Senior Director, Compliance and Ethics

Your Role 

This role will act as Blue Shield of California’s (BSC’s) Senior Director, Compliance & Ethics. BSC’s Compliance & Ethics Department is part of BSC’s larger Corporate Integrity and Risk Management.  BSC Corporate Compliance & Ethics owns and coordinates the Company’s compliance and ethics program across the enterprise, including all business units, products, services and activities. The Compliance & Ethics program includes the implementation and maintenance of proper preventive, detective and remedial programs and controls; the execution of relevant policies and procedures; training and educating the workforce; implementing an effective communications program; ensuring effective testing, auditing, monitoring, tracking and reporting; and remediating control deficiencies. 

The Compliance & Ethics program encompasses many subject matter areas, including Code of Conduct, Corporate Compliance policy management, compliance training, compliance investigations, anti-bribery, -kickback and –corruption, exclusion lists, Conflict of Interest program management, and other compliance and ethics initiatives. The role will report directly to BSC’s Vice President, Chief Risk and Compliance Officer. While this role will spend most of its time leading our enterprise-wide Compliance & Ethics program, it may serve in additional capacities and assist in other initiatives, as needed.

Your Work

In this role, you will:

• Lead, implement, and maintain an effective enterprise-wide Corporate Compliance and Ethics Program, including but not limited to managing compliance Whistleblower programs, anti-corruption programs, maintaining effective compliance policies and procedures, effective compliance training, awareness, and communications programs.
• Manage and conduct enterprise-wide compliance investigations. Maintain a clear, comprehensive, and integrated enterprise compliance investigation protocol. Oversee all internal and external hotline and compliance reporting channels. Prepare comprehensive investigation summary reports. Ensure proper corrective action and remedial measures are taken once investigations are completed.                           
• Build, develop, and lead team of Compliance & Ethics professionals to ensure robust and effective, preventive, detective and remedial programs and controls throughout the Company’s operations.                                                                                   
• Lead and model collaborations with CIRM and other Blue Shield compliance resources (e.g., Human Resources Employee Relations, IT Security, Legal, Internal Audit) and operational areas to promote the C&E Program and encourage ethical behavior at all levels within Blue Shield.                                                                        
• Provide regulatory and compliance industry standards support and guidance to Blue Shield. Lead development and implementation of enterprise-wide compliance policies, procedures, and training programs to effect compliance with legal and regulatory standards.                                                                                   
• Research, identify, review, and summarize new and existing regulations; maintain awareness of industry trends and regulatory actions; and communicate impact of these changes to CIRM Leadership and the Chief Risk and Compliance Officer (CRCO).

Your Knowledge and Experience

• Bachelor’s Degree and a minimum of 12 years of substantive health care legal, compliance and ethics experience with increasingly progressive responsibility including Director-level Compliance experience and 8 years of management/leadership experience required.
• Juris Doctor (JD) from an ABA accredited law school and admission to practice law in California is preferred.                                   
• Functional subject matter expertise in Codes of Conduct, compliance investigations, compliance hotlines/reporting, compliance training and communications, anti-corruption/anti-bribery/anti-kickback, government contracting, exclusion lists, corporate ethics, business partner and third-party risk management, and applicable laws, regulations and standards including anti-fraud, anti-corruption, Federal Sentencing Guidelines, U.S. Department of Health, and Human Services (DHHS) Officer of Inspector General (OIG) and Centers for Medicare and Medicaid Services (CMS) guidance on effective compliance programs.                     
• Demonstrated experience with writing and implementing policies and procedures, performing risk assessments, documenting controls and control gaps, remediating control gaps, and delivering and maintaining a robust and effective compliance and ethics program.                                                                        
• Mus