Vice President of PBM Compliance and Regulatory Operations
hace 1 día
Albany
We wanted a PBM that worked better. So we took a bold approach... When we set out in 2011 as Southern Scripts to reshape pharmacy benefit management, it was because we believed there was a better way. Throughout our journey, we’ve never been afraid to challenge widely accepted industry practices or to pioneer a better model. We see that the concept of “transparency” is gaining momentum. At Liviniti, we’ve been delivering it for more than a decade. Liviniti, grew from a commitment to offer an uncomplicated approach to managing pharmacy benefits. One based on transparency, affordability, quality, service and innovation. Our name describes the future that we envision - one with infinite possibilities for better living. Join a team that is reshaping pharmacy benefit management! At Liviniti, we give people the runway to do their best work. We seek people who analyze, challenge and think outside the box – and reward them with an environment and benefits that support their professional and personal goals. We are currently seeking a Vice President of PBM Compliance and Regulatory Operations. This role can be hybrid (office and remote). Ideal candidates reside in or around Natchitoches, Louisiana. Role and Responsibilities The Vice President, PBM Compliance and Regulatory Operations is responsible for building, leading, and operating Liviniti’s PBM compliance and privacy functions to ensure adherence to all applicable state and federal laws and regulations, including PBM-specific requirements and HIPAA, HITECH, ERISA-related disclosures, and the Consolidated Appropriations Act (CAA). This role translates regulatory and privacy obligations into operational workflows, system logic, controls, and audit-ready processes, embedding compliance into day-to-day business operations. The role owns PBM regulatory compliance, market conduct exam readiness, and privacy operations, including oversight of HIPAA incidents, breach response, corrective action plans, and ongoing risk mitigation. Partnering closely with Legal, Operations, Product, and Technology teams, this position does not act as a plan fiduciary or manage client ERISA compliance, but ensures PBM operations, data, disclosures, and privacy practices meet all regulatory and contractual requirements as an integral member of the Legal and Compliance leadership team. The Vice President, PBM Compliance and Regulatory Operations is required to perform, but not limited to, the following duties and professionally undertake the following key responsibilities: Build and Implement the Compliance Function • Stand up the compliance program and drive full implementation across the business., • Develop company and departmental policies and procedures and convert them into actionable workflows, controls, and system requirements., • Establish governance, reporting, and accountability mechanisms that are actively used and adhered to State PBM Regulatory Compliance • Own and maintain a state-by-state regulatory inventory and monitoring process., • Translate regulatory requirements into specific business rules and system configurations., • Partner with operations and technology to implement requirements in areas such as claims adjudication, NADAC, MAC pricing, pharmacy network standards, and appeals processes., • Validate that requirements are correctly implemented and functioning in practice. Market Conduct Exam Readiness • Build and maintain a continuous state of market conduct exam readiness., • Develop documentation, evidence repositories, and audit trails tied to actual operations., • Conduct internal readiness reviews and mock exams., • Lead regulatory exams, including data requests, responses, and remediation efforts. Systems, Controls, and Monitoring • Design and implement system-based compliance controls and automated edits within PBM platforms., • Work closely with technology teams to embed compliance with claims logic and operational workflows., • Establish ongoing monitoring, including control testing, exception reporting, and data validation., • Develop dashboards and reporting to track compliance performance and risk. CAA and Gag Clause Compliance (PBM scope) • Oversee PBM responsibilities under the Consolidated Appropriations Act (CAA), • Support and validate data for RxDC reporting., • Ensure compliance with gag clause requirements and support related attestations., • Build controlled, repeatable processes for cross-functional data aggregation and reporting., • Ensure outputs are accurate, documented, and audit ready. Audit, Risk, and Third-Party Oversight • Build a risk-based audit and monitoring program aligned to regulatory exposure., • Identify control gaps and drive remediation with business owners., • Oversee compliance of pharmacies, vendors, and downstream partners. Privacy Governance & HIPAA Oversight • Provide executive leadership for the organization’s HIPAA Privacy, Security, and Breach Notification Compliance programs, ensuring alignment with enterprise compliance and regulatory strategy., • Oversee development and maintenance of HIPAA policies, standards, and procedures and integration into business and operational processes., • Interpret and operationalize federal and state health privacy regulations into actionable compliance controls and requirements., • Partner with Legal, Information Security, IT, HR, and business leaders to embed privacy compliance across the organization and third-party relationships., • Report on privacy risk posture, key metrics, and emerging issues to executive leadership and governance bodies HIPAA Incident Management & Corrective Action • Developing and updating HIPAA policies and procedures within the company, • Serve as executive