Deputy Director of Marketplace Compliance & Program Integrity

Position Overview

The Deputy Director of Marketplace Compliance & Program Integrity leads the overall Compliance program for Get Covered Illinois (GCI). GCI is seeking a creative and engaged attorney with expertise in compliance programs to develop and implement GCI’s privacy, data security and appeals resolution functions. The Deputy Director of Marketplace Compliance & Program Integrity will play a vital role in ensuring Illinois’s health marketplace complies with all federal and state laws and regulations, Illinoisians’ personal information is handled appropriately and securely, and applicants and enrollees of the marketplace are able to take advantage of all state and federal laws and regulations concerning appeals rights. This is an exciting opportunity for a mission-focused creative individual to design brand new programing for a highly visible and impactful initiative that aims to expand access to healthcare in Illinois.  We invite all qualified candidates to apply.

Get Covered Illinois is the State of Illinois’s new Health Insurance Marketplace. Get Covered Illinois’s mission is to increase access, enrollment, affordability, and choice for individuals and families by connecting them to health insurance plans and savings available through the Affordable Care Act. Get Covered Illinois provides pathways to coverage through a consumer-centric online application platform, a Customer Assistance Center, localized outreach and education strategies and a network of in-person assisters embedded in communities across the state that help Illinoisans enroll in the coverage that best meets their families’ needs. Get Covered Illinois is part of the Illinois Department of Insurance and has offices in Chicago and Springfield.

Essential Functions

1. Manages and leads design, implementation, maintenance, and improvement of the Get Covered Illinois (GCI) Compliance Program: 
    •Manages design implementation and maintenance of an annual compliance strategic plan and an executive compliance communication plan by which the GCI executive staff can communicate the importance of compliance.
    •Manages design implementation and maintenance of an agency wide annual risk assessment process.
    •Establishes and operates an anonymous tip line with appropriate procedures for processing any complaints received and the design and implementation of an internal compliance communication plan.
    •Oversees the annual update of the GCI compliance program document and the design implementation and maintenance of a work group dashboard.
    •Develops and implements an agency wide code of conduct administrative policy process and related training.
    •Designs, implements, and maintains a compliance training program that includes various delivery methods electronic, in person and paper delivery.
    •Monitors the design implementation and maintenance of a third-party monitoring program.
    •Leads the design implementation and maintenance of an internal audit program and processes for coordinating external audits. 
    •Updates policies and procedures to reflect disciplinary standards.

Essential Functions Cont'd

2. Leads GCI’s data practices, data privacy, and data security programs in compliance with federal and state laws:
    •Oversees the development and maintenance of GCI’s privacy and security policies, standards, and procedures in coordination with GCI staff and other state agency staff, including coordinating with the Department of Innovation and Technology (DoIT) and IT vendors to ensure that any privacy and security policies, standards, and procedures support and are promulgated in compliance with all applicable federal and state laws, information security policies, procedures, and standards. 
    •Works closely with Internal Revenue Service (IRS), Department of Central Management Services (CMS), DoIT and IT vendors to implement, maintain and renew GCI’s Authority to Connect agreements granting GCI the authority to integrate marketplace systems with the federal data services hub.
    •Ensures that GCI privacy and security policies support compliance with external requirements, including all applicable federal and state laws, information security policies, procedures, and standards.
    •Oversees the dissemination of policies, standards, and procedures to GCI management, employees, consultants, vendors, or other authorized users. 
    •Sets the direction and provides the vision for the privacy and security compliance program, including planning, implementing, and directing ongoing privacy and data security risk activities, as appropriate under all applicable federal and state laws, information security policies, procedures, and standards.
    •Reports on the status of the privacy and data security program, as appropriate under all applicable federal and state laws, information security policies, procedures, and standards.
    •Oversees, delivers, or ensures delivery of any privacy and security training for all employees, contractors, and other required individuals, as appropriate under all applicable federal and state laws, information security policies, procedures, and standards or as required by GCI policy. 
    •Manages a system to report and respond to GCI data security incidents (breaches), alleged policy violations, or complaints from external parties, as appropriate under all applicable federal and state laws, information security policies, procedures, and standards.
    •Keeps abreast of latest security and privacy legislation, regulations, advisories, guidance, and alerts and vulnerabilities pertaining to GCI and its mission.
    •Oversees the development, implementation, and maintenance of a system for receiving and responding to requests for access to GCI data and for receiving and responding to questions or concerns regarding problems in obtaining access to data or other data practices problems.
    •Oversees the maintenance and improvement of policies regarding public access to GCI data, data subjects’ rights and access to data, and the creation and maintenance o

