SVP Chief Corporate Ethics & Compliance Officer

JOB SUMMARY

The Chief Corporate Ethics & Compliance Officer (CCECO) will direct and oversee the corporate compliance program for Baylor Scott & White Health. In this role, the CCECO will oversee a department of compliance and privacy professionals that includes over 60 FTEs, with the following areas reporting through the CCECO:
- Privacy
- Compliance Operations, including the Compliance Hotline and Conflicts of Interest
- Regional Compliance
- Billing, Regulatory and Coding Compliance
- Research Compliance
- Health Plan Compliance
- Value Based Care Compliance
- Third Party Compliance
- Physician Compliance
- Compliance Training and Communications
- Internal Audit – The VP of Internal Audit reports to the Audit and Compliance Committee directly and administratively reports to the CCECO.
- There is a dotted line affiliation with Information Security.

The CCECO has a direct relationship with the Audit and Compliance Committee of the highest governing board of Baylor Scott & White Health and, along with the Chief Financial Officer and Chief Legal Officer, provides key staff support to the Chair of the Audit and Compliance Committee.

ESSENTIAL FUNCTIONS

This is a mission critical position dedicated to the development of a Compliance Program serving the needs of a leading and growing integrated healthcare delivery system. The CCECO:
- Develops and oversee an integrated, enterprise-wide compliance and privacy program.
- Serves as a role model for ethical management behavior, promotes an awareness and understanding of positive ethical principles and compliance with federal and state law, and assists in planning and identifying priorities for the Compliance Program.
- Oversees strategic planning, implementation, and operation of an effective Compliance Program with direct access and accountability to the CEO and Board of Trustees of Baylor Scott & White Health and Audit and Compliance Committee.
- Regularly reviews the Compliance Program and recommends appropriate revisions and modifications.
- Advises senior leadership and BSW Health of potential compliance risk areas.
- Presents periodic and annual compliance reports and education to the BSW Health Board of Trustees, the BSWH Corporate Compliance Committee, BSWH senior management, and other fiduciary boards.
- Coordinates with the BSWH Chief Legal Officer on matters of legal oversight and review and resolution of compliance matters.
- Identifies and assesses areas of compliance risk for Baylor Scott & White Health and guides the Compliance Program to effectively prevent and/or detect violations of law, regulations, BSWH policies, or the Code of Conduct.
- Designs internal controls that are capable of preventing and detecting significant instances or patterns of illegal, unethical, or improper conduct by employees, agents, affiliated providers, or others working with BSWH.
- Encourages the prompt and proper resolution and implementation of audit or review recommendations.
- Collaborates with legal counsel to conduct or authorize and oversee investigations of legal matters that merit investigation under the Compliance Program.
- Provides input and/or direction to Human Resource policies and procedures, and the performance management system and incentive programs, to discourage improper conduct and support conformity with the Compliance Program in the performance management process for all employees.
- Oversees activities with respect to the BSWH conflict of interest’s disclosure process.
- Identifies, develops and implements system-wide education and communication programs to educate all employees and affiliated parties on the BSWH Code of Conduct, the Compliance Program, and other specific compliance areas deemed necessary.
- Implements and operates retaliation-free reporting channels, including an anonymous telephone and web-based reporting system available to all employees, volunteers, and affiliated providers, and oversees the resolution of investigations and other issues identified by or reported to the Compliance Program, including development of corrective action plans, as needed.
- Develops and oversees the strategic auditing and monitoring plan for evaluating the performance of the Compliance Program and related activities to identify risks and initiate appropriate steps to improve effectiveness and mitigate risks.

PREFERRED CANDIDATE PROFILE

- Experience serving as compliance officer or regulatory counsel for an integrated healthcare delivery system including the following core functions: hospitals, physician clinics, academic medicine (UME and GME), research, ambulatory sites, joint venture relationships (including physician/hospital joint ventures), accountable care organizations and clinically integrated networks, health plan (including Medicare Advantage and Medicaid), pharmacy and 340b, provider-based billing and reimbursement, digital health, and tax-exemption.
- Proactive, collaborative executive.
- Visible, approachable individual who is an effective communicator and educator
- Strategic business partner dedicated to managing and reducing potential risk and exposure while furthering strategic objectives.
- Leader and motivator of people and teams.
- Servant leader who is passionate about the mission of BSWH and those we serve
- Solution-oriented team player who has credibility and integrity, provides counsel and contributes broadly as a subject matter expert.
- Capable of nurturing a culture that actively seeks input from compliance to further optimize BSWH’s day-to-day operations.

MINIMUM REQUIREMENTS

- Bachelor’s degree required.
- Juris Doctor, Master’s degree in Business, Healthcare Administration, or equivalent degree is preferred. Certification in Healthcare Compliance (CHC, CHC-F, CHRC and/or CCEP) is preferred.
- At least ten years’ experience in healthcare and knowledge of all elements of corporate compliance for an integrated healthcare delivery system.