Corporate Compliance Officer

Overview

Reporting to the CFO and Board Chair, the Corporate Compliance Officer (CCO) provides strategic leadership and independent oversight of the enterprise-wide corporate compliance program for an integrated nonprofit healthcare system with approximately $1.2 billion in annual operating revenue. The CCO promotes a culture of integrity, ethical conduct, accountability, and compliance across hospitals, physician practices, outpatient facilities, subsidiaries, and affiliated operations.

The CCO designs, implements, evaluates, and continuously improves an effective compliance program aligned with applicable federal and North Carolina requirements, U.S. Department of Health and Human Services Office of Inspector General (OIG) guidance, and recognized healthcare compliance practices. The position advises executive leadership and the Board, identifies and mitigates compliance risks, directs investigations, and ensures timely corrective action.

Responsibilities

Essential Duties and Responsibilities

· Lead and maintain an enterprise-wide compliance program based on the OIG’s seven elements of an effective compliance program, including policies, oversight, training, communication, monitoring, enforcement, and response.

· Develop and execute a risk-based annual compliance work plan; periodically assess program effectiveness and report measurable outcomes.

· Oversee the Code of Conduct, compliance policies, reporting channels, and nonretaliation expectations; foster a speak-up culture.

· Provide independent, timely compliance advice to the CEO, CFO, executive leadership, and the Board’s Finance Committee.

· Coordinate compliance governance and accountability across hospitals, medical groups, ambulatory operations, and affiliated entities.

Regulatory Compliance and Risk Assessment

· Oversee an annual compliance risk assessment and develop a compliance workplan.

· Collaborate with revenue cycle team and operations on CMS requirements, billing and coding, medical necessity, documentation, reimbursement, and overpayments.

· Address fraud, waste, and abuse risks, including the False Claims Act, Anti-Kickback Statute, Stark Law, physician arrangements, conflicts of interest, and exclusion screening.

· Coordinate with responsible leaders on EMTALA, Conditions of Participation, 340B, tax-exempt obligations, and relevant federal and North Carolina requirements.

· Monitor regulatory developments and translate changes into practical policies, controls, education, and operational action plans.

Investigations, Monitoring, and Corrective Action

· Oversee confidential intake, triage, investigation, documentation, and resolution of compliance allegations, hotline reports, and potential violations.

· Ensure prompt escalation of significant issues and coordination with counsel regarding privilege, disclosure, repayment, and government inquiries as appropriate.

· Direct compliance auditing and monitoring activities; use data analytics to identify emerging risks and recurring patterns.

· Ensure corrective action plans identify accountable owners, deadlines, root causes, validation testing, and follow-up reporting.

· Oversee consistent, fair enforcement of compliance standards in partnership with Human Resources and leadership.

· Collaborate with Legal, Revenue Cycle, Finance, Human Resources, Privacy, Information Security, Quality, and clinical leaders on compliance issues, audits, and compliance education needs.

Education, Reporting, and Governance

· Develop role-specific compliance education, including onboarding and periodic training for employees, medical staff, leaders, and governing bodies.

· Prepare regular dashboards and executive/Board reports on risk assessments, work-plan progress, investigations, training, trends, and remediation.

· Maintain direct and unrestricted access to the Board or designated committee, including the ability to meet in executive session.

· Manage compliance program resources, budget, staffing, vendor relationships, and external assessments; develop and mentor the compliance team.

· Support due diligence and integration for new affiliations, partnerships, transactions, and major operational changes.

· Lead and oversee activities of the Corporate Compliance Committee.

· Present compliance risk assessment and audit activities to the Board or designated committee on a routine basis.

Key Performance Expectations

· Completion and timely reporting of the annual risk assessment and compliance work plan.

· Timely, documented investigation and closure of allegations and corrective actions.

· Evidence of effective training, policy governance, reporting access, and nonretaliation.

· Reduction in repeat findings and sustained effectiveness of corrective actions.

· Transparent, actionable reporting to executive leadership and the Board.

Independence and Authority

The CCO should have sufficient stature, resources, and authority to administer the program independently; direct access to the CEO and Board; and the ability to escalate material concerns without interference. The CCO should not be assigned operational responsibilities that create conflicts with independent compliance oversight.

Working Relationships

Partners closely with the CEO, CFO, COO, General Counsel, Chief Medical Officer, Chief Nursing Officer, Revenue Cycle leadership, Human Resources, Privacy/Security, Quality, operational executives, and the Board.

Qualifications

Minimum Qualifications

· Bachelor’s degree in healthcare administration, business, law, accounting, nursing, or related field.

· At least 10 years of progressively responsible healthcare compliance, regulatory, legal, audit, or risk experience, including significant leadership responsibility.

· Demonstrated knowledge of federal healthcare program requirements, fraud and abuse laws, reimbursement compliance, and health system operations.

· Experience conducting complex investigations, enterprise risk assessments, and executive/Board reporting.

· Excellent judgment, integrity, communication, analytical, and relationship-building skills.

Preferred Qualifications

· Master’s degree, JD, MBA, MHA, or comparable advanced degree.

· Certified in Healthcare Compliance (CHC) or comparable relevant credential.

· Experience in a large, multi-hospital, integrated nonprofit health system.

· Experience with compliance analytics, physician enterprise compliance, and independent compliance program effectiveness assessments.