Participates in the strategic planning of regulatory programs across the medical center and/or health system. Oversees the implementation of new initiatives, processes, and improvement plans.
- The compliance program includes all facets of clinical care and numerous facets of clin research: Prof Coding/Billing/Collection/Reconciliations: Oversee and report to the governing body, leadership, and compliance committee on the progress of implementation, and assist in establishing methods to improve efficiency/quality of services, and reduce the vulnerability to fraud/abuse/waste. Periodically revise the program in light of changes in the needs of the organization, and in the law/policies/procedures of govt and private payer hlth plans.
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15 |
Analyzes quality and efficiency of compliance
methods and systems from a strategic standpoint.
Manages development and implementation of
system improvements that are cost-effective and
scalable. Integrates activities with system wide
initiatives, and ensures compliance with state
reporting requirements.
- Review all documents/information relevant to compliance activities, including: data, patient records, billing records, marketing efforts, and arrangements with other parties, including employees/research sponsors/ insurers/health care providers/independent contractors/ suppliers, etc. This enables the review of contracts/obligations (seeking advice of legal counsel) that may contain referral/payment issues that may violate the anti-kickback statutes, as well as the physician self-referral prohibition and any other legal/regulatory requirements.
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10 |
Oversees the development of policies and
processes to promote cooperative and efficient
practices, focused on compliance with internal
policy and external regulations. Determines need
for changes or enhancements to systems and
processes to mitigate areas of risk.
- Enforce standards through well publicized disciplinary guidelines and developing policies addressing dealings with sanctioned individuals;
Review and advise on issues related to Professional Service Agreements (PSA). Conduct periodic risk assessments and responsive action plans.
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10 |
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Responsible for employee performance reviews,
recruitment, retention, terminations and staff
development programs. Instills strong
management practices to create a culture of
teamwork, collaboration and timely achievement
of objectives and goals.
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5 |
Collaborates with leaders across the medical
center and/or health system to identify
regulatory high risk situations and negotiations.
Develops methods and seeks opportunities to
increase manager and staff awareness of
regulatory compliance programs and associated
processes.
- Training: Develop/coordinate and participate in multifaceted educational/training programs that focus on the elements of the overall components of the Clinical/Research professional services/ compliance programs, seeking to ensure that all employees/mgt are knowledgeable of, and comply with, pertinent federal and state standards. Ensure that independent contractors/agents who furnish medical svcs to the hlth system are aware of the requirements of the compliance program with respect to coding/coverage/ billing/marketing/patients rights etc.
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10 |
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Collaborates with senior leaders to promote and support regulatory interests in organization-wide information technology initiatives, including business intelligence and the electronic medical record system.
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10 |
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Clinical Research Compliance:
Coordinate with UCR Research and Economic Development designee to ensure appropriate invoicing/billing with clinics/hospitals/physicians/partners; Monitors effort on study; Contracts: Subject Injury language/consent forms; Reviews and approves contract language to ensure that Subject Injury language and consent form are consistent; and determination of Medicare Qualification as a Medicare qualifying trial; As appropriate, assist the Institutional Officer (IO) for Clinical and Social/Behavioral Sciences Committees on Human subjects Research (CHR) Institutional Review Boards (IRB) with responsibilities associated with reviewing protocols and consents, managing annual reviews and amendments, monitoring and reporting on adverse events, serious non-compliance, unanticipated events and other safety issues to HHS Office of Human Research Protection (OHRP) and FDA.
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10 |
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Risk Management: As appropriate, coordinate with UCR and UCR SOM risk management programs for the health sciences activities of the SOM, develops and conducts risk assessments, identifies and mitigates specific risk issues. Reviews and advises on provisions required in professional service agreements (PSA). Ensure risk reporting mechanisms and monitor risk incidents for appropriate routing (to health sciences counsel, UC Risk Management, clinical departments, as appropriate). Ensure that appropriate incident follow-up investigations and action plans are carried out. Assist risk management, health sciences counsel, campus counsel, and outside counsel with responding to requests for information including subpoenas and discovery requests. Participate in the campus Enterprise Risk management subcommittee, identifying campus wide risks to be reported annually to the Regents. Represent the SOM on the UCR Enterprise Risk Work Group (ERWG) and Executive Committee for Risk and Audit (ECRAC).
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10 |
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Privacy Officer:Participate and/or oversee all ongoing activities related to development, implementation, maintenance of, and adherence to UCR policies and procedures covering privacy of and access to protected health information (PHI) in compliance to federal and state laws and health system privacy practices.
Provide development guidance and assists in the identification, implementation, and maintenance of organization information privacy policies and procedures in coordination with the AVC, Clinical and Research Compliance, health sciences counsel and management, key departments, and committees to ensure the organization has and maintains appropriate privacy and confidentiality consent, authorization forms, and information notices and materials reflecting current organization and legal practices and requirements.
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15 |
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Investigations: Respond to government investigations and queries related to clinical professional services or research as the principal point of contact. Independently investigate and act on matters related to compliance, including the flexibility to design and coordinate internal investigations (e.g., respond to reports of problems, 'hot-line' calls, or suspected violations) and resulting corrective actions with all health system departments, providers and sub-providers, agents and, if appropriate, independent contractors. Respond promptly to detected offenses, developing corrective action, and reporting findings to the government via established channels; Develop policies and programs that encourage managers and employees to report suspected fraud without fear of retaliation. Ensure prompt repayment of any identified overpayments; Create written policies, procedures, and standards of conduct to prevent, identify and address fraud, waste, and abuse.
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5 |
