Associate General Counsel; Regulatory and Commercial

The Associate General Counsel will serve in a hybrid healthcare regulatory and commercial role, providing strategic legal counsel on healthcare laws and regulations, data privacy, Medicare and Medicaid compliance and related regulatory matters, while also supporting a broad range of commercial contracting activities. The role supports business lines spanning health plans and other payers, healthcare providers, specialty pharmacy and life sciences, including quality measurement and risk adjustment analytics.

The role will draft, review, and negotiate a broad range of commercial agreements, including customer and vendor contracts. Working closely with business leaders, the Associate General Counsel will advise on matters involving healthcare analytics, artificial intelligence ("AI"), software-as-a-service ("SaaS") and data strategy. The Associate General Counsel will also have significant interaction with internal clients and senior executives, as well as extensive cross-functional collaboration with all functions that touch the sales cycle.

• Provide legal and strategic advice and counsel on a variety of matters with a focus on healthcare regulatory compliance, commercial contracts and various other corporate transactions;

• Advise business teams on the legal and regulatory considerations associated with commercial transactions, including matters involving the Anti-Kickback Statute, False Claims Act, and related healthcare fraud and abuse laws;

• Draft and negotiate a broad range of complex commercial agreements, identify and resolve material legal and business issues, and develop practical contractual solutions;

• Advise on business proposals, commercial arrangements, and go-to-market strategies, structuring practical solutions that advance business objectives while managing healthcare regulatory and contractual risk;

• Advise on products and services supporting Medicare Advantage, ACA, and Medicaid risk adjustment programs, including RADV audits, chart review, supplemental data submissions, provider engagement, and related fraud, waste, and abuse risks;

• Serve as a subject-matter resource on HIPAA, HITECH and applicable state privacy and laws, negotiate and interpret business associate agreements, subcontractor BAAs, data use agreements and advise on permitted uses and disclosures of PHI;

• Review and recommend approaches to resolve the privacy aspects of vendor and customer contracts and other commercial transactions;

• Advise on de-identification and limited data sets under the HIPAA Expert Determination and Safe Harbor methods, re-identification risk, tokenization and data-linking arrangements, and downstream commercialization rights in de-identified and aggregated data;

• Advise health systems, medical groups, ambulatory facilities, and hospitals on clinical data access, EHR integration and interoperability, provider incentive and engagement programs, information blocking, and 21st Century Cures Act requirements;

• Support the specialty pharmacy business, including hub services, patient support and adherence programs, manufacturer, pharmacy and payer arrangements, copay and patient assistance considerations, and applicable state pharmacy and PBM regulation;

• Support AI governance: responsible AI, model and training-data rights, algorithmic transparency in clinical and quality use cases, and emerging AI regulation affecting healthcare analytics;

• Support the Legal Department's broader business objectives by handling non-commercial legal matters as needed. This could include, but not be limited to: pre-litigation matters, dispute resolution, customer correspondence, regulatory inquiries, subpoenas and other legal initiatives depending on capacity and workload;

• Contribute to legal…