Senior Manager, Inflation Reduction Act Program Analysis & Compliance

About the Department 

The Finance & Operations department brings insights and intelligence to inform decision making & drives digitalization and business solutions to attain NNI goals. Finance & Operations works closely across the organization to guide enterprise-wide resource allocations, investment choices, drive core operations and develop insights to drive growth and operational excellence across the value chain while innovating for future capabilities. Our focus on innovation ensures we're constantly building future capabilities. We're responsible for regulating accounting, upholding workplace safety, managing our supply chain and sampling, supporting technological and data innovation, maintaining our facilities and assuring the integrity and completeness of all business transactions. At Novo Nordisk, you will have the opportunity to build a career in a global business environment. We encourage our employees to make the most of their talent, and we reward hard work and dedication with opportunities for continuous learning and personal development. Are you ready to maximize your potential with us?

 

The Position

Assist Director of Institutional Contracts in managing the development and implementation of 340B as well as Inflation Reduction Act ("IRA") processes and compliance activities for the Medicare Drug Negotiation Program. Ensures accurate and timely input and implementation of 340B requirements as well as Maximum Fair Price ("MFP") effectuation requirements consistent with regulatory requirements, NNI policies and procedures and Sarbanes-Oxley regulations. Co-develop processes to validate 340B Program processes as well as MFP refund processes, oversee general management, and modifications in the event of regulatory changes. Supports analytics, good faith inquiries, complaints, and post payment audits. Supports master data management requirements for the IRA, as required. Supports special projects for all U.S. government programs to assist with compliance and implementation of new and existing regulations.

 

Relationships

Reports to the Director of Federal and Institutional Contracts. Also works closely and supports MDRP, Chargebacks and Master Data Management. Also maintains relationships with the Finance, Pricing & Contracts, IT, Legal, Market Access and Field Sales. External relationships may include wholesalers, 340B entities, dispensing entities, vendors and other customers. Maintains a positive working relationship as an NNI representative to all stakeholders.

 

Essential Functions

• Supports resolution of government contract issues and compliance with 340B regulations and review of MFP refund payments within the 14-day payment window to confirm accuracy of refund calculation and adherence with NNI policies and procedures
• Coordinates maintenance of membership lists with Membership Team and supports onboarding new customers into Model N
• Oversees and manages issuance of 340B refunds to covered entities and MFP refunds to dispensing entities
• Assists with developing policies and procedures for 340B and MFP refunds
• Independently and proactively manages outsourced activities related to administration of 340B and MFP tasks
• Manage inquiries from 340B entities as well as responses to Good Faith Inquires (“GFI”) from dispensing entities
• Provide support for SOX inquiries and ensure adherence to SOX controls.  Performs post audit reviews and analysis of 340B PHS chargebacks and MFP rebates
• Ensure timely receipt of claim-level data, transmission of payment elements, and submission of required information such as audit, complaint, and dispute data
• Proactively notify the MTF Data Module (“MTF DM”) Contractor of any system changes that may impact connectivity
• Update CMS with any changes to the Manufacturer MTF Enrollment Information within 30 calendar days of such changes
• Access claim-level data elements through the MTF DM and maintain functionality to receive and process this data
• Monitor for inaccuracies in previously transmitted claim-level payment elements
• Regularly update, correct, maintain, and re-certify the completeness and accuracy of Manufacturer MTF Enrollment Information within the MTF DM
• Utilize the MTF PM in alignment with the Manufacturer’s MFP Effectuation Plan and update the Plan as required by applicable guidance and regulations
• Provide accurate banking account information to the MTF Data Module Contractor in a