, coding, and clinical documentation. Disseminates information and educates employees on a broad spectrum of compliance-related topics (e.g., fraud and abuse laws, Stark, Anti-Kickback, Medicare and Medicaid requirements)

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Associated Job Duties

• Develops and maintains relationships with regulatory agencies including but not limited to CMS (Centers for Medicare and Medicaid), OIG (Office of Inspector General), HRSA (Health Resources and Services Administration), FSSA (Family and Social Services Administration), and the IDOH (Indiana Department of Health). Collaborates regularly with the Eskenazi Health Chief Counsel, HHC General Counsel, HHC Senior Leadership and HHC division Senior Leadership, Eskenazi Health CEO, Marion County Public Health Department Director, HHC Treasurer, and HHC President & CEO on compliance matters.
• Makes periodic reports regarding compliance matters directly to the Board of Trustees and is authorized to report on such matters at the Board of Trustees’ request or when needed.
• Establishes and serves as the Chair of the Executive Compliance Committees, which shall be composed of representatives of the key areas of the organization.
• Responds to alleged violations of rules, regulations, policies, procedures, and the Code of Conduct by evaluating or recommending the initiation of investigative procedures. Develops and oversees a system for uniform handling of such allegations and ensures appropriate corrective actions.

Supervises Compliance staff

• Participates in public health emergency preparedness exercises and in the response to public health emergencies, as directed.
• Participates in a minimum of two H.O.P.E. events totaling eight (8) hours annually.
• Performs other job-related duties as assigned

Qualifications

• Bachelor’s degree required. Master’s in healthcare administration, public health or related field or JD strongly preferred
• A minimum of five years of relevant experience in healthcare compliance for a health system, hospital, and/or long-term care facility, including supervisory experience.
• Proven leadership of a compliance program or compliance function in a complex organization
• Experience working with government-funded healthcare programs, grants, and reimbursement regulations.
• Demonstrated knowledge of Medicare and Medicaid issues, fraud and abuse laws, and behavioral health compliance issues.
• A demonstrated ability to work with all levels within an organization, including front-line staff, physicians, and senior management, and to work effectively on a team.

Licenses/Certifications Required

• Professional certification in healthcare compliance is strongly preferred. (CCEP, CHC, or

CPO)

• Valid Indiana driver's license

Knowledge, Skills & Abilities

• Proven leader of teams and partner of executive management.
• Knowledge of healthcare regulatory standards, trends, and changes to the law.
• Knowledge of reimbursement systems; federal, state, and payer-specific regulations: and policies relevant to documentation, coding, and billing
• Strong leadership, interpersonal, and problem-solving skills and ability to influence and educate staff at all levels.
• Analytical skills and ability to understand operational processes and technology concepts.
• Ability to operate successfully in a constantly changing, fast-paced environment with multiple dead lines.
• Demonstrated initiative, self-motivation, practical learning skills, enthusiasm, and an ability to complete multiple tasks in a timely and accurate manner.
• Excellent written and oral communication skills and attention to detail.
• Ability to train/explain complex issues in easily understandable terms.

Working Environment

• In-person standard office setting at HHC and Eskenazi Health. Frequently in person in division offices with teams and clients.
• Patient care areas, clinics, nursing offices.
• May be required to attend meetings or perform work remotely from clinic or hospital campus.