Position Summary:

The Compliance Manager is responsible for building, executing, and continuously improving Dozee's
healthcare compliance program across all regulatory domains - Medicare RPM billing, HIPAA privacy and
security, FDA device compliance, and Anti-Kickback Statute adherence. The role reports to the VP
Administration and is the organization's primary day-to-day compliance operator, translating policy into
procedure and ensuring every business function performs within established legal and regulatory boundaries.

Responsibilities

1. CMS / Medicare RPM Billing Compliance
• Own the monthly billing compliance review cycle - validate CPT code selection ([redacted]0), data-day
thresholds, and mutual exclusivity rules before claims are released.
• Monitor CMS Final Rules, MAC Local Coverage Determinations (LCDs), and OIG Work Plan items
affecting RPM billing; brief leadership on material changes within 30 days.
• Maintain the pre-bill dual-attestation workflow and enforce the 99458 MUE cap and time-counting rules.

2. HIPAA Privacy & Security Program
• Serve as Dozee's designated HIPAA Compliance Officer - conduct annual Security Risk Assessments,
manage the Notice of Privacy Practices, and oversee BAA lifecycle for all vendors and SNF partners.
• Lead breach investigation and notification workflows; coordinate with Melvin Law Group on any reportable
incident.

3. SOP Development & Version Control
• Own and maintain the full CAIT/Dozee SOP library (currently seven SOPs, v2.1) - initiate updates within
30 days of any material regulatory change.
• Manage the annual SOP review cycle; obtain CEO and VP sign-off; track version history and change logs.

4 .Internal Audit - Monthly Claims Sampling
• Conduct monthly random-sample claims audits (minimum 10% of submitted claims) - verify
documentation completeness, code accuracy, and consent/care-plan compliance.
• Track audit findings in the Compliance Tracking Log; escalate repeat findings to VP Administration;
implement and verify corrective actions within agreed timelines.

5. Staff Training & Annual Attestation
• Design, deliver, and track annual compliance training for all clinical, billing, and administrative staff -
covering CMS billing rules, HIPAA, AKS, and the OIG RPM Compliance Framework.
• Maintain training attestation records in Circle Health Domain 0.2; generate compliance attestation reports
for VP and CEO annually.

6. Overpayment Management - 60-Day Rule Enforcement
• Maintain the Overpayment Tracking Log; ensure all identified overpayments are investigated, classified
(isolated vs. systemic), and refunded within the 60-day statutory deadline.
• Coordinate with the Billing Manager on MAC refund submissions; consult Melvin Law Group on any
systemic overpayment before refund.

7. Regulatory Intelligence & State Monitoring
• Monitor applicable state NP practice act changes across CAIT's six operating states (TX, OH, PA, FL, NY,
MO) and Dozee's expansion targets.
• Track RHTP, THRIVE, and NIH grant compliance obligations as Dozee enters new government programs.

8. Contract & AKS Compliance Support
• Review all SNF partner and vendor agreements against the Anti-Kickback Statute checklist before
execution; escalate any FMV or referral-contingency concerns to VP Administration and Melvin Law
Group.
• Maintain executed contract files and the annual contract review schedule.

Requirements

Experience : Minimum 5 years in healthcare compliance - Medicare billing, HIPAA, or post-acute / RPM environment strongly preferred.

Certifications: Certified in Healthcare Compliance (CHC) required or obtainable within 12 months of hire. CHPC (privacy) a plus.

Technical : Working knowledge of CPT coding ([redacted]0), CMS PFS Final Rules, OIG Work Plan, MAC audit processes, and AKS/Stark safe harbors.

Skills : Strong SOP writing, audit documentation, and cross-functional communication skills. Ability to deliver training to clinical and non-clinical staff.

Systems : Familiarity with healthcare compliance platforms (preferred); proficiency in Microsoft 365 required.

Education : Bachelor's degree required; healthcare administration, law, or clinical field preferred.