Sr. Director Compliance & Training
We are seeking a Sr. Director Compliance & Training, who will direct the Office of Compliance Professional Fee Services and is responsible for all billing compliance and training programs for Johns Hopkins Medicine’s clinical care providers. The Senior Director is a member of the senior management team of the School of Medicine’s Clinical Practice Association (CPA) and the Office of Johns Hopkins Physicians. Responsible for strategic planning, implementation and direct and indirect management of all professional fee billing compliance activities. Works closely with CPA leadership, OJHP Leadership, School of Medicine (SOM) leadership, the Johns Hopkins University (JHU) General Counsel, Johns Hopkins Health System (JHHS), Legal Department and Corporate Compliance Department, JHHS physician entity leadership, Revenue Cycle leadership, and SOM clinical department directors and administrators. Will ensure the Billing Quality Assurance compliance and training programs are appropriately coordinated and effective. Reports directly to the JHU Senior Assoc General Counsel & Chief Compliance Officer with a dotted-line report to the Chief Operating Officer, Office of Johns Hopkins Physicians/Executive Director CPA, and is the University’s senior subject matter expert on professional fee billing. Physician entities included in the scope of responsibility include but are not limited to,
- JHUSOM: Clinical Practice Association (faculty practice plan)
- JHHS: Johns Hopkins Community Physicians, Johns Hopkins Regional Physicians, Johns Hopkins All Children’s Specialty Physicians, Johns Hopkins Personalized Care
- Johns Hopkins Executive Health
Specific Duties & Responsibilities
- Responsible for strategic planning and the development, expansion and viability of the Office of Compliance: Professional Fee Services and compliance and training programs to safeguard the reputation and billing integrity by SOM and JHHS clinical faculty, physicians, and other JHM providers. Oversees and manages an exemplary compliance program as a leading academic medical center.
- Develops, plans and is accountable for the professional fee billing compliance operations of JHM, working collaboratively with the JHU Chief Compliance Officer, JHU General Counsel, SOM Office of Research Administration, JHHS Compliance, JHHS Central Business Office, and JHHS Legal.
- Plans and creates all JHM programs and processes to assess the level of knowledge and accuracy of professional fee billing medical record documentation and coding to adequately represent services billed to third-party insurers.
- Plans and creates all JHM programs and processes to ensure that items or services provided to patients are correctly billed by to insurers and other third-party payors. Supports clinical and operational teams to build and implement new and non-traditional professional billing codes and associated clinical services (such as remote monitoring, asynchronous care, chronic condition management, and interprofessional consultation).
- Plans and/or approves all billing compliance training programs for SOM clinical faculty, JHHS clinicians, JHM non-physician practitioners and billing office staff.
- Sets the priorities and agenda and with the physician chair, serves as co-chair of the CPA’s Compliance Committee.
- Evaluates clinical programs to ensure effectiveness and continually refines or adds to the scope and priorities based on internal initiatives and external regulations.
- Evaluates and promotes the use of innovative technologies and processes to enhance billing compliance, improve operations and facilitate efficient clinical practice.
- Represents the CPA/OJHP and/or JHM as a key member on special projects and strategic institutional initiatives.
- Provides timely audit reports of all JHHS clinicians to the JHHS Compliance Department.
- Responsible for the overall operation of the Office of Compliance: Professional Fee Services and compliance and training programs for SOM, which includes Compliance Action Plans for each clinical department.
- Develops policies, procedures and an organizational structure for billing in coordination with all related institutional entities and departments.
- Creates methods and processes for pre and/or post-billing compliance auditing of professional fee charges billed to insurance. Collaborates with the JHHS Corporate Compliance Office to create audit processes for professional billing.
- Proactively addresses JHHS compliance concerns and adjusts operational processes, as necessary, with a key focus on professional documentation that impacts hospital billing.
- Participates in developing JHM policies regarding clinical billing, patient registration and related operations.
- Develops and recommends for approval by the CPA Board of Governors (through the CPA Compliance Committee) policies and procedures as they relate to professional fee billing compliance or other related regulatory matters.
- Oversees the management of the quality assurance review program to continuously assess physician and non-physician practitioner documentation as compared to the service(s) billed, and provides results to clinical department administration and individual providers.
- Monitors, analyzes and reports the results of documentation reviews to the appropriate JHUSOM and JHHS leadership.
- Develops, reviews and/or approves mandatory and supplemental billing compliance training for all new clinical faculty, clinical fellows, residents, non-physician practitioners and professional fee billing staff.
