Responsible for working with Prisma Health leadership and the Finance, Audit and Compliance Committee to develop, implement and ensure quality "state of the art" compliance, privacy and internal audit programs/controls/behaviors that minimize or mitigate risk for Prisma Health and related affiliates and joint ventures, Promise Health Plan, and the Invio Network. Works with system and facility leadership, corporate legal counsel, medical staff and others while maintaining appropriate independence and objectivity in carrying out responsibilities. Works in a highly matrixed organization. Serves as Prisma Health's Chief Compliance and Privacy Officer and is responsible for administering an effective corporate compliance program consistent with Office of Inspector General (OIG), Centers for Medicare and Medicaid Services (CMS), HIPAA, and other federal and state regulatory requirements. Maintains direct and independent access to the Chief Executive Officer and the Finance, Audit and Compliance Committee regarding significant compliance, audit, privacy, and ethics matters.
All team members are expected to be knowledgeable and compliant with Prisma Health's purpose: Inspire health. Serve with compassion. Be the difference.
Institutes and maintains effective communication, education and training programs for privacy, internal audit and corporate compliance programs as appropriate and/or required by local, state and federal laws. Oversees Prisma Health's Code of Conduct, conflict of interest program, and mechanisms for reporting concerns, including anonymous reporting channels.
Establishes strategic direction for corporate compliance, internal audit, and privacy programs by implementing processes, tools, policies, and systems to assess, report, measure, monitor, and manage risk through development of the annual internal audit and corporate compliance work plans. Provides executive direction for the co-sourced internal audit relationship. Conducts enterprise-wide compliance and internal audit risk assessments and develops annual compliance and internal audit work plans based on identified risks, regulatory changes, investigations, enforcement trends, and operational priorities.
Provides oversight of regulatory compliance programs including Medicare, Medicaid, billing and coding compliance, physician arrangements, Stark Law, Anti-Kickback Statute, EMTALA, 340B, reimbursement integrity, research compliance, and other healthcare regulatory requirements. Oversees compliance monitoring, auditing, and validation activities designed to assess adherence to regulatory requirements, organizational policies, billing and coding standards, and documentation practices.
Coordinates response to alleged violations of rules, regulations, Code of Ethics, information security breaches, and policies and procedures. Ensures appropriate reporting of violations or potential violations to duly authorized enforcement agencies as appropriate and/or required. Oversees special audits or investigations and coordinates with appropriate departments in the investigation and resolution of audits. Ensures corrective action plans are developed, implemented, validated, and reported through appropriate governance structures.
Works with Finance Audit and Compliance Committee of Prisma Health to ensure appropriate governance oversight of corporate compliance, internal audit, and privacy programs. Regularly reports to the Finance, Audit and Compliance Committee regarding compliance effectiveness, privacy incidents, audit results, significant investigations, emerging risks, and corrective action progress. Has authority to directly communicate with the Chair of the Finance, Audit and Compliance Committee as circumstances warrant.
Works with Human Resources and other Prisma Health leadership to support programs that enhance the recruitment, development, retention and engagement of team members. Ensures ongoing staff compliance with organizational, facility, state, federal and Joint Commission requirements.
Works with operational owners, Legal, Information Security and other departments as necessary to review contracts, Business Associate Agreements and Data Use Agreements for compliant provisions and establishing acceptable behaviors and information management practices.
Develops, implements and monitors annual operating budgets for corporate compliance, privacy, and internal audit departments.
Communicates and advises the Chief Executive Officer of Prisma Health where necessary to ensure the effective oversight of Compliance within Prisma Health and Promise Health Plan in compliance with Federal and State guidelines.
Serves as a member of the following committees: Data Governance, AI Governance, 340B Steering, Information Security Risk Management, Place of Service Governance (reviewing compliance with provider-based facility regulations), Outlook Retention Oversight (Chair), Conflicts of Interest (disclosures and management).
Performs other duties as assigned.
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