General Summary

Under the supervision of the Director of Compliance, the analyst will manage, develop, implement and monitor policies, procedures, processes, training, corrective action plans and overall operations to ensure compliance with federal and state laws and regulations affecting the Medical System and its Affiliates. Additionally, the Analyst will work collectively with Affiliate management and other personnel to ensure that compliance initiatives are implemented at all UMMS affiliates. For assigned components, individuals will be responsible for leading efforts implementing, monitoring and tracking Compliance Program elements and providing direction and guidance to affiliate personnel for adherence to industry regulations, system policies, Federal Sentencing Guidelines, CMS Conditions of Participation, Conditions of Payment and State specific requirements.

Principal Responsibilities and Tasks

The following statements are intended to describe the general nature and level of work being performed by the individuals assigned to this classification. These are not to be construed as an exhaustive list of all job duties performed by personnel.

Principal responsibilities of a Corporate Compliance Analyst include:

1. Serves as case investigator and performs follow-up with affiliate personnel on complaints and inquiries received through the Compliance Hotline, internal reporting, or other reporting and monitoring mechanisms.

2. Develops closing summary reports for case investigations and performs follow through to determine implementation of corrective action plans.

3. Serves as a consultant to UMMS operations personnel including Affiliate Compliance Officers for compliance questions and collaborate with affiliate management personnel in the development of corrective action plans.

4. Prepares reports to meet the needs of the Chief Compliance Officer, Director of Compliance, and UMMS executive management and the Audit and Compliance Committee of the Board of Directors.

5. Conducts audits/reviews and performs analysis to determine compliance with applicable federal and state laws, and policies and procedures.

6. Monitors data and trends to determine deficiencies and/or areas for further investigation and provides recommendations.

7. Develops and implements compliance policies as requested by the Compliance Director.

8. Carries out compliance research on specific topics such as Privacy regulations, Conflict of Interest Standards, Billing & Coding, policy development and healthcare regulations.

9. Compliance Subject-Matter Areas

Manages all aspects in one or more subject-matter areas of Compliance operations and works directly with Corporate Compliance Directors to implement specific components of the annual Compliance Plan. Specific Compliance subject matter areas include:

A. Compliance Administration
1. Hotline Triage intake, classification, investigation, remediation and incident resolution.
a. Leads intake for all reported incidents into Compliance Hotline, Call Center and Email Center. Triages, assigns incident category, notifies and involves appropriate affiliate or shared service team when applicable for case investigation and resolution.
b. Creates and maintains hard copy file documentation and logs into departmental tracking database.
c. Manages the follow-up process for resolving incidents according to organizational policy timeframes.
d. Develops Compliance Hotline statistical data for reporting to the Audit and Compliance Committee of the Board of Directors, the Executive Compliance Committee, the Affiliate Compliance Officer Committees and other meetings as requested.

2. Education, both general and supplemental, development, distribution and presentation. Healthcare compliance and regulatory research.
a. Analyzes, prioritizes and provides supporting research theory on researched data and summarizes in a presentable format for discussion with management.
b. Prepares departmental research reports inclusive of supporting documentation and executive summaries as applicable.
c. Identifies education and training needs across organization's shared services and affiliates.
d. Carries out compliance special projects such as compliance internal education and training requirements, development and of training modules and loading into learning management system and annual review and revision of organizations learning portal library.

3. Policy Administration and development of committee content and follow through on action items.
a. Oversees standardized system for ensuring compliance policy implementation at each affiliate.
b. Assists in the implementation and support of the policy and procedure management process.
c. Works collaboratively with the Compliance Director in compiling agenda and materials for Audit and Compliance Committee of the Board of Directors, the Executive Compliance Committee, the Affiliate Compliance Officer Committees and other meetings as requested. Attends and take minutes as requested. Performs follow-up on meeting topic discussion when necessary.

B. Screening and Exclusion
1. Screening and Exclusion of System Groups
a. Manages the Screening and Exclusion process for all employee/staff group levels, conducting data runs from government databases, determining report matches, conducting necessary research and preparing and submitting reports to HR, Office of General Counsel and Corporate Compliance for appropriate action and resolution.
b. Conducts training regarding the Screening and Exclusion process and protocols
c. Develops and maintains Screening and Exclusion policies, tools and vendor process.

