POSITION SUMMARY

GHC Healthcare Staff Attorney(s) work closely with the Compliance Counsel and the Chief Compliance Officer to anticipate, assess, and navigate legal and business issues. Staff Attorney(s) proactively anticipate and recognize issues and propose innovative and responsive solutions and are knowledgeable regarding the regulations and procedures relevant to the federal and state reimbursement and regulatory compliance requirements unique to Federally Qualified Health Centers. Healthcare Staff Attorney(s) work closely with other departments within the organization, including pharmacy, by providing legal analysis and advice for areas related to contract law and business transactions. This position is primarily out of the corporate office in Columbia, but some travel will be required to the clinic and pharmacy locations. Reports to Compliance Counsel.

PRIMARY ACCOUNTABILITIES

Achieve Results

1. Provide legal services in a wide range of areas, including but not limited to general business matters, regulatory compliance, pharmacy compliance, privacy and security, intellectual property, contracts, document retention and legislation.

Operational Excellence

1. Ensure and uphold the confidentiality requirements of all patient records and manage all daily tasks and activities consistent with HIPAA, state and federal laws and regulations, as well as clinic and pharmacy policies and regulations regarding confidentiality and security.

2. Ensure organizational compliance with all state and federal laws and regulations

Relationships

1. Develop and ensure effective, positive relationships within and among the administrative, clinic, and pharmacy staff, as well as with patients, vendors, contractors, and related resources.

Professionalism

1. Ensure all actions, job performance, personal conduct and communications represent the organization in a highly professional manner at all times.

2. Uphold and ensure compliance with and attention to all corporate policies and procedures, and the organization's mission and values.

PRIMARY TASKS & DUTIES

1. Review and/or initiate and negotiate all 3rd party contracts, consultant agreements, or other business partners related to GHC prior to signature, and oversee contracts software (HighQ)

2. Drafts all GHC provider agreements

3. Regularly review regulations and statutes pertaining to GHC operations (clinic and pharmacy) to ensure compliance and to propose changes, as necessary.

4. Proposing needed revisions of the program, including internal departmental audits, considering changes in the organization's needs and/or in the law or in policies and procedures of Government and private payer health plans.

5. Participate in departmental meetings, committees and working groups and provide legal input, as necessary.

6. Works with the compliance staff to update all policies, procedures, etc. to reflect all current laws and regulatory requirements (specifically pharmacy-related policies and procedures)

7. Maintain awareness and knowledge of ongoing federal and/or state litigation that could directly affect GHC clinic and/or pharmacy operations, including but not limited to: Medicaid/Medicare reimbursement rates, 340B program requirements, limited distribution drugs, etc.

8. Assist with any onsite site visits related to the clinic and/or pharmacy

9. Assist with all new and renewal accreditation programs for the organization

10. Monitor the pharmacy compliance program, including risk management activities (incident reporting and action request forms) and quality improvement (customer satisfaction surveys).

11. Ensure all pharmacy regulatory and legal requirements are met. This includes, but is not limited to:

• SC Board of Pharmacy
• SC LLR
• DHEC
• DEA
• HRSA
• 340B
• ACHC
• URAC

12. Ensure ongoing monitoring of pharmacy compliance through the oversight of internal departmental compliance packet audits and participation in monthly Pharmacy Oversight Committee meetings and quarterly 340B Oversight Committee meetings.

13. Review all external audit requests related to the pharmacy and work with pharmacy staff to ensure appropriate documentation is provided

14. Reviews any outside requests for pharmacy records

15. Assists staff, as needed, with re-credentialing and other annual reviews of databases (NCPDP, PF Cares, LLR, etc.) and annual license renewals (pharmacy permits, outlet permits, CLIA certificates, licenses, etc.)

16. Provide regular updates to Compliance Counsel on all above-referenced matters.

17. Other such duties and responsibilities that may be added from time to time

ESSENTIAL FUNCTIONS/KEY COMPETENCIES

1. Function in a multi-tasking, multiple priorities environment, while maintaining accuracy and attention to detail.

2. Communicate with a diverse employee population. Will be required to successfully communicate with co-workers and external constituents

3. Utilize a wide variety of office technology and tools to collect, enter, process, file records and documentation