Ethics Education & Communications Program Manager I/II - 021041

Summary:

This position is responsible for the ethical compliance program and associated education, training, and ethics communications for the enterprise. The incumbent prepares communications and educates to ensure compliance with policies, laws, and the Corporate Code of Business Conduct. They also promote ethical business conduct, facilitates ethical decision making, and provide business partners with the tools and resources to assist them in understanding and meeting corporate ethics and compliance standards through training and communications. Under minimal supervision, this position supports the Ethics Office and conducts internal investigations that are sensitive, confidential, and often high risk to the corporation with utmost discretion.

Essential Accountabilities:

Level I

• Leads and manages Ethics and Compliance initiatives and projects including ethics investigations, ethics and compliance training, and ethics and compliance communications. Effectively communicates ethics, privacy, and compliance policies, procedures, and practices to all employees, Boards of Directors, and other agents through publications, training, and educational programs. Maintains strict confidentiality related to matters of the corporations and Boards of Directors.

• Leads ethics investigations for all areas of the enterprise, conducts extensive research, interviews subjects, facilitates resolution and provides highly detailed and accurate documentation for all actions taken during the investigation process. Collaborates with Human Resources, management, and Corporate Legal staff throughout the investigative process to ensure an informed and fair resolution and determine disciplinary action that is consistent and fair.

• Provides expert advice and interpretation of the Corporate Code of Business Conduct, Conflict of Interest, and Ethics and Compliance including the applicability of corporate policies and procedures to specific situations for employees and Boards of Directors. May participate on various groups, committees, etc. to represent EEC and ensure ethical practices are being followed. May, at times, represent the enterprise with external stakeholders (EEOC, DHR).

• Manages Code of Conduct allegation investigations in accordance with established policies and procedures, for all areas of the enterprise. Consults with Enterprise Legal and Supplier Solutions to determine applicability of attorney client privilege requirements for ethics investigations. Reviews results with the Ethics Officer.

• Assesses potential non-compliance vulnerabilities, identifies root causes of issues, provides practical business recommendations for corrections and works with business areas to develop recommendations and reach meaningful and appropriate resolutions.

• Compiles data for trending and analysis; prepares investigative, training, and communication reports to senior management and the Audit Committee of the Board of Directors.

• Participates in audits, provides verification of actions, and presents content representing the corporation's Ethics, Education, and Communications (EEC) processes. Responds to audit requests and supplies evidence of training, communications, and investigations to meet regulatory requirements.

• Develops and delivers an effective Ethics and Compliance Communication Plan for the enterprise. Assists with the development and execution of communication and education tools to ensure continued compliance with expected employee behavior.

• Designs, develops, and executes training programs for Regulatory Compliance, Privacy, Security, Workplace Violence, FWA (Fraud, Waste and Abuse) and Code of Conduct topics ensuring ethical awareness across the organization through communication activities and deliverables for the ethics and compliance functions. Monitors training programs for accuracy, currency, and compliance with all state, federal, and accreditation requirements.

• Administers the annual mandatory training process by partnering with subject matter experts to solicit content and create or refresh training for new hires, employees, board of director members, and contractors. Guide subject matter experts in capturing the information necessary to meet regulatory requirements and comply with established training curriculum requirements.

• Develops and executes compliance communication tools and monitoring programs to ensure continued compliance. Develops and implements communication vehicles to address expectations of employee behavior.

• Manages annual Ethics and Compliance Awareness Days including preparation of communications content, events and activities which may include, vodcasts, blogs, video creation.

• Administers the Compliance Champion Program which includes updates to promote participation and awareness.

• Reviews and mitigates new-hire and annual Conflict of Interest and Code of Conduct disclosures in accordance with applicable corporate policies and procedures. Develops annual review plan including review of questionnaires, system design, reporting function and content review. Review disclosures for actions required and facilitate discussions with employees, leaders and legal as needed to address issues.

• Establishes and maintains strong relationships with peer groups and professional organizations to further departmental and corporate goals and objectives.

• Consistently demonstrates high standards of integrity by supporting the Lifetime Healthcare Companies' mission and values, adhering to the Corporate Code of Conduct, and leading to the Lifetime Way values and beliefs.

• Maintains high regard for member privacy in accordance with the corporate privacy policies and procedures.

• Regular and reliable attendance is expected and required.

• Performs other functions as assigned by management.

