The Vice President and Chief Compliance Officer serves as the senior organizational leader for all aspects of compliance related to VUMC's operations, which exceeds $3B in annual revenue. This executive will be responsible for oversight of the strategic development, implementation, daily operation, and overall integrity and quality of the VUMC Office of Compliance & Corporate Integrity and VUMC's Compliance Program.
Oversee the strategic review, planning, implementation, and operation of an effective reimbursement and research compliance program with direct access and accountability to the senior management team for VUMC. Perform regular reviews of the compliance program and recommend appropriate revisions and modifications. Advise senior leadership of potential compliance risk and opportunity areas. Provide regular periodic reporting to VUMC's Board of Directors Audit and Compliance Committee and VUMC's CEO and senior management about the operations of the Compliance Program (including without limitation pending matters under review by the Compliance Program).
Identify and assess areas of compliance risk and opportunities for VUMC; ensure that the Compliance Program effectively prevents, detects and/or addresses violations of law, regulations and VUMC policies. Collaborates with the Office of Internal Audit and others to ensure that internal controls are in place to prevent, detect and address significant instances or patterns of illegal, unethical, or improper conduct by employees, agents, affiliated providers, or others working with VUMC. Assures the prompt and proper resolution and implementation of audit or review recommendations.
Collaborate with other VUMC departments and stakeholders to identify, develop, refine, and oversee system-wide training and communication programs to ensure that all employees and affiliated parties are educated on the Compliance Program, and other specific compliance areas deemed necessary.
Coordinate with VUMC senior leaders and VUMC's Office of Legal Affairs toensure compliance with the laws and regulations that pertain to participation in Federal health care programs and other Federally funded grants and programs, including but not limited to the Federal anti-kickback law, Stark law, civil monetary penalties law and False Claims Act.
Provide input and/or direction to VUMC policies and procedures and the performance management system and incentive programs to ensure support of conformity with the Compliance Program as a part of performance management processes for all employees and that improper conduct is discouraged. .
Promote an organizational culture that supports and encourages the identification and reporting of potential compliance concerns and violations of laws, regulations and VUMC policy. Oversee and operate retaliation-free reporting channels, including the Integrity Line, an anonymous telephone reporting system available to all employees, volunteers, affiliated providers and others.
Oversee, follow up, and as applicable, resolve investigations and other issues generated by the Compliance Program, including development of corrective action plans, as needed. Collaborate with legal counsel as appropriate to authorize, conduct and/or oversee investigation of matters that merit investigation under the Compliance Program.
Develop and oversee the strategic auditing and monitoring plan for evaluating the performance of VUMC's processes for clinical documentation, coding and billing and related activities to identify risks and initiate appropriate steps to improve effectiveness and mitigate risks.
Collaborate with VUMC leaders in Information Technology/Biomedical Informatics, Clinical Care Programs, Department of Finance, and Business Enterprise to optimize use of information technology in defining and advancing state-of-the-art compliance efforts.
Principally responsible for supporting operations and meetings of VUMC's Compliance and Corporate Integrity Committee and subcommittees, including but not limited to developing and managing the monthly meeting agenda, the open issues tracking dashboard, and preparation and distribution of meeting materials.
Key interpersonal skills for this position are:
Consummate team player able to work effectively up, down and across the organization, especially in relating to the operating units.
Service orientation towards faculty, staff, patients and visitors.
The Chief Compliance Officer and his/her team work across diverse, decentralized departments. Hence, the Chief Compliance Officer should have the predisposition to engage and persuade people with a sense of communication and openness; the individual should not be political or hierarchical in nature.
Ability to distill complex data to essential elements and communicate effectively to a wide range of audiences both internally and externally.
A bias for action even in the face of ambiguity and complexity.
Ability to maintain harmonious working relationships and effectively address complex and sensitive administrative issues throughout the spectrum of constituents.
Ability to be a collaborative expert and authority on compliance issues.
Understanding the Business
Knows the business of an academic medical center with a significant research enterprise; has the mission-critical technical and functional skills needed to do the job; understands various types of business propositions and understands how academic medical centers and other health care providers operate in general; learns new methods and technologies easily; contributes to the analysis and resolution of complex situations in ways that are seen as helpful and clarifying.
Creating the New and Different
Is able to identify and lead implementation of the next great breakthrough thing to do; is creative, a visionary, and can manage innovation; is an effective strategist full of ideas and possibilities; sees multiple futures; has broad interests and knowledge; can both create and bring exciting ideas to life within the team and institution; comfortable speculating about alternative futures without all of the data.
Is well organized, resourceful, and planful; effective and efficient at marshaling multiple resources to get things done; lays out tasks in sufficient detail to mark the trail; uses continuous performance improvement techniques to complete work with less and in less time; can work on multiple tasks at once without losing track; foresees and plans around obstacles.
Getting Work Done Through Others
Manages people well; engenders respect and trust among \colleagues and team members through both personal accountability and effective collaboration; gets the most and best out of the people he/she has; sets and communicates guiding goals; measures accomplishments, holds people accountable, and gives useful feedback; delegates and develops; keeps people informed; provides coaching for today and for the future.
