Director, 340B Compliance (Director, Procurement Systems and Operations), Corporate Pharmacy

New York, New York


Employer: NYC Health Hospitals
Industry: CORPORATE PHARMACY
Salary: Competitive
Job type: Full-Time

Empower Every New Yorker - Without Exception - to Live the Healthiest Life Possible

NYC Health + Hospitals is the largest public health care system in the United States. We provide essential outpatient, inpatient and home-based services to more than one million New Yorkers every year across the city's five boroughs. Our large health system consists of ambulatory centers, acute care centers, post-acute care/long-term care, rehabilitation programs, Home Care, and Correctional Health Services. Our diverse workforce is uniquely focused on empowering New Yorkers, without exception, to live the healthiest life possible.

At NYC Health + Hospitals, our mission is to deliver high quality care health services, without exception. Every employee takes a person-centered approach that exemplifies the ICARE values (Integrity, Compassion, Accountability, Respect, and Excellence) through empathic communication and partnerships between all persons.

Job Description

NYC Health + Hospitals' Supply Chain Services is an enterprise-wide centralized department which solicits proposals, and negotiates/enters into contracts for goods, services, software, pharmaceuticals, consultants, staffing, and construction for NYC Health + Hospitals' eleven acute hospitals, six long-term care facilities, numerous clinics, correctional health services, 45,000 staff, with an annual spend of approximately $1.5 billion. Supply Chain services also works closely with facility-based materials management, inventory management, distribution and logistics.

General Responsibilities

Reporting to the Senior Director of 340B, Pharmacy/Supply Chain, the Director of 340B Compliance serves as the covered entity's compliance expert on 340B Program details, audits, policies, and procedures. Ensures that compliance regulations are developed, implemented, and maintained according to organizational, regional, national, state and federal requirements.
The Director of 340B Compliance will be responsible for ensuring 340B program integrity, assisting the organization oversight operations management, contracting, auditing, project management, and vendor management.
The Director of 340B Compliance will provide ongoing training, education, and communication required for 340B program compliance and assist in developing audit materials for monitoring of the 340B program.
The Director of 340B Compliance will also actively engage with leadership and participate in decision-making processes related to the implementation of 340B initiatives. Develops and maintains internal relationships (Legal, Compliance, Finance, IT) and external relationships (wholesalers, manufactures, contract pharmacies, split-billing software vendors, pharmacy benefit managers, and third-party administrator (TPA) as needed.

The Director of 340B Compliance
1. Compliance
  • Ensure that facilities maintain adherence to all 340B Program regulations and guidelines
  • Assure ongoing maintenance of up-to-date policies and procedures and offer contributions and changes to ensure compliance
  • Administer systems and processes to limit program liabilities and provide proper audits to identify risk and prevent duplicate discounts and diversion
  • Perform reviews of all pertinent audits on a routine basis; may involve presenting and resolving reconciliation issues as they arise during the monitoring and reconciliation process
  • Serves as the point person and coordinator for all audits. Coordinates all requests and responses
  • Provides oversight for all audits performed by independent external auditors
  • Coordinates external compliance assessments with outside firms, when appropriate, to validate internal processes
  • Reviews and monitors all points of service where 340B participation occurs to ensure policy and procedure compliance, covered entity eligibility, and "covered patient" eligibility
  • Ensures that audits follow current regulatory compliance recommendations and are completed at the facility level
  • Ensures evaluations of gaps at the site level and assists in providing the tools necessary to be compliant with the 340B Program

This position requires an experienced 340B program background in Federal, State, and Local regulation requirements as well as analytic and problem solving skills. This position also requires reporting and presentation skills to communicate initiatives status at all levels of the hospital system.

The individual in this position must:
  • Possess knowledge associated with 340B program and its associated regulations and requirements.
  • Have experience in managing multiple covered entities and FQHC principles and practices.
  • Ability to manage multiple Third Party Administrators (TPA), and create/manage profitable financial structures within each TPA.
  • Experience in preparation and execution of successful HRSA audits.
  • Ability to manage and improve compliance with the use of internal and external auditors.
  • Perform associated duties that are predominantly intellectual and varied in nature, requiring creative, analytical, evaluative, interpretive, and/or critical thinking
  • Exercise discretion and independent judgment, requiring only general supervision for day-to-day tasks

