COMPLIANCE MANAGER for
Sierra Health Services / Health Plan of Nevada

Sierra Health Services is the parent company to a life, health insurance, WC and HMO conglomerate on the NYX. Its principle insureds are casino employees, Medicare recipients and armed forces dependents. The position was established in the Legal Department in response to a Quality Control analysis and reported to Mr. Frank Collins, General Counsel. The acquisition of California Commercial Indemnity placed an extreme financial strain on the company's resources resulting in a hiring freeze, terminations, and salary and title reductions. Many employees, including myself, relocated with a new competitor, Med One Health Plan.

• Developed compliance bulletin system to alert and advise staff regarding state law changes.
• Colorado Market Conduct Survey analysis; drafted policy revisions to bring company into compliance.
• Developed and filed Service Area revision for Health Plan of Nevada (HMO).
• Advise/consult with staff and management regarding legal standards and state and federal regulatory compliance.
• Analyized and advised regarding interdepartmental relationships causing delay in production of marketing material.
• Compiled and drafted guide to advertising and disclosure laws to five states for the Marketing Department.
• Analyized interdepartmental work flow problems and proposed solution - flow chart.

This memo is directed to management as a proposed corrective response to the memoranda of the CTF and QC committees.

Management accepted two of the committee recommendations by adding staff to initiate response to the problems and workload.

Listed below are the issues identified by the two committees, followed by my proposed solutions:

1. Need for a receiving, disseminating and filing procedure for technical and regulatory information.
2. Lack of timely and accurate communications of local and regional law, and regulatory changes, their implementation and follow-up. Committees expressed a need for 'proactive' compliance measures.
3. Lack of accessibility to authoritative resource materials, interpretation and guidance by knowledgeable counsel.
4. No centralized authority available to all departments and regions for comprehensive guidance.
5. Need for quality or image control of public communications.
6. Lack of knowledgeable insurance writers capable of developing marketing literature and company documents that are accurate, in compliance with the law, user friendly and understandable by the public.
7. Duplication of creative efforts for what should be uniform or 'stock' marketing text and letter documents (claim, enrollment, member services and u/w letters).
8. Document drafting, correcting and approval process is circular and terminable only based on a due date, reflecting an ineffective procedure.
9. Large volume of untracked documents, unable to locate or relocate stock text, form letters and brochures or manage inventory.
10. Need for documented compliance policies and procedures or guidelines.

PROPOSED SOLUTIONS

1. Establish receiving point and log-in procedure, develop, manage and distribute information from a library of technical and regulatory resources (separate analysis drafted).*
2. Review, identify and select pertinent information from the above material. Coordinate the timely drafting of and write for a period Compliance Bulletin. This tools will enable us to systematically advice the Departments regarding law changes, summarize rules, give hypothetical examples of when the new rule will apply, draft department instructions with the V-P of Operations. This bulletin will also allow us to analyze the impact on the Company, and alert management to track forms for future analysis. See attached medical bulletin.
3. Draft and file new policy forms, amendment and endorsements as needed:
4. Rewrite certain group health policy forms and certificates to a simplified language and style with Flesch score readability requirements - possibly a shell format.
5. Develop and maintain a lexicon of stock industry and company language, specific to each state, company and product type. Train and oversee writers and editorial staff regarding regional advertising law and idiomatic aspects of insurance writing and readability; Flesch score requirements and objective computerized analysis.*
6. Review and check all public communications including PR and controlled documents for compliance with state and federal laws, and regulations, Company and product image, proper English, insurance style and good forms.
7. Systemize and document the routing procedure for the creation and approval of new marketing literature prior to its release.
8. Develop and systematize and oversee policy form numbering system*, catalogue (index) and files, e.g., Microsoft based security coded 'Access' computerized data base system for tracking forms (by number, IDs, use, owner, DOI filing status - submission and filed date, last date determined to be a legal compliance, application, comments, location and quantity); Interface with document control system of Records Management.
9. Conduct an audit and periodically identify obsolete forms and order their withdrawal from circulation and inventory.
10. Reply in writing to inquiries from senior staff regarding current law and regulation.
11. Counsel staff, brokers and agents assist in the identification of problems and provide legal support for development of a solution.
12. Communicate and respond to regulators and outside counsel to limit compliance communications.
13. Develop computerized 'Acrobat' hypertext based Group Operations Information Manual -- compilation of general instruction and single case opinions (ID removed) rendered by Compliance, Claims and Operations, and to document policy decisions (Acrobat is already on the system wide computer).
14. Act as a facility and liaison to new product development committee.
15. Oversee and edit Sales and Underwriting ad hoc issuance of variations to existing plan designs and amendments to group enrollment agreement, this in order to limit the number of legacy plans.
16. Review and research unusual claims to render coverage opinion relative to contract and laws.
17. Develop and implement compliance policy procedures - flow chart and restrictions.
18. Maintain a proactive stance by attending and reporting on the proceedings of Compliance conferences and seminars. Develop and expand industry contacts for the professional development of the staff.

* We have received specific requests for particular tools and guidance from departments.

• Wayne Finch, head underwriter has asked for a Compliance Bulletin.
• Underwrting asked for more guidance regarding issuance of schedules and their up-dates for mandated benefits.
• Terresa Keane-North in Policy Issue Dept. asked for a computerized form number catalogue.
• Mark Holland of Marketing has asked for an Advertising Rule Book and an "X'Y" extra-territorial chart.

writing sample

< < Prior Job		Next Job > >		Index to Writing Samples		RESUME		E-mail Dean now

---

[/sierra.html]5/7/99