Compliance and Privacy Officer
Job Summary:
Reports directly to the Executive Director and Board of Directors as acting compliance officer for Medicare Part D fraud, waste and abuse (FWA). Under the supervision of the Director of Quality Assurance, develops and maintains the Corporate Compliance Program at the PACE program, including developing awareness and understanding of federal, state and local requirements and regulations. Develops a Corrective Action Plan when areas of opportunity are identified and investigates reports of alleged non-compliance. Assists the Director of Quality Assurance in all activities related to the maintenance of and adherence to policies and procedures covering the privacy of, and access to, patient health information in compliance with the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and PACE privacy practices. Assists with quality assurance and performance improvement activities including monitoring the quality of services provided at contract facilities. Coordinates the employee safety/OSHA program.
Qualifications and Requirements:
Experience:
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Minimum of 1 year working with frail or elderly.
Skills and Knowledge:
- Knowledge of safety, privacy and compliance requirements for healthcare facilities.
- Demonstrated experience in quality assurance and performance improvement activities and in the development and implementation of staff education with application of adult learning concepts.
- Creative, detailed-oriented and organized.
- Excellent written and verbal communication skills with specific ability to maintain accurate records.
- Possess strong research and analytical skills in order to examine and extract relevant information while conducting compliance reviews and other assessments.
- Committed to promoting best practices in the application of policies, procedures and other elements of governance affecting compliance risk throughout the organization.
- Must have integrity, practice discretion and practice objective problem solving.
- Word processing skills, data collection skills and knowledge of basic statistical principles.
- Able to apply compliance program knowledge to communicate, train and answer questions consistent with established policy.
- Skilled in identifying and recommending problem resolution.
- Ability to work independently with minimum supervision.
- Able to maintain confidential information.
- Previous experience in compliance, privacy and safety activities.
- Familiarity with federal government compliance regulations.
Physical Demands and Working Conditions:
The physical demands and work environment characteristics described here are representative of those that must be met by an employee to successfully perform the essential functions of this job. In compliance with ADA requirements, reasonable accommodations may be made to enable individuals with disabilities to perform essential functions.
Work Environment:
Employee must be able to work effectively within an interdisciplinary team model, interfacing and collaborating with a wide range of clinical and social services disciplines who work together to manage the PACE participants’ care. The work setting is in an Adult Day Health Center and primary care clinic environment with moderate noise levels and controlled temperatures.
Physical Requirements:
Requires manual and finger dexterity and eye-hand coordination; the ability to use department equipment; and the ability to lift/carry up to 30 pounds using appropriate body mechanics with reasonable accommodation if needed.
Visual, Hearing and Communication Requirements:
Requires corrected vision and hearing to normal range, with or without reasonable accommodation. Ability to communicate by way of the telephone with participants, customers, vendors and staff.
Pressure Factor:
Requires working under stressful conditions. Working conditions may be noisy and crowded and fluctuating indoor temperatures. Moderate pressure to meet scheduled deadlines. Potential for exposure to verbal aggression by client, vendors, and staff.
Environmental Conditions:
May be exposed to a risk of bodily injury through contact with moving instrumentation, toxic substances, medicinal preparations, bodily fluids, communicable diseases and any other conditions common in a healthcare environment. Subject to unpleasant odors.
Duties and Responsibilities:
- Responsible for development, operating and monitoring the compliance plan for Medicare Part D sponsors that is comprehensive to detect, correct and prevent fraud, waste and abuse according to the requirements of the compliance plan 42CFR 423.504(b)(4)(vi).
- In addition, develops and maintains the Corporate Compliance Program.
- Develop and implement written policies, procedures and standards of conduct to ensure the PACE organizations commitment to detect, correct and prevent fraud, waste and abuse.
- Develop and implement procedures for effective internal monitoring and auditing of fraud, waste and abuse.
- Develop and implement procedures to ensure prompt responses to fraud, waste and abuse and develop corrective action initiatives for offenses.
- Responsible for the training and education related to detection, correction and prevention of fraud, waste and abuse to PACE employees, subcontractors, and any other appropriate entities. Ongoing will promote disciplinary guidelines and standards through a variety of methods.
- Reports on a periodic basis to the Board of Directors/Compliance Committee regarding the status of the PACE Organization’s Compliance Program and the identification and resolution of any potential or actual instances of noncompliance.
- Develops and maintains compliance reporting mechanisms that allow employees and vendors to report suspected fraud, waste and abuse without fear of retaliation.
- Responds to reports of potential instances of fraud, waste and abuse in the PACE Prescriptions Drug Program (PDP), including coordinating investigations and developing corrective action plans.
- Reports instances of fraud to the appropriate Medicare Drug Integrity Drug Contractor (MEDIC) and/or CMS, when the PACE Organization determines that such a report is appropriate.
- Maintains appropriate documentation regarding the Compliance Program.
- Resolves questions/concerns regarding policy, procedures, fraud and abuse laws, including those received through the compliance hotline.
- Develop and implement written privacy policies and procedures to ensure that PACE employees are in compliance with the HIPAA privacy rule.
- Educates PACE employees on privacy policies and procedures.
- Ensures that safeguards to prevent intentional or unintentional use or disclosure of protected health information are in place.
- Receives complaints and provides individuals with information on the PACE Organizations privacy practices.
- Assures a confidential communications process for the solicitation, evaluation and response to complaints and problems.
- Performs periodic compliance monitoring activities in coordination with privacy risk assessments.
- Works with all of the PACE departments to ensure compliance with privacy policies.
- Maintains current knowledge of federal and state privacy laws to ensure compliance.