C. HIPAA Privacy and Security
1. HIPAA Privacy and Security and serves as Liaison to Hospital Privacy Officers
a. Prepares required HIPAA breach reporting for reporting submission and enters into current government reporting system as required after review by Compliance Director.
b. Develops related HIPAA Privacy, IT and Security policies and collaborates with IS&T with implementation across the System.
c. Leads Corporate Compliance and Hospital Privacy Officer Committee Roundtable meetings.
d. Identifies and provides related HIPAA Privacy and Security education and training opportunities.
e. Collaborates with Hospital Privacy Officers and HIM staff to investigate, mitigate and resolve HIPAA Privacy related incidents.

D. Billing & Coding
1. Handles Medicare billing and coding issues directly related to Medicare rules and regulations and HSCRC requirements.
a. Conducts research, data analysis and investigation for billing and coding issues and inquiries.
b. Resolves and responds to billing, coding and risk related inquiries by working collaboratively with Internal Audit, Hospital Compliance Officers, Rates and Reimbursement and Revenue Cycle teams.
c. Drafts recommendations directly related to billing and coding investigation outcomes.
d. Develops closing summary for all investigated billing and coding issues and inquiries and creates executive summaries for management reporting.
e. Performs statistical and data analysis to identify outlier patterns that require investigation for Affiliates and their functional areas. Provides oversight for monitoring, review, investigation and resolution of any confirmed outlier event.
f. Analyzes external audit activity to capture consistent data on topics, prepare reports for Executive Compliance Committee, the Affiliate Compliance Officer Committees and other meetings as requested, and analyze if internal follow-up required at other Affiliates based on topics.

E. Compliance Program Metrics
1. Manages validation of Compliance Program Metrics, identifies gaps and develops and reports aggregated data by Affiliate. Develops management and committee reports based on aggregated System data.
a. Collects documentation from Hospital Compliance Officers quarterly and annually regarding their Compliance Program Metrics and assists in determining documentation is appropriate, reviews for statistical accuracy, meets standards, requests more information if required, and ensures it is complete.
b. Works collaboratively with Hospital Compliance Officers in understanding and continually monitoring the metrics, identifying educational gaps and develops process and training tools to close those gaps.
c. Completes required metrics summary chart and highlights overview for management presentation
d. Prepares corporate compliance summaries of project research into electronic formats for meetings and presentations
e. Validates data as requested and makes recommendations to improve the accuracy of the data. Presents ideas for modifications and additions to the metrics to make the Compliance Program more robust or measure compliance outcomes.

F. Compliance Risk Assessment
1. Manages the Annual Compliance Risk Assessment process.
a. Carries out compliance research on examples of industry risk analysis as requested.
b. Conducts elements of risk analysis and identified priorities.
c. Investigates, resolves and responds to risk related inquiries.
d. Develops risk identified Action Plans as requested by the Compliance Director.
e. Provides oversight to the Hospital Compliance Officers and related functional departments for the Action Plans resulting from the Annual Compliance Risk Assessment.

G. Physician and Referral Source Relationships
1. Handles physician and referral source issues directly related to Stark law and Anti-Kickback Statute.
a. Conducts research data analysis and investigation for referral source issues.
b. Resolves and responds to physician and referral source inquiries by working collaboratively with the Office of General Counsel, Affiliate Contract Administrators, Affiliate Compliance Officers, and Internal Audit.
c. Drafts management recommendations directly related to physician and referral source investigation outcomes.
d. Develops closing summary for all investigated physician and referral source issues.
e. Oversees the new employee and annual Disclosure of Financial Relationships (aka conflict of interest) questionnaire process. Ensure completed questionnaire timeframes are met. Develop management reports regarding questionnaire results.

2. Monitoring activities and affiliate physician and referral source relationship controls. Develop and deliver tools/training for referral source relationships.
a. Updates and recommends referral source contract initiation and administration controls.
b. Develops fair market value templates to assist with contract initiation process.
c. Develops tool to monitor referral source control effectiveness
d. Conducts monitoring activities related to referral source database.

3. Manages validation of physician and referral source Compliance Program Metrics, identifies gaps and reports aggregated data by Affiliate. Develops management and committee reports based on aggregated System data.