SUMMARY OF DUTIES AND RESPONSIBILITIES:
1. Leads projects, attends meetings, creates/maintains contract compliance, reduction of spend, data mining/reporting, ensures transactions are compliant/timely, and prepares reports with key stakeholders which may include timelines, resource needs, and potential obstacles for each project. Utilizes standard project management tools and summary documents to track and communicate status of projects.
  • Conducts and reviews all audits and compliance monitoring
  • Assists the external, independent audit team in collection and pulling of data requests

2. Analyzes business needs and ensures that functional, financial, and technical requirements are documented.
  • Develop communication strategy and establish communication plan.
  • Performs necessary investigations, analyses, and evaluations to determine project feasibility.
  • Prepares routine project status reports.
  • Provide regular project status information to team members, including attending required meetings and following-up on action items.
  • Ensure adherence to protocols, procedures, and project plans.
  • Establish project goals and measurements of success
  • Ensure each project deliverable has clear completion criteria and acceptance plan
  • Maintains all relevant documentation and communications as part of program library.

3.Provides direction and support to the project team ensuring the team is informed of all project changes, decisions, etc. that may affect the success of the project.
4. Establishes and maintains collaborative relationships within the system in order to obtain information and content from providers and colleagues to foster successful project completion.
5. Support short and long term operational/strategic business activities - by developing, enhancing and maintaining project information and models. Also develop and implement effective/strategic business solutions through research and analysis of data and business processes.
6. Develops and manages best-practices and tools for performance improvement plan execution and management. Identifies and manages performance improvement dependencies and critical path issues.
  • Helps optimize TPA portals and participates in weekly strategy and improvement calls
  • Reviews file and data integrity across all TPAs
  • Monitors ineligible claims and reviews for potential eligibility and qualification
  • Projects and analyzes internal ERX data to identify new contract pharmacy relationships
  • Investigates and examines TPA suggested pharmacies for contract pharmacy expansion

7.Serve as an operational resource for internal team members for expedited problem identification and resolution, provision of project-specific updates, and team interactions and deadlines.
  • Assists as a liaison between TPAs and wholesalers, as needed
  • Answers any questions TPAs may have regarding contract pharmacies
  • Reviews all new PSAs and amendments for accuracy and execution

8.Ability to coordinate or manage multiple projects across the Health System.
9. Adhere and assists with business operations and project specific quality documents (for example: SOPs, work plans/practices, training guides).
10. Excellent planning and problem-solving skills.
11. Excellent communication skills and ability to communicate effectively with all levels of the organization.
12. Proficiency with Excel, Word, PowerPoint and standard computer programs required.
13. A highly-motivated and meticulous individual with excellent problem-solving and communication skills to join a fast-paced, growth-oriented work environment in a cutting-edge field of business transformation.

Minimum Qualifications
1. Baccalaureate degree from an accredited college or university in Business Administration, Computer Science, Management or other related discipline from an accredited college or university; and six (6) years of satisfactory, full-time paid responsible experience in information processing, program management, systems development or related activity in a large governmental agency, hospital or health care facility, or hospital-related business firm, three (3) years of which must have been in a managerial capacity; or
2. Master's degree from an accredited college or university in disciplines, as listed in "1" above, and five (5) years of experience, as described in #2 above, one (1) year of which must have been in a managerial capacity; or
3. A satisfactory equivalent combination of education and experience.

Department Preferences

  • Knowledge of HRSA and Office of Pharmacy Affairs Guidelines
  • Accounting principles, cost analysis, budgeting, forecasting, market and supplier research and analysis
  • Experience working in a 340B program in a multi-hospital system
  • Proficiency in Microsoft Office, especially Excel and PowerPoint
  • ERP and current supply chain information systems
  • Experience with split billing software.
  • Knowledge in contracting, pharmaceutical purchasing, and inventory systems.
  • Skilled collaborator.
  • Experience working in a 340B program in a multi-hospital system.
  • Completion of Master's Degree in Business Administration or Master of Health Administration.
  • Lean Six Sigma experience.
  • ACE Certification
  • Minimum of four (4) years' management experience in 340B operations


If applying online, please include your cover letter in the same file attachment with your uploaded resume.

NYC Health and Hospitals offers a competitive benefits package that includes:
  • Comprehensive Health Benefits for employees hired to work 20+ hrs. per week
  • Retirement Savings and Pension Plans
  • Loan Forgiveness Programs for eligible employees
  • Paid Holidays and Vacation in accordance with employees' Collectively bargained contracts
  • College tuition discounts and professional development opportunities
  • Multiple employee discounts programs

Created: 2024-05-29
Reference: 101265
Country: United States
State: New York
City: New York
ZIP: 10036


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