The Director Health Plans Compliance will serve as the compliance officer for CHRISTUS Health Plan and Networks (CHP) and all its lines of business. The Director will be dedicated to the development and oversight of a Compliance Program serving the needs of CHP. This role will report to CHRISTUS Health's Vice President, Corporate Compliance, and the CHP Board of Directors, with a dotted line to the Chief Administrative Officer of CHP. The Director will collaborate with the CHP leadership team and the Corporate Compliance team.
Oversees the day-to-day functions of the CHP compliance and privacy programs
Directs CHP compliance and privacy-related policies to ensure CHP and its delegated entities are meeting requirements with regulatory guidelines
Creates and implements new and revises existing compliance and privacy policies and procedures in response to regulatory changes and external reviews
Reviews updated CMS Chapters and creates and ensures delivery of training on revisions and changes
Collaborates with other departments to facilitate identification and resolution of compliance risks/issues as well as role-based compliance training
Manages required breach determination and notification processes under HIPAA and applicable State breach rules and requirements
Create and monitor Business Associate Agreements and monitor Plan Business Associates for adherence to privacy requirements and responsibilities
Reviews CHP vendor contracts from a compliance perspective
Works closely with the VP of CHRISTUS Compliance and the CAO of the Health Plan; the Director will be responsible for and have the authority to implement necessary processes to ensure the achievement of the regulatory objectives of an effective compliance program
Serves as the first-tier liaison between CHP and regulators to facilitate timely and effective communication and is responsible for the reporting of non-compliance
Responsible for compliance with federal, state, and local laws, rules, and regulations affecting CHP and client-related business
Oversees CHP compliance operations, including, for example, Integrity Line call response and conflict of interest management
Provides billing, regulatory, and coding compliance oversight as well as oversight of CHP's Fraud, Waste, and Abuse program
Promotes and models ethical management and behavior, facilitate awareness and understanding of positive ethical principles and compliance with federal and state law
Regularly reviews the CHP compliance program and recommends appropriate revisions and modifications
Advises senior leadership of potential and actual compliance risk areas
Presents periodic compliance reports and education to the CHRISTUS Health Plan Executive and Senior Management Team
Coordinates with CHP's internal legal counsel on matters of legal oversight and review
Identifies and assesses areas of compliance risk within CHP and guides the Compliance Program to effectively prevent, detect, and remediate violations of law, regulation, CHRISTUS policies, or the Code of Ethics and Business Conduct
Designs internal controls designed to detect significant instances or patterns of illegal, unethical, or improper conduct by employees, vendors, or other contractors working with CHRISTUS
Encourages the prompt and proper resolution and implementation of regulatory or compliance program audit/review recommendations
Works closely with the training and development team to develop and implement plan-wide education and communication programs to educate all employees and affiliated parties on the CHRISTUS Health Code of Ethics and Business Conduct, the Compliance Program, and other specific compliance risk areas deemed necessary
Implements and operates retaliation-free reporting channels, including an anonymous telephone and web-based reporting system available to all employees, volunteers, and affiliated providers, and oversees the resolution of investigations and other issues identified by or reported to the Compliance Program, including the development of corrective action plans, as needed
Develops and oversees the annual CHP Compliance auditing and monitoring plan
Creates and delivers CHP compliance updates at CHP Board meetings and annual board member compliance education.
Strong subject matter expertise in health plan laws and regulations; compliance investigations; compliance hotlines and reporting; compliance training and communications; fraud, waste, and abuse; government contracting; exclusion lists; corporate ethics; and third-party risk management required.
10+ years of Compliance and progressive leadership experience in Health Plan Management
Healthcare Compliance Certification and Healthcare Privacy Certification strongly preferred
Knowledge and experience in state and federal information privacy laws
CHRISTUS HEALTH is an international Catholic, faith-based, not-for-profit health system comprised of almost more than 600 services and facilities, including more than 60 hospitals and long-term care facilities, 350 clinics and outpatient centers, and dozens of other health ministries and ventures. CHRISTUS operates in 6 U.S. states, Colombia, Chile and 6 states in Mexico. To support our health care ministry, CHRISTUS Health employs approximately 45,000 Associates and has more than 15,000 physicians on medical staffs who provide care and support for patients. CHRISTUS Health is listed among the top ten largest Catholic health systems in the United States.