Dealing with Trouble
Fearlessly takes on all issues, challenges, and people; comfortably confronts and works through conflict; delivers negative feedback and messages constructively and without hesitation; deals promptly and fairly with problem performers; lets everyone know where they stand; thrives in crises and is energized by tough challenges; not afraid to make negative decisions and take tough action; challenges the status quo.
Brings a measured approach to addressing identified issues. Thoughtfully considers the risks and benefits of all alternatives in assessing compliance-related concerns and developing pathways to resolve them.
Being Organizationally Savvy
Maneuvers well to get things done; capable of working successfully in a highly matrixed organization; knows where to go to get what he/she needs to meet institutional commitments; politically aware and able to navigate through or around institutional political obstacles; knows what the right thing to do is; presents views and arguments well.
Acting with Honor and Character
Is a person of high character; is consistent and acts in line with a clear and visible set of values and beliefs; deals and talks straight; walks his/her talk; is direct and truthful but at the same time can keep confidences.
The ideal Chief Compliance Officer will be an individual of uncompromising integrity who has a distinguished record of accomplishment and leadership in compliance. Academic Medical Center and healthcare finance experience will be highly valued, but other backgrounds will also be considered. The successful candidate will demonstrate a combination of intellect, technical skills, vision, and collegiality consistent with the culture and momentum of the VUMC community.
Bachelor's Degree is required. A Master's Degree, CPA, Internal Audit Certification or Juris Doctor and Certification in Healthcare Compliance (CHC) or Certification in Research Compliance (CRC) are strongly preferred; however, outstanding candidates with substantial compliance-related experience who are willing to attain such certification reasonably promptly following hire will be considered.
Seven (7) or more years of executive level corporate compliance program experience as a Corporate Compliance or Ethics Officer or equivalent.
Proven track record in the areas of compliance auditing and monitoring, investigation, risk assessment, enforcement and formulation of comprehensive audit policies, programs, and plans.
Sound knowledge of organizational and accounting controls and technology. Demonstrated understanding of public, federal, state, local and third party regulatory and governance processes.
Outstanding interpersonal and leadership skills, and the ability to function in a team environment required. Demonstrated knowledge is necessary of how to accomplish superior performance in a complex environment.
Will have served in a complex and matrixed environment such as an academic medical center or a large integrated health system with a reputation for world class management.
Able to build positive and effective relationships inside and outside of the medical center.
Demonstrated track record of working successfully with academic clinical leaders, diverse management teams, community organizations, local and state government officials as well as other major constituencies.
Will have a particularly strong capability to work from a position of influence engaging people and to set and execute performance goals.
Has a natural intellectual curiosity and innovation interests which will add to the creativity and progress of this academic medical center.
Executive level writing and presentation ability.
Demonstrated prior success that is measurable and consistent, in addition to demonstrated advancement of the candidate's career.
A leadership philosophy that takes into consideration the sensitivity and complexity of the academic medical center community.
Demonstrated capacity to develop the talents and expertise of staff so that they are able to assume expanded responsibilities; proven ability to recruit and retain well-qualified, high-performing professionals.
Experience with re-engineering, restructuring, and upgrading an organization, ideally including the implementation of a significant and sustained change in performance levels and culture.
Vanderbilt University Medical Center is home to Vanderbilt University Hospital, The Monroe Carell Jr. Children’s Hospital at Vanderbilt, the Vanderbilt Psychiatric Hospital and the Vanderbilt Stallworth Rehabilitation Hospital. These hospitals experienced more than 61,000 inpatient admissions during fiscal year 2015. Vanderbilt’s adult and pediatric clinics treated nearly 2 million patients during this same period. Vanderbilt University Hospital and the Monroe Carell Jr. Children’s Hospital at Vanderbilt are recognized again this year by U.S. News & World Report’s Best Hospitals as among the nation’s best with 18 nationally ranked specialties. Vanderbilt University Medical Center is world renowned because of the innovation, work ethic and collegiality of its employees. From our health care advances to our compassionate care, Vanderbilt owes its accomplishments and reputation to staff and faculty who bring skill and drive and innovation to the medical center day after day. World-leading academic departments and comprehensive centers of excellence pursue scientific discoveries and transformational educational and clinical advances across the entire spectrum of health and disease.As t...he largest employer in middle Tennessee, we welcome those who are interested in ongoing development in a caring, culturally sensitive and professional atmosphere. Most of us spend so much of our lives at work, we want to be part of maintaining a workplace in which people support one another and encourage reaching for excellence. Many high-achieving employees stay at Vanderbilt because of the professional growth they experience and because of their appreciation of Vanderbilt’s benefits, public events and discussions, athletic opportunities, beautiful setting and, above all, sense of community and purpose.Vanderbilt and its employees share a set of mutual expectations that have been created with productivity, legality, fairness and safety always in mind. We believe that our investment in training and compensating employees multiplies in value when we enable individuals to deliver their best performance for the benefit of us all.