Level II (in addition to Level I Accountabilities)

• Manages the highest level of complex compliance issues and exercises decision-making in project work groups. Authorized to investigate all internal employees regardless of rank and/or title in the organization. Collaborates with various departments and reports to Ethics and Compliance leadership regarding high-risk investigations at the time of discovery (of allegations).

• May serve as a primary contact with internal and external counsel to resolve complex and highly sensitive compliance issues, ensuring optimal resolution.

• Effectively engages in collaborative decision making for timely resolution of investigations while managing multiple cases in a variety of geographic locations.

• Provides guidance to less experienced team members and internal customers, in the absence of management. Acts as a resource for the department and serves as a trusted advisor to the organization.

Minimum Qualifications:

NOTE: We include multiple levels of classification differentiated by demonstrated knowledge, skills, and the ability to manage increasingly independent and/or complex assignments, broader responsibility, additional decision making, and in some cases, becoming a resource to others. In addition to using this differentiated approach to place new hires, it also provides guideposts for employee development and promotional opportunities.

All Levels

• Associate's degree in Business/Health Administration with seven or more years' progressive experience in related field, or Bachelor's degree in Business Administration, Health Administration or related area with five or more years of related experience in compliance, training, instructional design, audit, internal investigations, human resources environment, health insurance or health care delivery.

• Extensive knowledge of regulatory initiatives and legislation that impact the Corporation.

• Proficiency in statistical analysis, data collection and reporting. Strong creative thinking and research skills with attention to detail.

• Experience creating online courses with eLearning software (Captivate, Articulate, etc.). Ability to design and develop training materials/programs and facilitate training/education through various mediums (e.g., classroom, online sessions).

• Knowledge of and/or ability to learn new training tools and become proficient in software and programs for developing, delivering, and tracking training (e.g., Articulate 360, Camtasia, Vyond, Stream). Experience with video production/editing software (Camtasia, etc.).

• Proven project management/implementation skills. Proven ability to solve problems and effectively manage complex issues.

• Strong organizational skills and ability to manage multiple projects simultaneously with minimal management directive.

• Advanced interpersonal skills inclusive of conflict management and face to face interviewing with tact and diplomacy.

• Excellent written and verbal communication skills and ability to collaborate across the organization. Ability to present/interact efficiently to internal and external audiences, and with all levels of management.

Level II (in addition to Level I Qualifications)

• Seven or more years of related experience or training. In lieu of degree, a minimum of twelve years in health insurance or health care delivery.

• Professional designation related to compliance or auditing desired.

• Demonstrated ability handling the highest level of complex compliance issues and exercising decision-making in project work groups.

• Ability to operate under the highest degree of initiative, innovation, and autonomy with limited guidance.

Physical Requirements:

• Ability to work while sitting and/or standing at a workstation viewing a computer and using a keyboard, mouse and/or phone for three (3) or more hours at a time.

• Ability to travel across the Health Plan service region for meetings and/or trainings as needed.

One Mission. One Vision. One I.D.E.A. One you.

Together we can create a better I.D.E.A. for our communities.

At the Lifetime Healthcare Companies, we're on a mission to make our communities healthier, and we can't do it without you. We know diversity helps fuel our mission and that's why we approach our work from an I.D.E.A. mindset (Inclusion, Diversity, Equity, and Access). By activating our employees' experiences, skills, and perspectives, we take action toward greater health equity.

We aspire to reflect the communities we live in and serve, and strongly encourage people of color, LGBTQ+ people, people with disabilities, veterans, and other underrepresented groups to apply.

OUR COMPANY CULTURE:

Employees are united by our Lifetime Way Values & Behaviors that include compassion, pride, excellence, innovation and having fun! We aim to be an employer of choice by valuing workforce diversity, innovative thinking, employee development, and by offering competitive compensation and benefits.

In support of the Americans with Disabilities Act, this job description lists only those responsibilities and qualifications deemed essential to the position.

Equal Opportunity Employer

Equal Opportunity Employer/Protected Veterans/Individuals with Disabilities

The contractor will not discharge or in any other manner discriminate against employees or applicants because they have inquired about, discussed, or disclosed their own pay or the pay of another employee or applicant. However, employees who have access to the compensation information of other employees or applicants as a part of their essential job functions cannot disclose the pay of other employees or applicants to individuals who do not otherwise have access to compensation information, unless the disclosure is (a) in response to a formal complaint or charge, (b) in furtherance of an investigation, proceeding, hearing, or action, including an investigation conducted by the employer, or (c) consistent with the contractor's legal duty to furnish information. 41 CFR 60-1.35(c)