lead for HIPAA-related incidents, overseeing intake, investigation, risk assessment, and breach determination., • Ensure timely, accurate, and compliant breach notifications to affected individuals, regulators, and other required stakeholders., • Direct development and execution of corrective action and remediation plans, addressing root causes and control gaps., • Oversee regulatory interactions related to privacy incidents, including OCR inquiries, audits, and enforcement actions, in coordination with Legal., • Monitor and validate the effectiveness of remediation efforts and drive continuous improvement to prevent recurrence. Leadership and Execution • Operate as a hands-on leader, directly owning key deliverables in early stages., • Build and scale the compliance team over time., • Serve as primary point of contact for regulators, auditors, and external counsel., • Provide regular reporting and insight into executive leadership. What We Have to Offer Our benefits package is designed to keep our employees happy and healthy – physically, mentally and financially. • Servant Culture, • Medical, Dental, Vision insurance, • Disability and Life insurance, • Employee Assistance Program, • Remote work options, • Generous Paid-Time Off, • Annual Reviews and Development Plans, • Retirement Plan with company match immediately 100% vested Required Skills and Competencies • Ability to review and interpret state and federal guidelines and translate them into practical, operational solutions., • Executive-level leadership skills with experience building and leading high-performing compliance or regulatory operations teams., • Sound judgment and decision-making in ambiguity, escalation, and regulatory risk scenarios., • Strong understanding of controls, audit readiness, and documentation, • Ability to balance compliance rigor with business enablement., • Strategic mindset with the ability to anticipate regulatory trends and proactively prepare the organization., • Strong analytical skills to assess operational risk, data flows, and system impacts of regulatory requirements., • Exceptional written and verbal communication skills, including the ability to explain regulatory requirements clearly to non-legal audiences., • Willing to challenge and push teams to implement, not defer., • Execution-oriented and comfortable working in the details, • Effective in ambiguous, fast-moving environments, • Ability to work independently and collaboratively in a team environment. Success Metrics (First 12 Months) • Compliance program implemented and operating across core PBM functions, • State PBM regulatory requirements translated into system logic and operational workflows., • Organization maintains ongoing market conduct exam readiness with complete documentation and evidence., • System-based controls and monitoring in place with measurable performance indicators, • CAA-related PBM processes operational, repeatable, and audit-ready., • All HIPAA incidents are identified, investigated, and resolved within required regulatory timeframes, with accurate breach determinations and compliant notifications., • Corrective actions address root causes and control gaps, with validation showing measurable reduction in repeat incidents and improved privacy control effectiveness. Supervisory Responsibility This position supervises the Compliance Staff Position Type and Expected Hours of Work Some flexibility in hours is allowed, but the employee must be available during the “core” work hours of 8:00AM to 5:00PM CT. The company covers clients from West to East Coast; work times must be adjusted to cover meetings in all time zones. Ability to work extended hours, weekends, and holidays pursuant with industry demands. Travel Limited travel expected for this position. Required Education and Experience • Bachelor's degree (B.A.) in Law, Healthcare Administration, Business Administration, Public Health, Pharmacy, or a related field or 2+ years of related experience and/or training; or equivalent combination of education and experience, • High degree of professional ethicsand integrity, • Sound judgement and ability to analyze situations and information. Preferred Education and Experience • Juris Doctor (JD) or equivalent legal background strongly preferred., • 10+ years of experience in healthcare compliance, PBM, health plan, or similar regulated environment, • Demonstrated experience implementing regulatory requirements into operations, systems, or workflows., • Strong knowledge of state PBM laws or comparable multi-state regulatory frameworks, • Experience supporting market conduct exams, audits, or regulatory reviews., • Proven ability to work cross-functionally with technology, operations, legal, and finance teams. Liviniti, LLC provides equal employment opportunities (EEO) to all employees and applicants for employment without regard to race, color, religion, sex, national origin, age, disability, or genetics. In addition to federal law requirements, Liviniti complies with applicable state and local laws governing nondiscrimination in employment in every location in which the company has facilities. This policy applies to all terms and conditions of employment, including recruiting, hiring, placement, promotion, termination, layoff, recall, transfer, leaves of absence, compensation and training. Liviniti expressly prohibits any form of workplace harassment based on race, color, religion, gender, sexual orientation, gender identity or expression, national origin, age, genetic information, disability, or veteran status. Improper interference with the ability of Liviniti employees to perform their job duties may result in discipline up to and including discharge. EOE M/F/V/D
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