The Director, Compliance is the leadership position directly responsible for the strategic development, implementation, operation, and continuous improvement of the corporate compliance and business ethics program for Cotiviti, a leading
and innovative analytics-driven payment accuracy company which provides services to the retail and healthcare industries. The company’s compliance and ethics program is based on the 7 elements contained within the U.S. Federal Sentencing Guidelines as well
as applicable federal and state health care compliance program standards.
This position is responsible for ensuring that the necessary policies and procedures, governance, training and education, risk identification and management processes and operational controls are implemented and operating effectively to ensure that the company’s
corporate compliance program is effectively preventing, detecting and responding to compliance and business ethics issues. The Director, Compliance, also provides expert guidance and analyses to the company’s executive leadership team on issues relating to
regulatory compliance and business ethics issues. This position will focus heavily on compliance with healthcare legal and regulatory issues applicable to the managed care industry, including those applicable to federal and state governmental programs (Medicare
and Medicaid managed care), and also to government contractors. This position will report to the Vice President, Compliance and Risk, and will have direct line of sight to the Audit Committee of the Board of Directors.
Develop, implement and continuously improve the corporate compliance and business ethics program, designed to promote a culture that fosters ethical and compliant behavior in accordance with applicable laws and regulatory requirements and which provides
a basis for ensuring adequate internal controls are in place to prevent, detect and respond to non-compliance and ethical issues. Develop, initiate, maintain, and revise policies and procedures for the general operation of the compliance program and its related
activities to prevent illegal, unethical, or improper conduct and to manage the day-to-day operations of the program. Develop and implement the necessary framework for collecting, analyzing, measuring, and reporting compliance metrics in order to measure and
continuously improve the effectiveness of the program.
Collaborate with compliance and risk colleagues and other departments (e.g., Finance, IT, Human Resources, Operations) to direct compliance and ethics issues to appropriate existing channels for investigation and resolution. Conducts and/or oversees appropriate
compliance investigations/inquiries. Operate an internal reporting process, including an anonymous telephone reporting system. Institute and maintain an effective compliance communication program for the organization, including promoting (a) use of the Compliance
Hotline;(b) heightened awareness of Standards of Conduct, and (c) understanding of new and existing compliance issues and related policies and procedures. Develops and implements methods and programs that encourage employees at all levels and others to report
concerns, suspected fraud, or other misconduct without fear of retaliation. Work with the Human Resources Department and others as appropriate to develop an effective compliance training program, including appropriate introductory training for new employees
as well as ongoing training for all employees, managers and third parties as appropriate. Ensures appropriate screening is conducted to ensure the organization does not hire or conduct business with individuals or entities that have been excluded or debarred
from participation in federal health care programs.
Compliance Activity Monitoring
Monitor, and as necessary, coordinate compliance activities of other departments to remain abreast of the status of all compliance activities and to identify trends. Identify potential areas of compliance vulnerability and risk, and develop/implement corrective
action plans for resolution of problematic issues. Provide general guidance on how to avoid or deal with similar situations in the future. Monitor the performance of the compliance program and related activities on a continuing basis, taking appropriate steps
to improve its effectiveness, including developing metrics for evaluating effectiveness of the program based on monitoring activities.
Chairs the internal quarterly Compliance Committee. Provide reports on a regular basis, and as directed or requested, to keep senior management and the Board of Directors informed of the operation and progress of the compliance program and any significant
compliance issues. These Compliance Committee and Board reports include the development and ongoing enhancement of metrics related to the operation of the compliance program as well as compliance program effectiveness measures for governance and oversight