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Government Public Attorney / Litigation Attorney in Franklin, TN

Community Health Systems, Inc. Feb 08,2017 Jan 20,2017 Location Franklin TN
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In-House

Attorney

Government / Public Law

Litigation

Litigation - Whistleblower - CFTC

Min 3 yrs required

Profile

Facility Compliance & Privacy Officer Duties: Responsible for the implementation, oversight and ongoing compliance operations of the Medical Center Compliance and Privacy Program. Will ensure that compliance and privacy concerns are reported to the Corporate Compliance Department, investigated appropriately and that adequate corrective action is taken to mitigate non-compliance of the organization’s compliance and privacy policies and procedures as directed by the Senior Vice President, Corporate Compliance and Privacy or her designee. Under the general supervision of Medical Center’s CEO and the Corporate Compliance Department, will: Program Oversight: Monitor and support the implementation of the Corporate Compliance Program for affiliates. Promote an environment in which employees are free to report instances of non-compliance confidentially and without fear of retribution. Incident Investigation: Communicate immediately with the assigned Corporate Compliance Director(s) (CCD) or the Senior VP, Corporate Compliance and Privacy upon learning of a matter of potential concern or upon receiving an allegation of non-compliance. Enter all reported incidents of known or suspected non-compliance into the Compliance 360 incident module on a timely basis. Maintain timely and thorough documentation and status updates in the system to ensure complete documentation of all reported concerns. Interact regularly with and report to the CCD and/or Senior Vice President, Corporate Compliance and Privacy regarding compliance-related activities including investigations of potential non-compliance with policies and procedures, training, auditing, disciplinary actions and corrective actions taken in response to reports of alleged non-compliance. Immediately notify CCD regarding any contact from a government agency (e.g., OIG, OCR, DOJ, etc.) Assist in the development and implementation of corrective action plans when areas of non-compliance are identified. Auditing and Monitoring: Establish a facility-specific audit plan for business units in collaboration with the CCD. Facilitate completion of the annual Corporate Compliance auditing and monitoring plans to determine compliance with established laws, regulations, company policies and managerial guidelines. Conduct regularly scheduled Monthly HIPAA Tours of various departments throughout the facility to monitor privacy and report the results to the FCC. Training and Education: Personally present compliance training at new hire orientation. Collaborate with Human Resources and all Department Directors to ensure all relevant staff complete new hire and annual compliance and privacy training and all training is appropriately documented. Attend corporate-led educational events and regularly scheduled FCO and FPO conference calls which address compliance and privacy topics. Policies and Procedures: Review and coordinate implementation, communication and distribution of new or revised corporate compliance and privacy policies and procedures to relevant staff. Recommend additional policies and/or policy language, as necessary. Facility Compliance Committee (FCC) Meetings Coordinate and/or chair the Facility Compliance Committee (FCC) meeting; ensure adherence to the corporate standard agendas for each meeting of the FCC and prepare minutes of FCC meetings. Add agenda topics as needed at the facility level to ensure adequate and appropriate coverage of specific compliance issues or concerns. Report all current and ongoing compliance and HIPAA privacy issues to the FCC in general terms. Eligibility Monitoring: Ensure implementation of a program for conducting eligibility screening for all relevant persons as identified in compliance policies; coordinate with Human Resources, Medical Staff Development and Contract Administration to ensure complete assessment of all required parties. Contract Management: Identify and flag all vendors which meet the definition of a Focus Arrangement as defined in the Corporate Integrity Agreement (CIA) Review all payments to Focus Arrangements and potential referral sources (PRS) for LMC using HBI, Ariba Contract Management System and other resource materials to determine the validity of payments to these vendors. Document the identification of new focus arrangements in the FCC meeting minutes and notify the CCD of unverified exceptions. HIPAA Privacy and Security: Conduct investigations and assignments for all HIPAA privacy issues under the guidance of the assigned CCD, including completion of the privacy risk assessment, when indicated. Work cooperatively with the HIM Director and other applicable staff to ensure patient rights to inspect, amend and restrict access to protected health information, when appropriate. Work with assigned CCD, Legal, HIM and other key departments and committees to ensure the organization has and maintains appropriate privacy and confidentiality consents, authorization forms, notices and materials reflecting current organizational practices and requirements. Ensure processes are in place to facilitate patient receipt of the Notice of Privacy Practices in registration areas, affiliate physician practices and in other business units. Coordinate with the Director of Information Systems to help ensure HIPAA Security Standards are implemented and maintained. Identify state privacy regulations more stringent than HIPAA working collaboratively with the HIM Director to ensure the regulations are documented and implemented.

Qualification and Experience

QUALIFICATIONS: Bachelor’s degree in Health Information Management, Nursing, Business, Health Administration or related area. Master’s degree or JD Degree preferred. Certified in Healthcare Compliance (CHC) preferred. 3+ years' experience in the health care industry, with specific ethics/compliance/privacy and/or privacy experience, or healthcare law experience. General knowledge of the Medicare and Medicaid reimbursement programs. Demonstrated effectiveness operating in complex organizational environments. Excellent written, oral, and presentation communication skills. The ability to plan, develop and present educational or programmatic materials in front of an audience greater than 20 people. Strong problem-solving skills. Demonstrated ability to partner with others in handling complex issues and investigations. Ability to positively influence others. Ability to think “big picture” while maintaining effective oversight/control of daily initiatives. Reputation for integrity and willingness to politely challenge higher levels of management on issues identified through Compliance Program oversight. Unbiased and subjective approach to complex situations including investigations and corrective action. Sound business judgment. English is required for both spoken and written communications. Proficiency in Spanish is preferred.

Additional info

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