Essential Functions Cont'd

3. Designs, implements, and oversees GCI’s appeals program and processes and related Resolution Review processes:
    •Oversees the development and updating of procedures and implements changes in procedures to improve operations; leads the development and implementation of public facing messaging related to GCI appeals, website content, eligibility notices, and media stories.
    •Develops, promulgates, implements, and amends as necessary, state statutes and regulations governing appeals, and drafts statutorily required legislative reports on appeals when applicable.
    •Develops, promulgates, implements, and amends as necessary, the administrative rules governing GCI appeals; identifies, collects, and utilizes metrics related to GCI appeals to continuously improve Marketplace appeals processes. 
    •Coordinates appeal activities with the Departments of Healthcare and Family Services and Human Services, and the Centers for Medicare and Medicaid Services (CMS); oversees coordination with CMS to facilitate second tier appeals of GCI appeal decisions.
    •Responds to requests from the public and constituency groups for copies of decisions in particular programs/subjects. 
    •Collaborates with state and federal networks of colleagues to constantly improve GCI appeal operations.
    •Leads overall development and implementation of business processes related to GCI appeals representation.
    •Represents GCI in second tier appeals of GCI appeal decisions. 
    •Leads the strategic and creative planning of GCI’s appeals representation to plan and organize resources under dynamic operations to achieve full efficiency.
    •Analyzes the efficiency and effectiveness of the GCI Appeals business processes and recommends, develops, and implements changes as needed. 
    •Identifies, collects, and utilizes metrics related to GCI’s representation in appeals to continuously improve Appeals representation processes.
    •Analyzes the merits of appeal cases, offers settlement agreements, negotiates, and/or mediates where appropriate, consulting with the Marketplace Director, DOI legal and/or senior management at GCI and DOI, when appropriate.
    •Prepares reports, including reports on the frequency of a given appeal issue and reports on the frequency of a given type of appeal.
4. Serves on various working groups and provides expertise of the appeals process within GCI:
    •Serves as GCI’s Rulemaking Coordinator and collaborates with the Department of Insurance’s (DOI) legal team on rulemaking activities.
    •Serves as lead representative on all related workgroups or committees related to Marketplace appeals.
    •Serves as lead representative and facilitates discussion on common issues within national collaborations related to appeals. 
    •Convenes workgroups or other outreach with internal and external stakeholders to develop effective processes.
    •Provides subject matter expertise to support the development and continuous improvement of appeals functionality within GCI systems.

Essential Functions Cont'd

5. Serves as full line supervisor:  
    •Assigns and reviews work.
    •Provides guidance and training to assigned staff.
    •Counsels staff regarding work performance.
    •Reassigns staff to meet day-to-day operating needs.
    •Establishes annual goals and objectives.
    •Approves time off.
    •Adjusts first level grievances. 
    •Effectively recommends and imposes discipline, up to and including discharge. 
    •Prepares and signs performance evaluations; determines and recommends staffing needs.
6. Develops and maintains relationships with GCI leadership and other staff to facilitate the execution of GCI compliance and the cultivation of a culture of compliance at GCI: 
    •Meets with GCI leadership and any other appropriate stakeholders to gather ideas, suggestions, and requests for audits.
    •Leverages the risk assessment and other processes to facilitate interactions with GCI leaders and identify areas of concern.
7. Performs other duties as required or assigned which are reasonably within the scope of the duties enumerated above.

Minimum Qualifications

1. Requires graduation from a recognized law school and possession of a license to practice law in Illinois.
2. Requires four (4) years of progressively responsible administrative experience in the practice of law with an extensive knowledge of the legislative and rulemaking process.
 

Preferred Qualifications

1. Prefers at least four (4) years of experience with Affordable Care Act (ACA) and/or Medicaid laws and regulations. 
2. Prefers at least four (4) years of experience with insurance laws. 
3. Prefers at least four (4) years of experience with judicial and quasi-judicial procedures at all levels. 
4. Prefers at least four (4) years of experience with common law, Federal and State laws, and regulations. 
5. Prefers at least four (4) years of experience with management and procedural problems.
6. Prefers at least four (4) years of experience applying legal methods, practices, and procedures to the overall operations of a large department. 
7. Prefers at least four (4) years of experience developing and maintaining effective public contacts and satisfactory working relationships with all levels of State, Federal and local government. 

Employment Conditions

1. Requires the ability to pass a background check.
2. Requires ability to travel in the performance of duties, with overnight stays as appropriate.
3. The conditions of employment listed here are incorporated and related to any of the job duties as listed in the job description.
 

About the Agency

The Department of Insurance (DOI) regulates the insurance market in the State of Illinois including, but not limited to, licensing and educating insurance agents, investigating Workers Compensation fraud, and examining the operations and finances of insurance companies domiciled in the state. We are committed to protecting consumers and regulating the insurance industry with innovation and efficiency. DOI has approximately 220 employees who are split between our Chicago and Springfield offices.

State of Illinois employees enjoy a robust benefit package, including:

• Health, Life, Vision, and Dental Insurance
• 13 Paid Holidays annually, 14 on even numbered years
• 10-25 days of Paid Vacation time annually - (10 days in year one of employment)
• 12 Paid Sick Days annually (sick days carry over from year to year)
• 12 Weeks Paid Maternity/Paternity Leave
• 3 Paid Personal Days annually
• Pension Plan
• Deferred Compensation Program and other pre-tax benefit programs (Medical/Daycare)
• Flexible work schedules may be available, dependent upon position
• Tuition Reimbursement Program and Federal Public Service Loan Forgiveness Program eligibility

Visit https://www2.illinois.gov/cms/benefits/Pages/default.aspx for more information about our benefits.