NICKIE A. BRAXTON, MPH, CHC

* ******** ****, **********, ** 06525, 203-***-****

ac6fq1@r.postjobfree.com

PROFILE SUMMARY

More than 17 years’ experience in compliance and privacy leadership roles in a variety of settings including small and large acute care hospitals, academic medical centers, level I trauma centers, skilled nursing and home health in both union and non-union environments. Identified as a dynamic leader with expertise in compliance operations, fiscal management, quality improvement, leading and mentoring staff. Known as an effective communicator and change agent with the distinct ability to balance multiple demands and priorities. Recognized for team building and collaboration across disciplines and departments with strong analytic and organizational skills.

EDUCATION & PROFESSIONAL CERTIFICATIONS

Masters of Public Health, MPH, University of Massachusetts, Amherst, MA

BA, Psychology, Wesleyan University, Middletown, CT

Board Certified in Health Care Compliance (CHC), Health Care Compliance Association

Board Certified in Cyber Security Architecture (CCSA) ecfirst

PROFESSIONAL EXPERIENCE

COMPLIANCE STRATEGIES TODAY New Haven, CT

Present President 11/4/2017 - present

Compliance Strategies Today is a full service regulatory compliance-consulting firm, serving health care institutions nationwide. CST provides a wide array of regulatory services based on long-term in-depth experience in health care Compliance and Privacy. Services offered are both in support of Compliance and Privacy Officers and as fully outsourced Compliance and HIPAA solutions. Services include implementation of the Compliance and Privacy Programs to meet OIG and OCR requirements, ongoing consultation, and Compliance/Privacy-related training for personnel and the Board of Directors.

Beth Israel Deaconess Medical Center March 12, 2018 – present

Interim Director and Privacy Officer

Beth Israel Deaconess Medical Center (BIDMC), is a 673-bed academic medical center and teaching hospital of Harvard Medical School. BIDMC was formed through the 1996 merger of Beth Israel Hospital and New England Deaconess Hospital. Among independent teaching hospitals, BIDMC consistently ranks among the top three recipients of biomedical research funding from the National Institutes of Health. Member hospitals include Beth Israel Deaconess Hospital-Milton, Beth Israel Deaconess Hospital-Needham and Beth Israel Deaconess Hospital-Plymouth. The Harvard-Thorndike General Clinical Research Center, the oldest clinical research laboratory in the United States, has been located on this site since 1973.

Responsibilities include:

• HIPAA Privacy risk assessment;

• Response to Office of Civil Rights (OCR) investigations and queries;

• Updates to HIPAA Privacy and related documents;

• Development of the HIPAA annual work plan;

• Development of New Employee and New Resident required education;

• HIPAA-related guidance to executive, mid-level management and staff;

• Focused audits to verify compliance with state and federal Privacy laws;

Response to hotline reports;

• Investigation reports of noncompliance, and

• Development of the annual mandatory compliance education for all workforce members.

BOSTON MEDICAL CENTER, Boston, MA 6/2014 – 11/3/17

Privacy Officer

Reporting to the Chief Compliance Officer

Boston Medical Center (BMC) is a 482-bed academic medical center located in Boston’s South End. The hospital is closely aligned with Boston University School of Medicine as its primary teaching facility. BMC is known for its trauma and emergency services. The hospital is the largest safety-net hospital in New England and includes the Faculty Practice Foundation, a physician organization; BMC Healthnet, an Organized Health Care Arrangement (OHCA) of 15 community health centers, and an Accountable Care Organization (ACO), involving multiple independent health care facilities working closely together to efficiently provide an array of health services.

Responsible for implementation and development of the HIPAA Privacy Program for the hospital, Faculty Practice Foundation, Organized Health Care Arrangement of 15 community health centers and the Boston Accountable Care Organization.

Responsibilities include:

• Leadership and oversight of the HIPAA Privacy Program;

Regular reporting to the Audit and Compliance Committee of the Board;

Oversight of the day-to-day operation of the program;

Development of policies, procedures and related documents to comply with HIPAA, the Omnibus Rule and HITECH;

Implementation of annual and on-going risk assessments and risk mitigation programs;

Development of an annual work plan;

Assisting in Privacy review of new business initiatives;

Development and implementation of an annual HIPAA Education Plan, including job-specific training ;

• HIPAA-related guidance to executives, management and staff;

• Oversight of the Compliance Hotline for Privacy matters, and

• Evaluation, investigation and timely resolution of Privacy-related incidents.

