General Counsel and Compliance Officer

The Compliance Officer and General Counsel plays a crucial role in fulfilling the commitment of Community Medical Centers, Inc. (CMC) to provide the best quality of care possible as well as the continuous assessment and improvement of the quality of care and the services. This position has the principal authority and responsibility for the development, implementation, oversight and evaluation of a dynamic integrated enterprise risk management and compliance program organization wide. This position reports to the Chief Executive Officer and will advise the CEO on legal strategies to enhance the work of the community health center.

SPECIFIC DUTIES:

Serves as health center counsel advising the CEO on legal strategy and coordinates work with external attorneys.

Coordinates with CEO or his/her delegate on composition and delivery of responses to state regulatory agency complaints and inquiries.

Stays current on all HRSA 330 Federal Grant requirements, notifies leadership of important updates, and prepares CMC for HRSA On-Site Visits.

Assists in the completion of applications to state agencies such as California Department of Public Health, the Department of Health Care Services, and the Board of Pharmacy.

Drafts and reviews all health center contracts, MOU’s, and grant agreements

With the help of the Document Control Specialist, ensures all agreements are archived and logged into our contract management system.

Ensures any contracts for goods or services follow HRSA 330 Grant requirements.

Drafts formal correspondence to opposing parties in the event of a contract dispute.

Oversees the development, management and annual review of CMC’s policies and procedures, in collaboration with policy owners and executive reviewers.

Supervises the Document Control employees who oversee the contract management system, policy and procedure management system, and claims management.

Develop an enterprise risk and compliance strategy including objectives, identification of key risks, and controls that are aligned with policies, procedures and operating principles.

Develop and implement a corporate infrastructure that facilitates early identification of new risks, incident identification, communication, issues management and internal and external reporting.

Annually conduct a Compliance training to all front line staff.

Cultivate relationships with front line staff to foster a culture of safety and be available to consult with front line staff on compliance related issues.

Advises front line staff on patient consent issues, minor consent issues, mandated reporting, and any other patient issues that may arise.

Develop relationships with front line staff and become a

Supports the Chief Medical Officer in the clinical risk management processes to ensure a culture of safety, timely capture of events, reporting to insurance and federal agencies and initiation of risk analysis for all events.

Supports the Director of Human Resources the management of the Workers’ Compensation Insurance coverage to include Workplace Safety Risk Controls and Claims Management.

Oversee and monitor the development and implementation of the Corporate Compliance Plan, Manual and Work Plan

Establish methods such as conducting periodic audits, developing effective lines of communication on compliance issues, and preparing written practice standards and procedures to improve the health center’s efficiency and quality of services and to reduce health center’s vulnerability to fraud and abuse as outlined by the Office of the Inspector General.

Chair the Corporate Compliance and Risk Management Committee

Periodically revise the Compliance Plan, by recommending such revisions to the Corporate Compliance and Risk Management Committee, in light of changes in the needs of health center or changes in the law and/or in the standards and procedures of government and private payer health plans

Advise the Security Officer on matters related to HIPAA regulations and required controls including periodic Risk Assessments

Advise the Privacy Officer on matters related to HIPAA regulations and required controls, including Medical Records Release of Information.

Ensure that independent contractors, consultants and volunteers who furnish medical services to health center are aware of the requirements of the Corporate Compliance Plan

In conjunction with the Director of Human Resources, insure that the HHS OIG's List of Excluded Individuals and Entities, and the General Services Administration's (GSA's) List of Parties Debarred from Federal Programs have been checked with respect to all employees, medical staff and independent contractors

Monitor the Compliance Hotline; Investigate and resolve any reported issues.

Independently investigating and acting on any report or allegation of unethical or improper conduct or business practices, reporting on the results of such investigations to the Corporate Compliance and Risk Management Committee, and implementing and monitoring appropriate corrective action and/or subsequent compliance

Reporting on a regular basis to the Board of Directors and CEO on the progress of the Compliance Plan's implementation and on the methods adopted to improve the health center’s efficiency and quality of services and to reduce its vulnerability to fraud and abuse.

Responsible for the management and processing of FTCA claims and serves as the claims point of contact any such claims.

Responsible for the review and management of all potential or actual claims such as employment, workers compensation, medical malpractice, and professional board complaints.

Supports the medical records department by reviewing subpoenas and helping staff determine how to answer the subpoena.

Continuing the momentum of the Corporate Compliance Plan and the accomplishment of its objectives after its implementation.

Participates on the Quality Improvement Committee, the Retirement Committee, and the Leadership Group.

Other duties as assigned

Qualifications

MINIMUM REQUIREMENTS:

Bachelor’s degree in related field and a minimum of 3 years of recent experience in health care corporate compliance and risk management at a manager level or above.

Juris Doctor Degree and successfully passed the California Bar Exam

Three years of legal or health care experience is highly recommended.

Knowledge of healthcare issues in FQHC’s and a proven track record in leading healthcare programs.

Knowledge of State and Federal healthcare regulations including CA Title 22, Joint Commission Standards, HRSA 330 Grant Requirements, HIPA/CMIA/42 CFR Part 2 or any other relevant privacy laws, and CMS Conditions of Participation.

Excellent written and verbal communication skills

Valid California Driver's License, proof of insurance and personal transportation.

PERFORMANCE REQUIREMENTS:

Knowledge, Skills and Abilities

Highly effective collaboration skills, written and verbal communications skills.

Computer competent and able to present key information in a succinct and clear manner.

Ability to facilitate conflict resolution, competent in identification of risk situations and resolution.

Ability to communicate well with families, patients, staff and physicians based on age, cultural beliefs and educational level.

Attention to detail, meticulous development and maintenance of regulatory paperwork.

Speaks with confidence and command.

Knowledge of organizational policies, procedures and systems

Ability to interact with internal personnel and external agencies requiring reasonable tact, discretion, and self-expression.

Ability to maintain open dialogue with supervisors and management staff

Ability to work independently, use good judgment, maintain excellent communication skills and self-initiative

Ability to read, understand, and follow oral and written instructions

Ability to establish and maintain effective working relationships with employees and the public

TYPICAL PHYSICAL DEMANDS:

Must be able to lift up to 40 pounds and push up to 100 pounds (on wheels)

Must be able to hear on the phone and those who are served in person, and speak clearly in order to communicate information to staff

Must have vision with or without lenses that is adequate to read memos, a computer screen, personnel forms and other documents

Must have high manual dexterity

Must be able to reach above the shoulder level to work, must be able to bend, squat and sit, stand, stoop, crouch, reach, kneel, twist/turn, fingering and feeling

TYPICAL WORKING CONDITIONS

Work is performed in an office environment within a clinic setting. Involves frequent contact with staff and the public. Work may be stressful at times. Contact may involve dealing with upset people.

EOE