Director - Compliance & Internal Audit

The Director of Compliance implements, monitors, coordinates and communicates compliance activities and programs for Connecticut Children’s Medical Center, carrying out the responsibilities set forth below.  The Director of Compliance shall report directly to Connecticut Children’s Senior Vice President, Chief Legal Officer. 

ROLE RESPONSIBILITIES

The functions to be performed by the Director of Compliance include, but are not limited to:

• Works collaboratively with Connecticut Children’s leadership in compliance program (the “Program”) development and implementation; 
• As necessary, assesses and revises the Program to reflect changes in the needs of Connecticut Children’s or modifications to state and federal statutes, rules, regulations or interpretations;
• Conducts annual compliance risk assessments based upon the OIG workplan, changes in regulations, implementation of new services, industry trends, etc.
• Ensures timely, complete and accurate execution of planned audit assignments.
• Ensures that the audit results and conclusions are adequately and timely communicated.
• Performs and manages follow-up on audit findings noted to validate timely, adequate, and effective implementation of prior audit recommendations.
• Defines audit findings and recommendations to enhance business process optimization, increase internal control assurance, and improve compliance adherence. 
• Designs a compliance audit plan to test internal controls over areas of highest risk;
• Advises leadership on issues concerning compliance matters and recommends controls designed to  improve efficiency and quality of service while reducing  vulnerability to fraud and abuse; 
• Encourages and assists with self-audits and monitoring by the various departments within the hospital to provide internal quality assurance over coding and billing; 
• Maintains a current working knowledge of applicable laws, regulations, rules and guidelines and applicable private payer guidelines and requirements; 
• Anticipates and responds to regulatory and accrediting agency requests;
• Establishes effective working relationships and building credibility within Connecticut Children’s to support a culture of compliance;
• Develops policies and procedures that set standards for compliance, giving specific guidance to employees, leadership, physicians, independent contractors and/or agents as appropriate.
• Maintains/oversees and publicizes the corporate compliance hot line to receive reports of compliance questions and concerns while emphasizing collaboration and non-retaliation;
• Develops and directs an educational and training program that focuses on the elements of the Program – including fraud and abuse prevention -  to ensure that all directors, employees, physicians,      independent contractors and agents are knowledgeable of, and comply with, the Program and pertinent Federal and State laws and regulations and requirements of private payors; 
• Coordinates with Connecticut Children’s Human Resources Department to ensure that the Office of Inspector General’s List of Excluded Individuals and Entities and the General Services Administration’s List of Parties Debarred from Federal Programs have been checked with respect to all staff, clinical staff,      independent contractors and agents;
• Conducts or manages the timely investigations of any report or allegation concerning possible unethical or improper practices and recommending corrective action;
• Maintains and updates the Connecticut Children’s Medical Center Code of Conduct;
• Reports to the Audit Committee of the Board of Directors and the Compliance Committee of Connecticut Children’s on a regular basis and if necessary, directly to the Board and/or President and CEO of Connecticut Children’s regarding the status of the Program and compliance related issues; 

SUPERVISORY RESPONSIBILITIES

• Facilitates and serves as Chair of the Corporate Compliance Committee.
• Supervises the evaluation of key risks and internal controls, reviews and approves audit programs/risk & control matrices, and evaluates opportunities for efficiencies/performance process improvements; 
• Defines and implements audit procedures, tools, and methodologies for sample selection, data analytics, audit planning, audit testwork, and audit communication and reporting.   
• Supervises planning, scheduling, execution, and reporting of audit engagements and projects within established timelines and budgets; 
• Reviews work papers and validates audit observations to ensure audit findings/root causes, risks/exposures, and recommendations for improvement are clearly articulated.
• Supervises team interactions with clients to ensure the audit communication flow is efficient and effective.
• Leads overall team development and performance activities; responsible for employee recruitment, selection and training, performance assessment, work assignments, salary, recognition/disciplinary actions, coaching, and mentoring; keeps the Vice President and General Counsel informed of progress and developmental issues. 
• Manages and oversees team in revenue cycle auditing activities to ensure patient charges and provider documentation is in compliance with appropriate payor contracts, federal and state guidelines, and internal procedures;
• Manages and oversees team in general and study-specific research and clinical trial auditing activities to ensure compliance with SOP’s, FDA, GCP, NIH and applicable regulations.
• Acts as a liaison between the institutional review committees, regulatory agencies, and the investigators to ensure that protocols are approved and that supplementary information is provided in a timely fashion as requested.

EDUCATION and/or EXPERIENCE REQUIRED

• B.A. or B.S. in Accounting, Finance, Health Care Administration, Mathematics, Information Systems or similar field is required. Master’s Degree/Juris Doctorate preferred. Minimum of five years’ experience in health care finance, reimbursement, public or other accounting, auditing, budget, compliance, billing or insurance required with progressive responsibility in analysis and project management. Previous experience at a Big 4 or large regional accounting firm strongly preferred.

LICENSE and/or CERTIFICATION REQUIRED

• Certification in compliance with a nationally recognized association required.
• Certified Public Accountant (preferred but not required)
• Certified Internal Auditor CIA (preferred but not required)      

  KNOWLEDGE, SKILLS AND ABILITIES REQUIRED

• Knowledge of State and Federal Medicaid and Medicare billing rules and program regulations.
• Recognized for demonstrated knowledge in compliance process improvement and the requirements of Federal healthcare programs.
• Knowledge of health care billing revenue process, accounting and auditing theory is required and assumed. 
• Proficiency in use of information systems, databases and Microsoft Office Suite.