- Working in conjunction with others, systematically researches and answers billing and documentation questions from clinical faculty and staff.
- In conjunction with the Senior Director of Revenue Operations, maintains a system of controls and reporting mechanisms to ensure that professional fee billing Production Units are functioning in compliance with third-party billing requirements. This includes a process to ensure that complaints from Medicare beneficiaries or the Medicare Program Integrity Unit are promptly researched and resolved.
- Responsible for investigating and addressing compliance concerns reported to the Johns Hopkins compliance hotline, to JHU General Counsel, directly to Office of Compliance: Professional Fee Services or through other intake portals.
- With others, reviews all clinical department compliance quarterly activity reports and annually reviews each department’s Billing Compliance Action Plan.
- Approves requests to bill professional fees and defines billing system controls for residents and clinical fellows approved by the SOM’s Office of Graduate Medical Education to perform clinical activities outside of their training program.
- Monitors clinical personnel leases between JHU and JHHS to ensure billing compliance.
- Proactively communicates information on compliance to the CPA leadership, JHU General Counsel, the Dean of the School of Medicine, JHHS physician group leadership, JHHS compliance, and clinical department leadership.
- Prepares and manages the annual operating budget for Office of Compliance: Professional Fee Services and compliance and training programs.
- Responsible for coordinating and/or serving as liaison to external auditing activities by the federal government, the university’s external auditor, or third-party insurers as related to billing compliance.
- Performs other duties as required related to professional fee billing, clinical practice operations, or hospital clinical billing as requested.
- Must foster and maintain effective relationships with clinical department chairs, administrators, compliance representatives, Office of Research Administration, and JHM and JHU leadership, JHHS Compliance Department and JHHS physician leadership to provide guidance and advice on billing compliance activities and issues.
- Cultivates appropriate relationships with government agencies and agents, in particular with the local Medicare carrier and fiscal intermediary medical directors and their respective Program Integrity Units.
- Works closely and effectively with the JHU Office of the General Counsel, JHHS Legal Office, and the JHHS Compliance Department on sensitive and complex compliance matters.
- Works closely and collaboratively with colleagues in the CPA/OJHP. Works closely with the President, VPMA/CMO and physician leaders in each of the JHHS physician groups.
- Interacts with department directors, administrators, hospital executives, SOM Dean/CEO and Vice Deans, and university representatives and participates in Johns Hopkins Medicine initiatives and committees.
- Coordinates compliance activities with the Johns Hopkins Health System’s Corporate Compliance Department and with the JHHS Legal Office.
- Brings leadership, credibility and sensitivity to the compliance activities of JHM.
- Actively participates in national professional organizations and associations to expand personal knowledge and share best practices with colleagues in other academic medical centers.
Minimum Qualifications
- Bachelor’s Degree in relevant discipline.
- Eight years directly related management and professional experience required, additional advanced education may substitute for some experience.
- Comprehensive knowledge of clinical billing regulations, clinical practice operations, and federal compliance guidelines for physicians, hospitals and third-party billing organizations required.
- A professional level of management and/or auditing expertise through direct work-related experience. Extensive experience with medical records, coding systems, and adult learner training techniques required.
- Demonstrated leadership and emotional intelligence to navigate within a complex organization, communicate sensitive information to all levels of leadership, and promote and implement any required remediation to mitigate organizational risk and ensure compliance required.
- Demonstrated expertise in billing compliance, health care administration or consulting, internal auditing, and planning and implementation of new programs required.
- Excellent written and verbal communication skills, and significant experience in delivering presentation to all organizational levels required.
- Strong interpersonal skills and ability to relate effectively with people at all organizational levels. Demonstrated ability to facilitate collaborative relationships and effectively motivate others to adhere to all necessary requirements to mitigate compliance risk for individuals and the institution required.
- Ability to handle confidential and sensitive information in a discreet and professional manner and demonstrate sound and prudent judgment in all business dealings required.
Preferred Qualifications
- Master’s Degree.
- Certification as a medical billing and coding professional.
Classified Title: Sr. Director Compliance & Training
Job Posting Title (Working Title): Sr. Director Compliance & Training
Role/Level/Range: L/05/LH
Starting Salary Range: $127,300 - $223,000 Annually (Commensurate with experience)
Employee group: Full Time
Schedule: Monday - Friday, 8:30 am - 5:00 pm
Exempt Status: Exempt
Location: Hybrid/Mount Washington Campus
Department name: Office of Compliance: Prof Fee Services
Personnel area: School of Medicine