Job Title
VP Corp Ethics/Bus Practice
Grade
22
Security Level
Reports To
Audit Committee of Board of Directors
Dimensions
Internal Contacts-all organizations employees, including affiliated
organizations.
External Contacts-Boards of Directors, members/beneficiaries, external
auditors, regulatory agencies, BCBSA, vendors, and others as
necessary to conduct business.

Primary Objective of Position

This position coordinates and communicates compliance

activities, including the implementation and monitoring of compliance

activities that detect and prevent unethical or illegal behavior. It

also directs the Internal Audit and Security and Privacy Departments

activities and acts as a member of the Executive staff. The Audit and

Compliance Committees of the Board of Directors supervise this

position.

Essential Functions

1. Overseeing and monitoring Divisional activities including, the

administrative responsibilities, supervisory responsibilities for

six employees and work product process and review;

2. Reporting on a regular basis to management and the Boards of

Directors, regarding the progress of Compliance Program and

Divisional activities;

3. Periodically reviewing and revising the Divisional activities to

meet the needs of the organization and support the

organization, its employees and Directors;

4. Responsible for compliance with pertinent laws, rules and

regulations governing the network of companies;

5. Periodically reviewing and revising the companys policies and

procedures to achieve compliance with applicable rules,

regulations, policies and procedures;

6. Ensuring that employees, Directors and vendors (as appropriate)

have received, read and understand pertinent portions of the Code

of Conduct and other pertinent policies, procedures, rules,

regulations and laws;

7. Developing and coordinating educational opportunities and training

programs that focus on the elements of the Compliance Program, and

other policies, procedures, rules, regulations and laws governing

the company;

8. Developing, implementing and training on policies and procedures,

that encourage employees to report suspected fraud and other

improprieties without fear or retaliation;

9. Coordinating internal audits and other monitoring activities that

identify risk areas/activities and the adherence of the company to

applicable processes, procedures and rules, regulations and laws;

10. Establishing, maintaining and publicizing the existence of an

anonymous reporting mechanism for employees to report suspected

violations of policy or procedures or other rules,

regulations and laws;

11. Investigating complaints or reports of incidents which may violate

company policies and procedures, the Code of Conduct or other

rules, regulations and laws which govern the conduct of company

employees and others who do business with the company;

12. Receiving complaints or reports of incidents that may violate

company policies and procedures, but should be investigated by

specialized Division, and referring the complaint to that

Division to conduct the investigation;

13. Coordinating/leading discussion, and following-up as appropriate,

with the Executive Compliance Committee and Internal Controls

meeting;

14. Coordinating the distribution and collection of the information

necessary to meet certain certification and reporting requirements,

including information on employee and Director conflicts of

interest, Privacy Act, HIPAA reporting, Security reporting, Violent

Crime Act of 1994 reporting;

15. Responsibility for the supervision of the development and

implementation of the organization-wide Security and Privacy

policies and procedures;

16. Participate as a member of Executive Staff in a way, which furthers

the vision, mission and value of the company.

17. Administrative supervision of the companies

Compliance Director and the Internal Audit Director.

Knowledge

Working knowledge of the company and its affiliates, the Medicare and

Medicaid programs, the insurance industry, as well as applicable

guidelines, laws and regulations.

Abilities/Skills

Management skills

Good communication skills, both written and oral

Leadership skills

Negotiation skills

Analysis and interpretation skills

Education/Experience

Law Degree

Segregation of Duties

Every employee is responsible to perform their duties and

responsibilities in accordance with company policies and procedures,

including but not limited to, Segregation of Duties Principles, HIPAA

Security and Privacy, CMS requirements, the Compliance Program,

and any other applicable laws, rules and regulations.

1. Cognitive or Mental Requirements
Does the job require any of the following on a daily basis? (Check as applicable)

Yes / Reading
Yes / Writing
Simple Arithmetic
Mathematics
Weighing and/or Measuring
Yes / Analyzing Data or Report Information
Yes / Creating Methodologies for Accomplishing a Goal
Yes / Conducting Research
Yes / Directing Activities of Others to Accomplish a Goal
Yes / Drawing Conclusions From Written or Computer Generated Materials
Yes / Implementing Recommendations by Coordinating Persons and/or Other Resources
Yes / Developing Plans, Procedures, Goals Strategies or Processors Based on Data Analysis of Experience

2. Physical Requirements
A. Do the major activities of the job include any of the following: (Check and quantify as applicable)

Yes / Use of Keyboard and/or Computer / Hours/Day / 3 hours
Other Electronic Equipment / Hours/Day
(Specify)
Yes / Use of Telephone / Hours/Day / varies
Yes / Use of Tools / Hours/Day
Yes / Working Under Time Pressure / Hours/Day / varies
Working Rapidly for Long Periods / Hours/Day

B. Do the major activities of the job include any of the following: (check and quantify as applicable)

Yes / Sitting / Hours/Day / 6 hrs
Yes / Standing / Hours/Day / 1 hr
While standing must you support any weight (e.g., use a heavy tool )? If so, How much weight must you support and for how long?
Yes / Walking / Hours/Day / 1 hr
Stooping / Hours/Day
Kneeling / Hours/Day
Climbing
How High on Ladders?
How High on Inclines?
How High on Stairs?
Yes / Lifting
How Much Weight? / 20 lbs.
Yes / Waist High?
Shoulder High?
Above Head?
How Often: Times/Day
How Often: Times/Week
Yes / Carrying
How Much Weight Alone? / 20 lbs.
How Much Weight With Someone Else?
How Often: Times/Day
Reaching / How High or Low?
Pushing / How Much Weight?
Pulling / How Much Weight?

C. Does the job require any of the following? (check as applicable)

Yes / Finger Dexterity
Yes / Close Work

D. What types of surface are the major activities of the job performed on? (Check as applicable)

Yes / Level Surface
Sloping Surface
Uneven Surface
Slippery Surface
Unstable Surface
Other
(Specify)

E. Are there any other physical tasks that must be performed even though they are not essential job activities. (e.g.,even if the job does not regularly require lifting, carrying, or keyboard or telephone usage during daily activities, does the job require doing some occasionally or in an emergency?)

F. Are there any specific physical requirements for this job? If so, what are they?

3. Working Environment

A. Where are the major activities of the job carried out ? (Check as applicable)

Under 50% / Over 50%
Location / of Day / of Day
Indoors / Yes
Outdoors
Underground
At a Desk or Bench / Yes
In a Car or Truck / Yes
In an Office or Control Room / Yes

B. What working conditions beyond normal office environment?

Extreme Heat
Extreme Cold
Dust
Fumes
Chemicals
Cramped Area
Dampness
Vibrations
Noise
Other
(Specify)

C. Are there any hazards involved in this job? If so, what are they?