Compliance Director
Eye Health America
The role serves as the primary architect and guardian of the organization’s ethical and regulatory framework. Reporting directly to the Compliance Officer and Chief Growth Officer, this high-impact leadership role is responsible for the strategic oversight of all compliance functions across a rapidly expanding, large, eye care platform.
In this critical juncture of the organization’s growth, the Director will lead the immediate remediation of identified regulatory concerns, oversee complex internal investigations, and manage the end-to-end whistleblower response program. Beyond crisis management, the Director will serve as a strategic partner to the executive team, ensuring that all mergers, acquisitions, and clinical operations—including physician compensation and co-management models—adhere to the highest standards of the Anti-Kickback Statute, Stark Law, and False Claims Act.
The ideal candidate is a proactive, "hands-on" leader who can transform compliance from a reactive function into a competitive advantage. You will be tasked with building a transparent "Speak Up" culture that protects our patients, our providers, and our investors’ interests, ensuring the organization remains "audit-ready" and ethically sound during aggressive market expansion.
Essential Functions and Responsibilities
I. Crisis Management & Whistleblower Remediation
- Whistleblower Program Oversight: Assume immediate leadership of the organization’s ethics hotline and reporting mechanisms; ensure all reports are triaged, investigated, and documented with the highest level of confidentiality and professional rigor.
- Internal Investigations: Lead and conduct complex internal investigations into allegations of fraud, waste, abuse, or misconduct; coordinate with external legal counsel where necessary to maintain attorney-client privilege.
- Corrective Action & Remediation: Design and execute formal Corrective Action Plans (CAPs) to address systemic failures identified by whistleblower reports or audits, ensuring long-term prevention of recurrence.
- Anti-Retaliation Leadership: Establish and champion a robust non-retaliation policy and a "Speak Up" culture to rebuild employee trust and psychological safety following compliance incidents.
II. Strategic Regulatory Oversight
- Specialized Legal Compliance: Ensure the organization’s physician compensation, co-management agreements, and marketing practices strictly adhere to the Anti-Kickback Statute (AKS), Stark Law, and the False Claims Act (FCA).
- Clinical Compliance & Eye Care Standards: Collaborate with the CMO to ensure medical necessity and documentation standards for high-volume procedures (e.g., cataract surgery, premium IOLs, intravitreal injections) meet Medicare and commercial payer requirements.
- Revenue Cycle Compliance: Partner with the RCM department to conduct regular "probe audits" on billing and coding practices to identify and mitigate risks of overpayment or fraudulent billing.
- HIPAA & Privacy Officer Duties: Serve as the Privacy Officer, overseeing the protection of PHI and managing the response to any potential data breaches or HIPAA violations.
III. M&A Growth Strategy
- M&A Due Diligence: Perform comprehensive compliance due diligence on potential acquisitions, identifying historical liabilities and "red flag" referral patterns before closing.
- Post-Acquisition Integration: Lead the rapid "compliance onboarding" of newly acquired clinics, standardizing their policies, training, and reporting structures under the corporate umbrella.
- Board & Sponsor Reporting: Develop and present executive-level risk dashboards and compliance KPIs for the Board of Directors highlighting EBITDA-impacting risks.
IV. Program Development & Auditing
- Seven Elements Implementation: Ensure the compliance program meets the Office of Inspector General’s (OIG) "Seven Elements of an Effective Compliance Program.
- Risk-Based Auditing: Design and implement an annual internal audit plan focused on high-risk areas identified through data analytics and previous whistleblower concerns.
- Policies & Procedures: Update and maintain the company’s Compliance Manual that translates complex federal and state regulations into clear, actionable operational workflows.
- Education & Training: Design and deliver specialized compliance training tailored to different roles (e.g., surgeons vs. front-desk staff), ensuring 100% completion rates and verified understanding of ethical obligations.
V. Monitoring & Operational Leadership
- Continuous Monitoring: Establish a testing program to monitor the effectiveness of internal controls and the "health" of the organization’s compliance culture.
- Cross-Functional Collaboration: Serve as a key member of the senior leadership team, providing compliance-focused guidance to Operations, HR, Finance, and Marketing to ensure a cohesive, unified approach to growth.
Minimum Qualifications:
- Experience: 8+ years of healthcare compliance experience, with at least 3 years in a leadership role (Director level or above).
- Preferred Education: Bachelor’s or Master’s degree in healthcare administration, Business or Law.
- Recommended Certification: CHC (Certified in Healthcare Compliance).
- Specific Background: Proven track record of managing internal investigations or responding to government inquiries (OIG/DOJ).
Skills and Abilities
- Strong analytical and problem-solving skills.
- Excellent communication and interpersonal skills.
- Ability to collaborate effectively with cross-functional teams.
- Detail-oriented with a commitment to accuracy and thoroughness.
- Integrity and a commitment to ethical business practices.