The Sr. Director, Compliance & Training, directs the Office of Billing Quality Assurance (OBQA) and the office of Clinical Research Billing Compliance (CRBC), and is a member of the senior management team of the Clinical Practice Association (CPA). The Sr. Director is broadly responsible through strategic planning, implementation and direct and indirect management for all professional fee billing compliance activities within the CPA in accordance with the Billing Quality Assurance Plan for Professional Services. The Sr. Director is responsible for the organization and oversight of the CRBC, which is charged with prospectively reviewing hospital and professional fee patient care charges for research participants through a pre-billing review process on behalf of Johns Hopkins Medicine (JHM) ensuring accurate billing for both hospital and professional services for patients enrolled in clinical research studies.
The Sr. Director works closely with CPA leadership, School of Medicine (SOM) leadership, Office of Research Administration and its Clinical Research Support Services unit, JHU General Counsel, JHHS Legal and Corporate Compliance Offices, JHHS leadership and clinical department directors and administrators to ensure that the Billing Quality Assurance and Clinical Research Billing and Compliance programs are appropriately coordinated and effective.
RESPONSIBILITIES AND DUTIES
I. PLANNING A. Responsible for strategic planning and the development, expansion and viability of the OBQA and the CRBC to safeguard the reputation of and revenue earned by SOM clinical and research faculty, physicians, other providers and the Johns Hopkins Health System (JHHS), and maintain an exemplary compliance program within academic medical centers. B. Develops, plans and is accountable for the clinical research billing compliance operations for the CPA, the Clinical Trials Office (CTO) and JHHS, working collaboratively with JHHS Compliance, JHHS Central Business Office, Office of Research Administration, JHU General Counsel and JHHS Legal. C. Plans and creates all 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.
D. Plans and creates all programs and processes to ensure that items or services provided to patients enrolled in clinical studies are correctly billed by JHHS or JHU to insurers and other third-party payors for standard of care and/or clinical research-related items and services.
E. Ensures pre- and post-billing compliance auditing processes for clinical research charges billed by JHU.
F. Plans and/or approves all billing compliance training programs for clinical faculty, non-physician practitioners and billing office staff. Participates in the planning or delivery of training related to clinical research billing to faculty, study coordinators, and operational staff. G. Sets the priorities, agenda and with the physician chair, serves as co-chair of the CPA’s Compliance Committee.
H. Evaluates the programs to ensure effectiveness and continually refines or adds to the scope and priorities of OBQA or CRBC based on internal initiatives and external regulations.
I. Evaluates and promotes the use of innovative technologies and processes to enhance billing compliance, improve operations and facilitate efficient clinical practice.
J. Represents the CPA and/or JHM as a key member on special projects and strategic institutional initiatives.
II. ORGANIZING, IMPLEMENTING AND MANAGING
A. Responsible for coordinating, managing and overseeing the overall operation of the OBQA, CRBC and the compliance programs for the SOM which include Compliance Action Plans for each clinical department. B. Develops policies, procedures and an organizational structure for clinical research billing in coordination across all related institutional entities and departments.
C. Creates methods and processes for pre and/or post-billing compliance auditing of professional fee clinical research charges billed to insurance or to the study sponsor. Collaborates with the JHHS Corporate Compliance Office to create audit processes for hospital clinical research billing.
D. Keeps the JHHS Director of Third-Party Billing & Financial Reporting informed of the status of clinical research charges on hold or released for billing. Proactively addresses JHHS A/R concerns and adjusts operational processes, as necessary, with a key focus on hospital billing requirements that affect advanced payments from Medicare for inpatient services and timely filing of claims.
E. Participates in developing JHM policies regarding clinical research billing, patient registration and related operations.
F. 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. G. Approves and oversees the management of the quality assurance review program to continuously assess physician and non-physician practitioner medical record documentation as compared to the service(s) billed, with regular feedback of results to the clinical department administration and the individual providers.
H. Monitors, analyzes and reports the results of documentation reviews to leadership, including, but not limited to, the COO OJHP/Executive Director of the CPA, the Dean of the School of Medicine, the Compliance Committee and the Board of Governors.
I. 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. J. Serves as the primary liaison with clinical department research compliance representatives to ensure that clinical research billing activities are effective and successfully integrated into departmental operations. K. Working with the Director of OBQA and Director of Clinical Research Revenue Cycle & Billing Compliance, systematically researches and answers billing and documentation questions from faculty and staff. L. In conjunction with the Sr. 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.
M. Responsible for investigating and addressing compliance concerns reported to the Johns Hopkins compliance hotline, to JHU General Counsel, directly to OBQA or CRBC, or through other intake portals.
N. With the Director of OBQA reviews all clinical department compliance quarterly activity reports and annually reviews each department’s Billing Compliance Action Plan.
O. Corresponds with the Medicare carrier medical director to request approval for billing Investigational Device Exemption clinical trials.
P. Approves requests to bill professional fees and defines billing system controls for residents and clinical fellows who have been approved by the SOM’s Office of Graduate Medical Education to perform clinical activities outside of their training program.
Q. Initiates, coordinates and monitors clinical personnel leases between JHU and JHHS to ensure billing compliance.
R. Proactively communicates information on issues, problems and successes related to compliance to the CPA leadership, JHU General Counsel, the Dean of the School of Medicine, JHHS leadership and clinical department leadership.
S. The Sr. Director is responsible for the preparation and management of the annual operating budget for OBQA and CRBC. T. 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 U. Performs other duties as required related to professional fee billing, clinical practice operations, or hospital clinical research billing as requested.
A. Must foster and maintain effective relationships with clinical department chairs, administrators, compliance representatives, clinical researchers and staff, the CTO, Office of Research Administration, and JHHS leadership including Corporate Compliance, Legal, and Central Business Office to provide guidance and advice on billing and/or research billing compliance activities and issues. B. 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. C. Works closely and effectively with the JHU Office of the General Counsel and JHHS Legal Office on sensitive and complex compliance matters. D. Works closely and collaboratively with colleagues in the CPA and CTO.
E. 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. F. Coordinates compliance activities with the Johns Hopkins Health System’s Corporate Compliance Office and with the JHHS Legal Office. G. Brings leadership, credibility and sensitivity to the compliance activities of the SOM.
H. Actively participates in national professional organizations and associations to expand personal knowledge and share best practices with colleagues in other academic medical centers.
IV. QUALIFICATIONS A. Bachelor’s degree in relevant discipline required, Master’s degree highly preferred. B. Eight years directly related management and professional experience required, additional advanced education may substitute for some experience, to the extent permitted by the JHU equivalency statement.
C. Certification as a medical billing and coding professional highly preferred. D. Comprehensive knowledge of clinical billing regulations, clinical practice operations, and federal compliance guidelines for physicians, hospitals and third-party billing organizations required. E. 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. F. 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. G. Demonstrated expertise in billing compliance, health care administration or consulting, internal auditing, and planning and implementation of new programs required. H. Excellent written and verbal communication skills, and significant experience in delivering presentation to all organizational levels required. I. 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. J. Ability to handle confidential and sensitive information in a discreet and professional manner and demonstrate sound and prudent judgment in all business dealings required.
Classified Title: Sr. Director Compliance & Training Working Title: Sr. Director Compliance & Training Role/Level/Range: L/05/LH Starting Salary Range: $119,970 - $165,040 annually Employee group: Full Time Schedule: M-F, 8:30 am - 5:00 pm Exempt Status: Exempt Location: 04-MD:School of Medicine Campus Department name: 10002673-SOM Admin CPA Billing Quality Assurance Personnel area: School of Medicine
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