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Compliance Officer

Compliance Officer

Tohono O'odham Nation HealthcareSells, AZ, USA
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Posit ion Summary :

The Compliance Officer promotes the Tohono O'odham Nation Health Care's culture that encourages ethical conduct and commitment to compliance and ensures due diligence to prevent and detect illegal conduct. The work involves investigation and analysis of a variety of compliance issues throughout the Nation's hospital and clinics.

Scope of W ork :

Investigation and analysis projected for proposed and existing TONHC programs for efficiency, effectiveness, and compliance with regulatory and legal requirements. Develops internal controls that adequately measures and manages risks and includes standards, procedures, capable of reducing the prospect of criminal conduct. The incumbent is under the Quality Management Division reporting to the Quality Assurance Officer.

Essent ial Dut ies and Responsibilit ies :

Organization - 50%

  • Exercises oversight responsibility for the TONHC compliance and integrity Uses the TONHC Compliance Plan, Federal Sentencing Guidelines, and the Office of Inspector General (OIG) Program guides to implement oversight functions.
  • Recommends Compliance Program revisions to meet changes in the organization's needs, business, and regulatory environment, to improve its effectiveness.
  • Provides compliance information to help TONHC management find new ways to improve decision making, quality, and reduce its vulnerability to fraud, waste, and abuse.
  • Ensures that independent contractors and agents who provide medical services are educated and aware of the TONHC Compliance Plan.
  • Researches and assists in applying regulatory compliance requirements.
  • Works closely with Chief Legal Officer (CLO), when appropriate to review investigations that result in violations of law that may require reporting to the Office of the Inspector General (OIG), appropriate agencies or fiscal intermediary.
  • Conducts investigations of alleged violations of law, standards of conduct, or any other system policies and procedures within TONHC.
  • Responds to employees by ensuring that reports (phone calls, emails, and interoffice mail) are appropriately investigated and resolved. The Compliance Officer will ensure reports remain anonymous or confidential to the extent possible.
  • Implements, documents and maintains a coordinated legislative and regulatory compliance program that meets the expectations of Tribal, State and Federal regulators and Government programs.
  • Stays abreast of changes to and clarifications of Federal Guidelines regarding meaningful use and EHR certification criteria. I n reference to compliance, will be responsible for developing tools to monitor and devise reporting mechanisms for high-risk areas identified in audits for TONHC.
  • Serves as the chairperson of the compliance Develops agendas, reports, and information as requested by the committee, CEO and Governing Body.
  • Manages the compliance department's administrative This includes organizing and maintaining relevant files, preparing necessary reports on activities and reporting to various TONHC committees.
  • Effectively incorporates the compliance program organizational committee reporting structure. This requirement will also consist of appropriate information and reporting system so that the CEO and Governing Body may exercise timely and informed judgments concerning the health care's compliance with applicable law.
  • Coordinates resources to ensure ongoing effectiveness of the compliance program.
  • Ensures coordination with other departments including the Revenue Enhancement Branch, Human Resources, Information Technology and Clinical Services to ensure effective implementation of TONHC's commitment to compliance and integrity.
  • Reports directly to the TONHC Quality Assurance Officer who will ensure that the CEO and the Governing Body are kept apprised regarding compliance matters.
  • Stops submission of data that he / she believes contains material errors.

Communication and Training 20%

  • Communicates the importance of compliance to senior management, and the TONHC staff, including promoting 1) use of the compliance hotline, 2) increases awareness of principles of integrity and compliance, and 3) understanding of new and existing compliance issues and related policies and procedures using the TONHC compliance plan to educate staff.
  • Conducts training to new and existing employees on compliance Will be required to present compliance education to new staff at the mandatory new staff orientation. Compliance education will be presented to staff at general staff meetings and departmental meetings, and any other forums as requested. Keeps documentation of new staff attendance at education sessions.
  • Develops and maintains productive relationship with supervisors and management staff including the regulators, and other relevant external parties.
  • Works with TONHC leadership to provide adequate information to ensure that they and their employees have the required information and knowledge of regulatory issues and requirements to carry out their responsibilities in a lawful and ethical manner.
  • Develops open lines of communication including non-retaliation.
  • Develops and presents quarterly compliance reports to Senior Management.
  • Monitoring, Auditing and Enforcement - 20 %

  • Conducts periodic reviews to assess adherence to TONHC compliance plan Reviews shall include confirmation that appropriate records have been created and maintained.
  • Takes appropriate action to address issues / problems uncovered in an audit Such action shall include training, Compliance Plan revisions, and Compliance Program revisions. Follow up monitoring will be conducted to ensure corrective action effectiveness.
  • Works with Third Party Billing, Finance, Health Information Management (HIM), and Health Care Providers to ensure audits are completed. Audits will focus on the billing process as identified within the organizations policies and procedures.
  • Conducts reviews focused on compliance with specific rules and policies identified in audits by the Office of Inspector General (OI G) as being problematic and applicable to TONHC.
  • Examines and reviews results of audits with the Senior Management. The Compliance Officer is responsible to take prompt action to correct problems of any deviation caused by improper procedures, misunderstanding of rules, including fraud and system problems.
  • Ensures that TONHC staff implement Corrective Action Plans as a result of an outside survey and / or audit.
  • Coordinates audits in other areas such as claims denial, breaches of privacy, licensures, referral practices and standards of care.
  • Coordinates investigations with CLO for major violations of law or conducts or oversees investigations, as appropriate.
  • Independently manages and resolves unanticipated issues as they The CEO sets overall TONHC goals, and the incumbent is expected to achieve all goals by determining independent strategies, plans and priorities.
  • Works independently and is expected to make immediate decisions on behalf of organization in regard to suspected fraud, waste and Conflict of interest shall be avoided to allow independent and objective reviews for organization.
  • Keeps Quality Assurance Officer abreast of decisions and immediately assuring initiation of corrective action based on objective and substantiated non-compliance information.
  • Policies, Procedures and Standards - 10%

