VP, Chief Compliance Officer

Vice President & Chief Compliance Officer

The Vice President & Chief Compliance Officer provides strategic and independent leadership for Boston Medical Center Health System's compliance and privacy programs across Boston Medical Center hospitals, Health Plan, and Physician Organizations. The position designs, implements, evaluates, and continuously improves an effective enterprise compliance program that identifies, prevents, detects, investigates, and remediates potential violations of law, regulation, policy, and ethical standards.

Reporting to the Senior Vice President, General Counsel, the Vice President & Chief Compliance Officer leads the Health System's compliance and privacy staff and has direct and unrestricted access to the Chief Executive Officer, senior leadership, and the Audit and Compliance Committee of the Board regarding significant compliance matters.

Essential Responsibilities / Duties:

• Establishes, leads, and continuously improves the Health System's enterprise compliance and privacy program to prevent, detect, and address conduct inconsistent with applicable laws, regulations, contractual requirements, ethical standards, and Health System policies. Maintains the independence, authority, visibility, and resources necessary to administer an effective compliance program, working directly with senior leadership, and the Audit and Compliance Committee of the Board.
• Leads the enterprise compliance risk assessment and annual compliance work-planning process to identify and prioritize regulatory, billing, privacy, operational, financial, and business-conduct risks. Oversees risk-based monitoring, auditing, data analysis, and testing activities; develops key compliance indicators; evaluates trends, audit findings, training completion, reporting activity, and corrective-action status; and uses results to assess program effectiveness and implement continuous improvements.
• Directs the intake, triage, investigation, escalation, documentation, and resolution of reported compliance and privacy concerns in coordination with Legal, Human Resources, Internal Audit, Information Security, and other functions, as appropriate. Maintains confidential reporting channels, promotes good-faith reporting without fear of retaliation, evaluates substantiated concerns for root causes, and ensures timely and sustainable corrective-action plans are implemented and monitored. Advises senior management regarding appropriate remediation and disciplinary action for confirmed violations or failures to report or address known concerns.
• Provides enterprise oversight of healthcare regulatory compliance and privacy activities, including billing, coding, clinical documentation, reimbursement, medical necessity, cost reporting, government program requirements, and arrangements involving referral sources. Supports compliance with applicable federal and state healthcare laws, including the False Claims Act, Anti-Kickback Statute, Stark Law, Civil Monetary Penalties Law, exclusion requirements, and other fraud-and-abuse provisions. Oversee compliance with HIPAA Privacy, Security, and Breach Notification requirements and 42 CFR Part 2 and participates in the assessment, investigation, mitigation, notification, and remediation of potential privacy and information-security incidents.
• Develops and oversees enterprise compliance and privacy education, communication, and policy-management programs to ensure employees, leaders, clinicians, contractors, and other workforce members understand applicable standards, policies, reporting expectations, and individual responsibilities. Maintains and regularly updates the Code of Conduct, compliance and privacy policies, training materials, and related communications. Promotes a culture of integrity, accountability, transparency, ethical decision-making, and non-retaliation through visible leadership and ongoing engagement with clinical and operational teams.
• Oversees compliance due diligence and monitoring related to third parties, transactions, and business arrangements, including vendors, contractors, delegated entities, providers, business partners, and other external parties. Ensures effective processes are maintained for required exclusion, debarment, licensure, and sanction screening. Advises on compliance considerations associated with acquisitions, affiliations, joint ventures, clinical arrangements, value-based care initiatives, new programs, and other significant business activities.
• Coordinates the Health System's response to compliance-related government and payer inquiries, audits, subpoenas, investigations, and information requests in partnership with Legal Counsel and other appropriate leaders. Evaluates potential over payments, reportable events, and disclosure obligations and oversees timely remediation, repayment, reporting, or self-disclosure when required. Ensures the Health System cooperates with government and payer reviews and maintains appropriate documentation, escalation, and…