Ethics and Compliance Officer I

PURPOSE AND SCOPE:

Supports Fresenius Medical Care North America's mission, vision, core values and customer service philosophy. Adheres to the FMCNA Compliance Program, including following all regulatory and division/company policy requirements.

Responsible for the development, implementation and communication of the FMCNA compliance program. Implements and monitors compliance as it relates to the assigned division and participates as a member of the divisional management team. Responsible for assisting in the development, implementation and ongoing revision of policies and procedures published through the Compliance department, as well as ensuring that existing and new company policies and procedures are consistent with the objectives of the Compliance department. Assists the assigned business in their efforts to comply with all applicable state and federal laws and regulations. Collaborates with Compliance Audit to contribute to projects related to the Compliance Audit, Self-Monitoring, Data Mining and Risk Assessment programs for the assigned division. Acts as the Privacy and Security Officer for the assigned division. Supports the Vice President or Senior Director of Compliance and the Chief Compliance Officer.

PRINCIPAL DUTIES AND RESPONSIBILITIES:

• Applies a highly advanced knowledge of compliance and a developed understanding of the business of FMCNA and the assigned division to function as a member of the assigned division's management team, working to mitigate the risks that impede the division's goals.
• Acts as an accessible, visible and available subject matter expert for the business.
• Establishes a compliance culture as a strategic, competitive advantage.
• Adapts to and reacts to the needs of a rapidly growing and changing business and understand the complexities of a large organization.
• Maintains current knowledge of law, regulation, and market changes that impact all aspects of the business including, but not limited to, Stark Law, Anti-Kickback Statute, Patient Inducement Statute, Health Insurance Portability and Accountability Act, relevant Office of Inspector General (OIG) Model Guidance and applicable Advisory Opinions.
• Works independently and autonomously, often leading projects.  May refer to other senior staff for assistance with higher level problems as they arise.
• Acts as a mentor and point of reference to junior level staff with general tasks that require a better understanding of functions.
• Consistently demonstrates sound judgement and strong capability across a wide range of subject matters.
• Adeptly identifies gaps and inefficiencies in compliance systems and processes.  Proposes proportionate remediation measures.
• Works in conjunction with the law department, regulatory and government affairs to better understand operational requirements under the law. Assists the business in implementing policies, processes and monitoring systems in an effort to remain compliant.
• Leads the FMCNA compliance activities within the division to support and enforce the overall Compliance program policies, procedures and standards, and compliance with applicable laws and regulations. Participates in the periodic review and update of FMCNA Compliance program policies, procedures, and training, to ensure continuing relevance in providing guidance to management and employees.
• Actively participates on the assigned division's Management team to discuss high level issues affecting the business and operations and to act as a resource for the division's management team for all compliance issues.
• Identifies key risk areas and works with the assigned division to mitigate risk through education, training, policy development and monitoring systems. Responsible for developing, implementing and maintaining relevant compliance training materials.
• Provides guidance to the assigned division in the development and interpretation of policies and procedures.
• Participates in the development and review of new business activities and programs.
• Serves as a resource for employees of the assigned division. Coordinates the resolution of compliance-related issues and concerns with the appropriate staff in a timely manner.
• Assists the business in the development and implementation of compliance training programs and educational material tailored to the specific needs of the division, consistent with the Corporate Compliance goals. Programs include introductory training for new employees as well as ongoing training as required. Delivers compliance training presentations as necessary, live or via WebEx.
• Participates in the development of the annual FMCNA compliance plan, including annual compliance plans tailored to the assigned division(s). 
• Acts as the Privacy and Security Officer for the assigned division(s). Works with the FMCNA Privacy and Security Officer in resolving privacy and security issues.
• Directs or participates in - collaborating with other departments as applicable - the timely closure of Compliance Action Line (CAL) investigations along with other potential compliance issues not reported through the CAL. Responds appropriately to alleged violations of rules, regulations, policies, procedures, and the FMCNA Code of Conduct.
• Acts as liaison with counterparts in the department that support other assigned divisions regarding compliance concerns across assigned divisions. Assists with coverage of other divisions as needed.
• Assists with activities related to outside investigations, including but not limited to potential fraud and abuse issues, which could be either general or targeted. Assists external counsel in identifying and reviewing pertinent documents.
• Participates in activities related to exclusion screening, which applies to new hires, current employees, vendors and providers. Investigates and resolves any potential matches.
• Participates in activities related to professional licensure lapses and identifies excluded parties to ensure that appropriate employee earnings' paybacks have been determined and collected.
• Responsible for case management of current or prior compliance initiatives launched in assigned division. Assigns tasks to sub-committees for corrective action plans. Ensures necessary follow-up takes place to resolve open items and that controls are in place to successfully mitigate business and regulatory compliance risks.
• Provides technical expertise, corrective action planning, and other compliance consultation as needed with respect to the assigned division.
• Participates in various committees and task forces on a Corporate, divisional and cross-divisional basis, and coordinates and manages compliance projects as required.
• Participates in the review of compliance due diligence materials in anticipation of potential acquisitions or divestitures.
• Acts as a compliance liaison with external agencies regarding compliance concerns as they relate to the operations and compliance for the assigned division.
• Assists with the monthly Corporate Compliance meeting, ensuring high level compliance issues are addressed. May be required to provide presentations on new initiatives, to report on the results of case management, or to schedule speakers.
• Serves as a member of the assigned division's Donations Committee to monitor that donation requests are appropriate and within FMCNA policy.
• Provides status updates to the assigned division and Corporate Compliance related to investigations, audit and other identified reportable issues.
• Adapts to and reacts to the needs of a rapidly growing and changing business.
• Completes special projects and reports as needed by the VP or Senior Director of Compliance.
• Other duties as assigned, including department wide projects.

Additional responsibilities may include focus on one or more departments or locations.  See applicable addendum for department or location specific functions.

PHYSICAL DEMANDS AND WORKING CONDITIONS:

• The physical demands and work environment characteristics described here are representative of those an employee encounters while performing the essential functions of this job.  Reasonable accommodations may be made to enable individuals with disabilities to perform the essential functions.
• Travel is expected to be up to 25% of overall work time.

EDUCATION:

• Bachelor's degree required.
• Law, MBA or advanced Degree preferred. 
• Professional certification such as State Bar Membership, CHC, CIPP or CHPC is a plus.

EXPERIENCE AND REQUIRED SKILLS:

• 8 - 12 years' experience in healthcare and/or compliance, or 6 years healthcare and/or compliance experience with a relevant Master's degree.
• Experience in relevant healthcare field preferred
• Strong writing skills with specific experience in the areas of developing, implementing and maintaining policies, procedures and training in a healthcare environment.
• Strong communication, interpersonal and presentation skills, working with both internal and external individuals and entities
• Ability to motivate, lead and coordinate cross-functional teams of senior management personnel.
• Analytic and project management, leadership and team building.
• Strong computer skills, including Excel, Word, and PowerPoint.

EO/AA Employer: Minorities/Females/Veterans/Disability/Sexual Orientation/Gender Identity

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Fresenius Medical Care North America maintains a drug-free workplace in accordance with applicable federal and state laws.