  • Identifies and assess areas of compliance risk for TONHC and develops and updates annually the Risk Matrix and Assessment tool that identifies risk areas with an assessment, action plan and responsible staff member.
  • The Compliance Officer is responsible for coordinating all audits and monitoring high-risk Education and training in risk areas are documented in reports to supervisor. Works with management to ensure training is conducted for employees who work in these areas including those who transfer or are new to the department.
  • Works collaboratively with the Revenue Enhancement Director to enforce compliance to the I HS I nternal Controls Policy ensuring no fraudulent claims are submitted to third party payers. Ensures responsible parties are cognizant and use accurate documentation, billing, and coding.
  • Coordinates monitoring and auditing with other staff to ensure compliance with HI PAA and Privacy Act Law.
  • Develops tracking tool using the RPMS system to monitor electronic protected health information as the use of the electronic health record becomes standard operating procedure to conduct health care.
  • Know ledge, Sk ills, and Abilit ies :

  • Knowledge of Tohono O'odham traditions, language, history, geography, and culture.
  • Comprehensive knowledge of federal and state regulatory laws with regard to healthcare delivery systems and compliance, g. Privacy Act of 1974, H I P AA , Joint Commission on Accreditation of Healthcare Organizations (TJC), etc.
  • Comprehensive knowledge of relevant laws, regulations and policies as they relate to Patient Financial services program and practices and compliance with third-party medical billing and collections requirements, including the requirements for the Centers of Medicare and Medicaid Services and other private payers of medical services and goods.
  • Knowledge of the standards and principles of patient account management requirements including administrative practices and procedures common to healthcare delivery systems.
  • Knowledge of and skill in the use of personal computers, various software and related computer equipment required to maintain databases, prepare reports, and track program activities.
  • Knowledge and ability to properly utilize, implement, and teach the use of electronic data collection.
  • Knowledge of data collection and analysis techniques with ability to format reports using data, with graphs and tending interpretation.
  • Excellent oral and written communication.
  • Strong influencing and perseverance in investigating.
  • Possess the ability to establish coordination with the medical staff to effect change to meet regulatory requirements for TONHC.
  • Ability to extract appropriate information from various sources to analyze data and reports to identify high risk areas and recommend corrective action.
  • Ability to mediate varying views of program requirements and obtain consensus in accepting concepts, plans and specifications to meet the needs of the TONHC.
  • Ability to read, interpret and communicate complex federal regulations and legal documents.
  • Ability to write clear, concise reports, business correspondence and procedures.
  • Ability to utilize organization and analytical skills.
  • Ability to work well both independently and with others in a matrix organization.
  • Ability to effectively present and represent the organization's interest externally with regulators.
  • Ability to effectively present information and respond to inquiries from employees, regulatory agencies, and others.
  • Ability to initiate administrative activities as necessary, and institute quality control procedures.
  • Ability to meet deadlines and adjust to changes in organization's policies, procedures, and priorities.
  • M inim um Qualificat ions :

  • Bachelor's Degree in Health Care Administration, Healthcare Law or closely related field, and
  • Two years' experience, education, or training, involving principles, techniques and accepted practices of healthcare compliance work.
  • Licenses, Cert ificat ions, Special Requirem ent s :

  • Healthcare Compliance Certification is required or must obtain within one year of employment.
  • Experience in the preparation of technical reports on quality levels to identify specific problem areas and to recommend corrective action, preferred.
  • Relevant experience in a Native American community, preferred.
  • Experience with RPMS and IHS EHR, preferred.
  • Must possess and maintain a valid driver's license with no DUI's or major traffic citations within the last three years.
  • Ability to meet the Nation's tribal employer's insurance requirements.
  • Upon recommendation for hire a criminal background and National FBI check is required to determine suitability for hire.
  • Tribal preference and Native American preference shall apply to all positions.
  • Based on the department's needs, incumbents may be required to demonstrate fluency in both the Tohono O'odham and English language as a condition of employment.
  • Physical Dem ands :

    Work is sedentary with some walking, bending, stooping. The work may require long periods of sitting and operating a personal computer. Standing for several hours may be required when conducting training sessions and workshops. Work areas are in different geographic areas (Sells Hospital, San Xavier, Santa Rosa, and San Simon Health Centers). The incumbent must work at all areas on a frequent basis.

    W ork Environm ent

    Work is performed in a typical office setting. Work is primarily sedentary, although some physical effort may be required. I ncumbent is required to operate a government vehicle in the performance of assigned duties under a variety of road and weather conditions and maintain a valid state driver's license.

    This list of duties and responsibilities is illustrative only of the tasks performed by this position and is not all inclusive.

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