Senior Managing Counsel - Enterprise Investigations

We are looking for an experienced leader skilled in compliance investigations to lead the Legal Department’s Enterprise Investigations unit.  Our team of seven internal investigators is responsible for assessing and investigating reports and allegations of healthcare fraud (including False Claims Act, Anti-Kickback statutes, and Stark Law), conflicts of interest, theft and fraudulent schemes, contract and procurement concerns, data privacy issues, discrimination, harassment, failure to report or escalate, and other inappropriate behavior.

Working within Cigna’s Legal Department, our internal investigators frequently partner with, and act under the supervision and direction of counsel.  They are responsible for cultivating a culture that emphasizes integrity, and a working atmosphere that promotes open and candid discussions regarding ethics or compliance concerns; acceptance of responsibility for actions taken; effective oversight; and operational transparency with key stakeholders.  To be successful, internal investigators must set a collegial tone and operate as thought partners with business leaders and other in-house professionals, including those in Legal, Employee Relations, Human Resources, Internal Audit, Corporate Security, and Information Security.

Specific duties include:

• Drive strategy, framework, and execution of the Enterprise Investigations team to ensure investigations are conducted to the highest standards, with an emphasis on continuous improvement;
• Lead a team of seven experienced investigators, providing guidance, mentorship, and support;
• Manage complex compliance, ethics, and employment investigations, including conducting case intake meetings, background research, interviews, and stakeholder debrief meetings;
• Assist with the review, analysis, and resolution of reports received through Cigna’s Ethics Help Line and other channels, including complaints involving allegations of fraud, corruption, privacy concerns, conflicts of interest, discrimination, harassment, retaliation, failure to escalate, and other inappropriate behaviour;
• Ensure that compliance and ethics inquiries, and reports of alleged employee misconduct are promptly assessed, responded to, timely and thoroughly investigated, and resolved;
• Partner with Cigna's team of e-discovery and forensic investigators to identify, preserve, and obtain relevant documents and data;
• Conduct internal investigations, to include reviewing relevant documents, communications and data, and conducting interviews of relevant individuals, including privileged internal investigations conducted under the supervision and direction of in-house and/or outside counsel;
• Ensure that investigative actions, files, findings, and outcomes are thoroughly and timely documented, memorialized, accurate and complete; prepare reports of interviews and other investigative reports; and ensure that findings and conclusions from internal investigations are timely and effectively communicated to relevant stakeholders;
• Collaborate with Human Resources and Employee Relations on any employment actions arising from internal investigations;
• In collaboration with partners in Enterprise Compliance and the relevant business segment, conduct root cause analyses and determine whether any remedial or corrective actions may be appropriate, and whether matters and/or findings or conclusions should be disclosed to federal and/or state agencies;
• Ensure that appropriate policies and procedures, and training and education programs, are adopted as warranted by findings in internal investigations.
• Foster a culture of integrity, accountability, and compliance within the organization.

Qualifications:

• Juris Doctorate from an ABA accredited law school required;
• Active law license in good standing in at least one state;
• Experience conducting and managing complex investigations, preferably in a large, matrixed healthcare company;  previous experience as a prosecutor, special agent, or other investigative office also preferred;
• Experience leading a team in a manner that enables a collaborative, respectful, and inclusive environment;
• Strong people skills, including effective interviewing skills, and outstanding oral and written communications skills;
• A comfort level with the laws and regulations that apply to The Cigna Group’s businesses;
• Ability to review and analyze a complex set of facts, documents, or data, and an ability to identify, distill, and present the most relevant material;
• Ability to evaluate complex issues and make appropriate recommendations;
• A demonstrated commitment to integrity, compliance, and ethical decision making;
• Consistently sound judgment and incisive analytical abilities;
• Ability to present or explain complex issues