Head of Compliance
负责领导医疗保健合规策略:制定,实施和维护符合适用的医疗保险与医疗补助服务中心 (CMS) 的要求,总检查员办公室的指导,州法规和商业付款人政策的综合合合规范。监督 PC-MSO 合规:确保组织的专业公司和管理服务组织结构遵守适用要求,包括管理服务协议,国家特定的企业实践医学规则,公平市场价值费,以及临床和商业决策分离。管理 HIPAA 隐私和安全:领导组织的隐私和安全计划,包括政策制定,风险评估,商业合作伙伴协议 (BAA),员工培训,访问审查,事件管理和违规应对。审计编码和发票实践:审查医疗保险 B 部分护理管理,评估和管理 (E&M) 的编码和账单以及相关服务以验证文件,时间要求和索赔提交符合适用的标准。监督收入周期遵守:评估终端到终端的收入周期管理流程,包括资格验证,索赔提交,拒绝管理,上诉,患者成本共享收费,豁免实践和过度支付识别和退款。监督监管发展:追踪年度医疗保健医生费用日程更新,国家正确编码倡议 (NCCI) 修订,医疗保健行政承包商 (MAC) 指导,OIG 工作计划优先事项,执行行动以及不断变化的医疗补助和商业支付者要求。防止欺诈,浪费和滥用:建立防范措施,防止违反抗杆行为条例,斯塔克法,虚假索赔法案以及受益者诱导限制,特别是在患者接触,注册,推介关系和伙伴关系安排方面。构建并维护合规计划:制定和监督基于 OIG 通用合规方案指南的结构化项目,包括书面政策,员工教育,监控,审计,报告频道和定期更新领导人员。将规定转换为可操作的指导方针:解释复杂的监管要求,用清晰的实际方式,并帮助团队了解其对临床运营,收费实践,产品开发和业务决策的影响。
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Accountabilities
Lead healthcare compliance strategy: Develop, implement, and maintain a comprehensive compliance framework aligned with applicable Centers for Medicare & Medicaid Services (CMS) requirements, Office of Inspector General (OIG) guidance, state regulations, and commercial payer policies.
Oversee PC-MSO compliance: Ensure the organization's professional corporation and management services organization structure complies with applicable requirements, including management services agreements, state-specific corporate practice of medicine rules, fair-market-value fees, and the separation of clinical and business decision-making.
Manage HIPAA privacy and security: Lead the organization's privacy and security program, including policy development, risk assessments, business associate agreements (BAAs), workforce training, access reviews, incident management, and breach response.
Audit coding and billing practices: Review Medicare Part B coding and billing for care management, evaluation and management (E&M), and related services to verify that documentation, time requirements, and claim submissions meet applicable standards.
Oversee revenue cycle compliance: Evaluate end-to-end revenue cycle management processes, including eligibility verification, claim submission, denial management, appeals, patient cost-sharing collection, waiver practices, and overpayment identification and refunds.
Monitor regulatory developments: Track annual Medicare Physician Fee Schedule updates, National Correct Coding Initiative (NCCI) edits, Medicare Administrative Contractor (MAC) guidance, OIG Work Plan priorities, enforcement actions, and evolving Medicaid and commercial payer requirements.
Prevent fraud, waste, and abuse: Establish safeguards against violations of the Anti-Kickback Statute, Stark Law, False Claims Act, and beneficiary-inducement restrictions, particularly in patient outreach, enrollment, referral relationships, and partnership arrangements.
Build and maintain the compliance program: Develop and oversee a structured program based on OIG General Compliance Program Guidance, incorporating written policies, employee education, monitoring, audits, reporting channels, and regular updates to leadership.
Translate regulations into actionable guidance: Explain complex regulatory requirements in clear, practical terms and help teams understand their implications for clinical operations, billing practices, product development, and business decisions.
Embed compliance into technology: Partner with engineering and product teams to integrate regulatory requirements, privacy safeguards, documentation standards, and compliance controls directly into software and operational workflows.
Provide compliance training and guidance: Educate employees and relevant stakeholders on regulatory obligations, internal policies, billing standards, privacy practices, and procedures for reporting potential violations.
