Job description

• Assists in the development and ongoing review and oversight of the privacy and security components of CCA's Corporate Compliance Plan, Code of Conduct and Compliance Program description and identification of compliance risks.
• Creates and executes CCA's annual privacy & security compliance workplan.
• Collaborates with CCA's regulatory compliance team and the CISO to respond quickly, effectively, and transparently to any inquiries, compliance reviews or investigations by the Department of Health and Human Services' Office of Civil Rights, other state, and federal regulators.
• Establishes and administers a process for receiving, documenting, tracking, investigating, and taking action on all complaints concerning the organization's privacy and security policies and procedures in coordination and collaboration with IT, legal and operations.
• Assists in selection and ongoing training of Privacy & Security Liaisons for each CCA entity.
• Co-chairs the company's privacy and security committee with the company's Chief Information Security Official (CISO)
• Supports the privacy and security related activities of the CCA Executive Leadership Compliance, Audit & Enterprise Risk Council and the Board of Directors' Audit, Compliance and Enterprise Risk Committee.
• In collaboration with the CISO, representatives of Human Resources (HR) and other members of the compliance team, oversees the development, delivery, and ongoing improvement of CCA's privacy and security compliance training and awareness program
• In cooperation with the CISO, and legal advises the Chief Compliance Officer, Human Resources, and executive leadership, on appropriate disciplinary actions for failure to comply with CCA's privacy & security policies.
• Collaborates with the CISO to deliver third party attestation report for controls related to the security, availability, or processing integrity of a system or the confidentiality or privacy of the information processed by that system (SOC-2 reporting).

• Works across the organization to respond to any release of protected health information and to ensure full coordination and cooperation consistent with CCA's policies and procedures and legal and regulatory requirements.
• Maintains current knowledge of applicable federal and state privacy laws and accreditation standards, and monitors advancements in information privacy technologies to ensure organizational adaptation and compliance.
• Serves as the privacy subject matter expert to the Public Affairs team in representing the company's interests related to state and federal legislation, regulations, or standards and in responding to press inquiries related to CCA's privacy and security practices and to increase the public's awareness of organization's efforts to preserve member privacy & security.
• Collaborates with the CISO, IT and other operations partners to track disclosures of and access to protected health information as required by law, regulation, and contract and, as necessary, to with CCA's regulatory compliance team to report any and all necessary data to management and as required by law, regulation, and contract.
• Performs initial and periodic information privacy risk assessments and analyses; conduct ongoing auditing, monitoring, and testing activities in coordination with CCA's other compliance and enterprise risk functions.
• Leads in collaboration with the CISO and relevant functional business owners, the review, development, implementation and ongoing compliance monitoring of all data breach and incident response policies, and procedures, third party vendor assessments, vendor guidelines, standards, and due diligence, enterprise security & privacy policies, business associate agreements and corporate record retention policies
• Leads in ensuring all CCA related entities maintain appropriate privacy and confidentiality consent and authorization forms, information notices and materials, and signage reflecting, as appropriate, CCA's privacy and security policies, procedures, and standards of practice.
• Collaborates with and advises applicable organization units in establishing, updating and monitoring compliance with policies and procedures related to the collection and use of patient/member data, advising members and patients of their rights to access, transfer, inspect, amend, and restrict access to their data and with complying with patient/member requests to access, transfer, inspect, amend, and restrict access to their data.

• Works closely with IT Security, members of the electronic medical record implementation/informatics team, and other information technology personnel to ensure that the organization's privacy & security protections keep pace with technological advances.
• Coordinates with management, physical plant, IT security, and others to assure physical safeguards to guard data integrity, confidentiality, and availability.
• Reviews all system-related information security plans throughout the organization's network to ensure alignment between security and privacy practices and acts as a liaison to the Chief Information Security Officer and the information systems department.
• Collaborates with CISO and regulatory compliance to assure complete and effective reporting all breaches and security incidents, as required by applicable federal and state law, regulation, and applicable contracts.
• Collaborates with the CISO and IT to develop, implement, administer and, on an ongoing basis audit, a system-wide requests for access/disclosure verification procedure that reasonably verifies the identity of the individual or entity requesting access or disclosures, and /or legal authority to request the personal health information.
• Collaborates with CISO and legal to acquire and maintain appropriate cyber insurance.

• Collaborates with operations, HR, CCA's facilities team, the CISO and IT on the privacy and security components of CCA's disaster recovery plan. Reviews and updates the privacy and security components of the disaster recovery plan regularly to assure consistency with applicable laws, regulations, standards, and relevant contract terms.
• Coordinates with senior management, operational managers, CCA's facilities team, the CISO, IT managers, and business support services to develop, update and continuously improve CCA's business continuity policies, procedures, and protocols.

• Standard office conditions.

• JD or master's degree in healthcare administration or similar Discipline
• Privacy & Security Certification(s) such as Certified Information Systems Auditor (CISA), Certified Information Security Manager (CISM), Certified Risk and Information Systems Control (CRISC)
• Certification in Healthcare Compliance (CHC)

• Six Sigma Certification
• Project Management Certification

• 15+ years of multi-state and/or global privacy & security experience within healthcare operations, regulatory compliance, or similar field
• Significant supervisory privacy and/or security experience within healthcare
• Extensive experience conducting investigations and overseeing the coordination, drafting, and submission of responses to regulatory agencies such as the OCR
• Multi-state experience
• Demonstrated experience successfully managing multiple priorities simultaneously by maintaining established timeframes, adhering to work plans, and communicating changes effectively.
• Significant experience with developing policies & procedures and oversight of implementation of procedures designed to ensure compliance with all pertinent regulations

• Excellent organizational and independent decision-making capabilities
• Extensive knowledge required regarding compliance with privacy & security regulations, OCR, Federal Sentencing Guidelines, and healthcare laws and regulations (both Federal and state)
• Able to utilize a variety of computerized software applications such as databases, spreadsheets, word processing, etc.
• Able to communicate clearly, make oral presentations to senior management, and prepare concise detailed written reports
• Demonstrated organization, facilitation, communication, and presentation skills.
• Able to initiate and develop innovative solutions to problems, to identify new opportunities; and have organizational perspective to see how the pieces fit and reflect that perspective in day-to-day decisions.
• Able be self-motivated and take initiative in a positive and productive manner
• Strong analytical skills -- having the ability to identify an issue, conduct an analysis to determine business impact (including gap analysis), troubleshoot and identify
• Strong project management skills and strong verbal and written communication skills
• Must be able to prioritize work and use independent judgment.

• English

• Multilingual

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