Associate Compliance Officer

Job Description

Job Description

JOB DESCRIPTION

JOB TITLE: Associate Compliance Officer
FLSA STATUS: Exempt
DEPARTMENT: Compliance
REPORTS TO: Compliance Officer

JOB SUMMARY

The Associate Compliance Officer, in conjunction with the Compliance Officer, is responsible for the development, implementation, operation, and monitoring of the Compliance Program to ensure regulatory requirements are met.

ESSENTIAL JOB FUNCTIONS

Compliance Program

• Alongside the Compliance Officer, direct, coordinate, and monitor efforts to ensure operational compliance with:

  • Applicable federal and state laws and regulations.

  • Centers for Medicare and Medicaid Services (CMS) contract and Part C and Part D Program requirements.

  • Compliance Department and operational policies and procedures as they relate to compliance.

  • Plan conduct requirements.

• Alongside the Compliance Officer, embody and promote an overall culture of compliance that encourages ethical conduct and a commitment to compliance with the law.

• Manage the Compliance Department alongside the Compliance Officer.

• Oversee and monitor implementation and effectiveness of the Compliance Program, including through supervision of direct employees who assist in Compliance Program efforts.

• Develop the Compliance Committee.

• Manage the Compliance Department, including management of the Compliance Program, to ensure that compliance goals are met and that resources are used effectively.

Compliance Committee Involvement

• Alongside the Compliance Officer, oversee the Compliance Committee, including scheduling meetings, developing appropriate agendas with a standing FWA agenda item, compiling reports and information as requested by the Compliance Committee, and maintaining meeting minutes.

• Present the findings of any internal or external audit at the first regularly scheduled Compliance Committee meeting after the conclusion of the audit, or sooner, as necessary.

• Stay abreast of evolving CMS and other compliance program expectations.

• Make reasonable efforts to stay abreast of current and evolving legal and program standards through review of regulatory and other materials, publications, websites, and guidelines, including Health Plan Management System memoranda issued by CMS or other relevant government agencies.

Internal Reporting Responsibility

• Alongside the Compliance Officer, report frequently, as necessary and appropriate, to the CEO, legal counsel, and the Compliance Committee on compliance issues and the status of the Compliance Program, unless such reporting would compromise an ongoing investigation or other confidential information.

• Report on a regular basis, at least quarterly, or more frequently as necessary, to the Board of Directors on the implementation and effectiveness of the Compliance Program.

• Provide reports containing an update concerning the activities and status of the Compliance Program, including, without limitation:

  • The status of compliance training when relevant.

  • Issues identified, investigated, and resolved by the Compliance Program.

  • State or federal audits or enforcement activity.

  • A summary of monitoring and auditing activities.

  • A description of FWA activities.

• In conjunction with the Compliance Officer and the Compliance Committee, provide the results of the annual readiness and risk assessment to the Board of Directors.

Policies and Procedures/Code of Conduct

• Alongside the Compliance Officer, develop written Compliance Program policies and procedures that meet CMS regulatory and other requirements and are designed to:

  • Implement an effective Compliance Program.

  • Address existing and new compliance risk areas.

• Work with senior management, as appropriate, to ensure that operational policies and procedures contain effective internal controls designed to prevent and detect significant instances or patterns of illegal, unethical, or improper conduct or FWA.

• Periodically review, modify, and amend, or work with others to modify and amend, the Compliance Program, including the Code of Conduct and the Compliance Program policies and procedures, as necessary, and present the same for Board of Directors approval when appropriate.

Education and Training

• Alongside the Compliance Officer, create, coordinate, and appropriately document education and training programs relating to the Compliance Program and FWA prevention, detection, and correction programs.

• Review and update education and training programs as necessary, but at least annually.

• Develop and implement mechanisms for testing the effectiveness of relevant education and training programs as directed by CMS or other oversight bodies.

• Work with senior management and FDRs, as appropriate, to ensure that these individuals and entities and their staff have the requisite information and knowledge concerning program requirements to carry out their responsibilities in a lawful and ethical manner, including through appropriate specific training.

Communication Regarding the Compliance Program

• Alongside the Compliance Officer, appropriately publicize the existence of the mechanism for reporting suspected instances of non-compliance, such as through periodic emails to employees or FDRs, posting information in prominent common areas, brochures, intranet, and internet.

• Develop and implement methods and programs that encourage the asking of compliance-related questions and the reporting of suspected fraud, misconduct, and other non-compliance, including through anonymous and confidential good-faith reporting of potential non-compliance or FWA through the compliance hotline, without improper retaliation.

• Develop and implement systems to ensure that member compliance-related issues are appropriately directed to the Compliance Department for consideration and/or investigation.

• Respond appropriately to compliance questions and inquiries.

FWA Prevention, Detection and Correction Program and Related Matters