Director of Compliance

General Statement of Responsibilities:

• Develop and maintain a compliance plan to meet regulatory requirements of state, federal, and local governmental agencies and private insurance carriers.  
• Coordinate compliance activities with the General Counsel’s Office and the University of Minnesota Office of Institutional Compliance.  
• Orientate staff to Boynton’s compliance plan.  
• Maintain mechanism for reporting compliance issues including options for anonymous reporting.  
• Address and follow up on compliance reports through internal mechanisms or the UReports (EthicsPoint) website. 
• Educational Affiliation Agreements as part of preceptor / learner arrangement including Inter-University Affiliation Agreements and 
• Non-AHC Affiliation Agreements
• Responsible for strategic direction and leadership of Boynton Health compliance programs, initiatives and activities. 
• Monitor compliance with state, federal, and University mandated compliance  training for Boynton Health.

Detailed Job Responsibilities:

Promote a safe, equitable, and respectful environment in which concerns can be addressed effectively.

Serve as the designated Compliance Officer

• Provide oversight for the planning and administration of the Boynton Health compliance plan
• Chair and facilitate the Compliance Committee meetings
• Implement Compliance Committee recommendations
• Provide annual certification of substantial compliance with the compliance plan to the Director of Boynton Health
• Assure that any reports of possible violations are promptly investigated
• Assure overall compliance with the compliance plan and facilitate corrective action when appropriate
• Report on a regular basis to the Director of Boynton Health on the progress of implementation of the compliance plan.
• Assist in establishing methods to prevent Boynton health from committing fraud, abuse and waste and improve Boynton Health’s efficiency and quality of services.

Serve as the Compliance Director

• Supervise the Director of Quality Assurance
• Supervise the Director of Health Information Management
• Supervise the Coding Specialists
• Develop, review and revise relevant policy statements, procedures and guidelines with the assistance of legal counsel and approval of the Compliance Committee and distribute such policies, procedures and guidelines to all employees and independent contractors.
• Ensure that policies, procedures and guidelines are accurate
• Review and suggest/recommend education and training materials.
• Maintain a mechanism for employee reporting, conduct appropriate investigations, adn make recommendations to the Compliance Committee as to needed actions
• Assure independent contractors are aware of and comply with the relevant requirements of Boynton’s compliance plan, policies, procedures and guidelines.
• Submit compliance reports to the University Office of Institutional Compliance.
• Risk Management/OSHA/MERKTAWork with Boynton Health Human Resources Department in monitoring compliance with OSHA, MERTKA, CPR, Fraud, Waste, and Abuse training of employees
• Review Incident Reports and work with supervisors to implement corrective action
• Policies, procedures and guidelines designed to address specific compliance issues will be developed by and presented to the Compliance Committee by the Compliance Director or their designee.
• Develop a reporting mechanism which allows employees and contractors to make reports anonymously, to the extent that is possible.
• Review compliance laws governing kickback arrangement, the physician self-referral prohibition (“Stark”), claim development, reimbursement and submission and marketing as well as review whether or not elements of the compliance plan in the areas of training and education have been met.
• Will, in consultation with legal counsel, engage in external billing review periodically to review a sample of records from each healthcare provider.

Compliance Officer and Compliance Director

• Have the authority to review all documents and records relevant to compliance activities, including but not limited to:  patient records, billing records, and records concerning the marketing efforts of the organization and the organization’s arrangements with other parties.
• Investigate any report non-compliance in consultation with the Office of General Counsel

Privacy Coordinator:

• Serve as University task force member for HIPAA (Health Insurance Portability and Accountability Act) implementation and ongoing monitoring and compliance in the role of Compliance Coordinator. 
• Attend Privacy Coordinator meetings as scheduled by the University of Minnesota Health Information Privacy and Compliance Office (HIPCO).
• Coordinate the HIPAA privacy and security efforts at the health service which include but are not limited to policy and procedure development, education and training, and monitor ongoing regulatory compliance 

Other:

• Serve on the following committees:  Executive Leadership; Leadership; Quality Assurance; Electronic Health Record;Research; Infection Prevention, IT Permission changes review monthly and special work groups as appropriate.
• Attend the Compliance Partner Meeting every other month with campus wide colleagues
• Serve and communicate effectively with students, staff, and faculty from diverse backgrounds,communities, and cultures.