Investigate and remediate compliance issues: Identify potential gaps, assess risks, recommend corrective actions, and oversee remediation to prevent recurring issues and strengthen organizational accountability.
Advise executive leadership: Provide clear assessments of compliance risks, emerging regulatory changes, audit findings, and recommended actions to support informed strategic decision-making.
Support scalable growth: Ensure compliance processes evolve alongside changes in healthcare services, reimbursement models, technology, and geographic expansion.
Requirements
Professional experience: At least seven years of experience in healthcare compliance, with substantial hands-on responsibility for Medicare Part B billing and coding.
Medicare and payer expertise: Deep working knowledge of Medicare, Medicaid, and commercial insurance requirements, including reimbursement policies, documentation standards, coding rules, claims processing, and payer-specific regulations.
PC-MSO experience: Direct experience working with a professional corporation and management services organization structure, or a comparable physician-practice management model.
Healthcare regulatory knowledge: Strong understanding of HIPAA, the Anti-Kickback Statute, Stark Law, and the False Claims Act, including their practical implications for healthcare operations and business arrangements.
Coding and reimbursement expertise: Familiarity with Medicare coding requirements and reimbursement changes affecting care management, E&M services, telehealth, and remote monitoring. Ability to understand how codes are introduced, revised, bundled, revalued, or retired and how these changes affect compliance.
Revenue cycle management experience: Practical knowledge of eligibility verification, claim submission, denials, appeals, patient cost-sharing, waiver restrictions, and overpayment refunds.
Compliance program management: Experience developing and operating compliance programs that include policies, risk assessments, audits, monitoring, workforce education, incident reporting, and corrective action plans.
Regulatory monitoring and interpretation: Ability to stay current with CMS rulemaking, the annual Physician Fee Schedule, NCCI edits, MAC guidance, OIG enforcement priorities, and state and commercial payer updates.
Privacy and security knowledge: Experience managing HIPAA compliance, privacy and security risk assessments, vendor agreements, access controls, workforce training, and breach response.
Preferred professional certifications: Certifications such as Certified in Healthcare Compliance (CHC), Certified in Healthcare Privacy Compliance (CHPC), Certified Professional Coder (CPC), or Certified Professional Compliance Officer (CPCO) are advantageous.
Preferred clinical services experience: Familiarity with Chronic Care Management (CCM), Principal Care Management (PCM), Advanced Primary Care Management (APCM), Behavioral Health Integration (BHI), remote patient monitoring, or telehealth services.
Managed care experience: Experience working with Medicare Advantage and Medicaid managed care plans across multiple states is preferred.
Legal and advisory background: A Juris Doctor (JD) degree or experience working closely with healthcare legal counsel is an advantage.
Technology collaboration: Ability to work effectively with engineers, product managers, clinical teams, and operational stakeholders to incorporate compliance requirements into software and business processes.
Analytical and risk-management skills: Strong judgment and attention to detail, with the ability to identify material compliance risks, prioritize remediation, and develop practical, proportionate solutions.
Communication skills: Excellent written and verbal communication skills, including the ability to explain complex regulatory issues in accessible language and provide clear recommendations that teams can implement.
Startup adaptability: Comfortable working in a fast-moving, evolving environment, balancing strategic leadership with hands-on execution and adapting compliance processes as the organization grows.
Professional integrity: Demonstrated discretion, accountability, independence, and commitment to ethical conduct and patient-centered healthcare delivery.
Benefits
Flexible part-time arrangement: Fractional leadership opportunity with flexible working hours.
Remote work: Work remotely from within the United States.
Strategic leadership impact: Shape the compliance strategy and regulatory foundation of a growing, technology-enabled healthcare organization.
Broad organizational influence: Collaborate with clinical, operational, legal, and technical teams to embed compliance throughout healthcare delivery and software development.
Innovation-focused environment: Help integrate regulatory safeguards into technology-enabled care models and evolving healthcare workflows.
Meaningful mission: Contribute to improving how Medicare patients navigate healthcare and access appropriate care and support.
Professional growth: Apply and expand expertise across healthcare regulation, reimbursement, privacy, revenue cycle management, and compliance program development.
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