Major Accomplishments:

Establishment of a robust auditing and monitoring program;

• Successful representation on behalf of BMC with the Department of Health and Human Services (HHS)/ Office of Civil Rights (OCR) and other state and federal regulatory oversight bodies regarding both Privacy and Security investigations and reporting requirements;

INDEPENDENT CONSULTANT Corporate Compliance and Privacy 4/2013 – 6/201

Providing Corporate Compliance & HIPAA Privacy consulting services

Consulting engagements include:

HARTFORD HOSPITAL/HARTFORD HEALTH CARE CORPORATION, Privacy Consulting, Hartford, CT

Interim System Privacy Officer

Responsibilities included:

• Organization-wide Compliance, HIPAA Privacy risk assessments;

• Representation on behalf of HHC to Office of Civil Rights (OCR) investigation;

• Development of HIPAA Privacy Program;

• Updates to HIPAA Privacy policies and documents in response to HITECH and the final HIPAA Omnibus Bill;

• Participation and advising on Health Information Exchanges (HIE);

• Development of Compliance and HIPAA education;

• Regulatory guidance to executives and management;

• Focused medical record access audits, and

• Investigation of hotline complaints.

UNIVERSITY OF MISSOURI HEALTH SYSTEM, Compliance and Privacy Consulting Columbia, MO

Interim System Privacy Officer

Responsibilities included:

• Organization-wide Compliance, HIPAA Privacy and Security risk assessments;

• Response to Office of Civil Rights (OCR) investigation;

• Preparation for OCR on-site visit;

• Development of HIPAA Privacy Program;

• Updates to HIPAA Privacy and Security policies and documents in response to the final

Omnibus Bill and HITECH;

• Advising on Health Information Exchanges (HIE);

• Development of Compliance and HIPAA education

• Regulatory guidance to executive management;

• Focused HIPAA Compliance audits;

• Investigation of Compliance and HIPAA complaints, and

• Compliance risk assessment.

NEW YORK-PRESBYTERIAN HOSPITAL New York, NY 7/2009 – 4/2013

Corporate Compliance Officer and Privacy Officer

Reporting to the VP, Audit and Compliance and to the Board of Trustees

NewYork-Presbyterian is a premier, 2,600 bed, multi-facility academic health care system with locations throughout the greater New York metropolitan area.

Responsibilities included:

• Creation and implementation of Compliance/HIPAA policies, in response to HITECH, HIPAA and the

HIPAA Omnibus Rule;

• Establishment of annual and on-going risk assessments;

• Development and management of department budget;

• Development of general and job-specific education for new and tenured employees;

• Oversight of Confidential Disclosure Program, including the Hospital’s hotline;

• Development, general oversight and daily operation of the Compliance and Privacy Programs;

• Timely investigation of compliance and HIPAA complaints;

Oversight of the external hotline service;

• Implementation of excluded parties reviews for all employees, vendors, contractors and physicians;

• General leadership and advisor to executive management and staff regarding Compliance and

HIPAA matters;

Regular reporting to the Audit and Compliance Committee of the Board of Trustees and to the Executive Compliance Committee of the hospital;

• Supervision of department staff, and

Budget development/management.

Major Accomplishments:

• Development of an on-line Conflict of Interest (COI) process for New York-Presbyterian, automating much of the administrative efforts of obtaining and sorting data fin preparation for executive leadership consideration, and

• Establishment of a robust risk assessment and mitigation program, responding to the OIG/OMIG work plans and other publicized data, working effectively with executives and key department directors.

HARTFORD HOSPITAL/HARTFORD HEALTH CARE CORPORATION, Hartford, CT 2006-2009

Hartford, CT

Hartford Healthcare is an integrated health care system that includes a tertiary-care teaching hospital, an acute-care community teaching hospital, an acute-care hospital and trauma center, two community hospitals, an extensive behavioral health network, a large multispecialty physician group, a regional home care system, an array of senior care services, a large physical therapy and rehabilitation network and an Accountable Care Organization.

Compliance Officer

Reporting to the President and CEO and to the Board of Trustees

Responsibilities included:

• Establishment and development of an effective Corporate Compliance Program for this multi-facility health care system;

• Creation of policies and procedures relative to compliance;

Oversight of Privacy Program and Privacy Officer;

• Annual and on-going assessment of potential compliance risks, including but not limited to the Office of Inspector General (OIG) and the Office of Medicaid Inspector General (OMIG) Work Plans and CMS notifications

• Development and oversight of risk mitigation plans;

• Implementation and oversight of auditing and monitoring of claims practices;

• Development, implementation & tracking of corporate compliance education for new & tenured employees;

• Establishment of a confidential disclosure program (hotline);

• Investigation of compliance complaints and concerns;

• Regular reporting to Board of Trustees and Senior Management regarding regulatory matters;

• Implementation of exclusion searches for all employees, vendors, contractors and physicians;

• Management of department staff and others involved in Compliance Department activities;

• Management, development and oversight of the Privacy Program.

Major Accomplishments:

• Creation and chairperson of an Executive Compliance Committee, comprised of VPs and other executive team members, to assist in the effective development of the Compliance Program;

Creation and chairperson of an Operational Compliance Committee comprised of department directors representing high-risk areas (i.e., coding, HIM, Patient Financial Services, etc.), which conducted risk assessments, implemented risk mitigations and assisted in developing a meaningful Compliance initiatives. The committee reported to the Executive Compliance Committee;

• Establishment of an effective annual compliance education for all board members, employees, vendors, contractors, physicians and volunteers;

• Development of a risk assessment process to evaluate organizational risk and implement mitigating controls where risk was determined. This process included interviews and focused audits.

MASONICARE, CORPORATE COMPLIANCE Wallingford, CT 1997- 2006

VP, Corporate Compliance and Legal Services / Compliance Officer

Reporting to the President and CEO and to the Board of Trustees

Masonicare is a continuum of care provider with focus on geriatrics, and offers assisted living, outpatient services, skilled nursing, behavioral health, home care, long term care, rehabilitation, hospice and palliative care services in multiple locations throughout the state of Connecticut.

Responsibilities included:

Implementation and direction of the Corporate Compliance and Legal Services Departments for the system, managed staff, set goals, strategies and time-lines, and interfaced with state regulatory agencies, board members, executive staff, managers and employees regarding current

• Establishment and development of a Corporate Compliance Program for the multi-facility corporation in response to the organization’s Corporate Integrity Agreement (CIA);

• Evaluation and development of policies and procedures relative to compliance;

• Implementation and oversight of the organization’s Risk Mitigation Program;

Implementation of auditing and monitoring procedures focused on billing, coding, documentation and known financial risks;

• Establishment of the organization’s hot line and Confidential Disclosure Program;

Investigation of compliance complaints;

• Implementation & monitoring Masonicare’s compliance with its Corporate Integrity Agreement (CIA);

• Communication with State agencies relative to Masonicare's CIA and other regulatory matters;

• Implementation of the Health Insurance Portability and Accountability Act (HIPAA) and on-going development;

• Consultative leadership to Masonicare’s affiliated entities relative to compliance matters.

Major Accomplishments:

• Creation of the health system’s Compliance Program, in accordance with the Office of Inspector General (OIG) requirements;

• Assistance and oversight of the organization’s Independent Review Organization (IRO), and

• Leadership for the organization’s successful response to its Corporate Integrity Agreement.

PUBLICATIONS/ARTICLES

Atlantic Information Services (AIS)- Vendor Relations in Health Care - publication, 2010, 2nd edition published 2012– discusses compliance-related risks in provider/vendor business and social relations

Report on Medicare Compliance - numerous articles and quote contributions 2008-present

Various healthcare-related publications articles and quote contributions Healthcare Audit Resource Center, AIS’ Health Business Daly, Association for Healthcare Resources & Materials Management, etc.

CONFERENCE PRESENTATIONS

26th National HIPAA Summit, Grand Hyatt, Washington, D.C. March 2017 – Presentation - Experience of a Boston hospital during response to the Boston Bombing; HIPAA and a Mass Casualty Event

American Conference Institute, Health Care Privacy and Security Forum, May 22-23, 2013, Carlton Hotel, NYC: Health Care Privacy and Security Risks/Benefit Assessment for the Use of Social Media, panel presentation

American Conference Institute, Health Care Privacy and Security Forum, December 6-7, 2012, The Union League, Philadelphia, PA: Health Care Privacy and Security Risks/Benefit Assessment for the Use of Social Media, panel presentation

Greater New York Hospital Association presentation, 2012, The Final Omnibus HIPAA Privacy Rule and Proposed Accounting of Disclosures Rule: Predictions, Analysis and Implementation

Greater New York Hospital Association presentation, September 21, 2011, Compliance Risk Assessment, Auditing and Monitoring

American Conference Institute, Health Care Privacy and Security Forum, December 5-6, 2011, The Union League, Philadelphia, PA: The Final Omnibus HIPAA Privacy Rule

And Proposed Accounting of Disclosures Rule: Predictions, Analysis and Implementation

Vendor Gifts and Relations: How To Revise Your Hospital’s Strategies As The Feds Crack Down, presentation and CD - 90-minute audio conference held on March 25, 2008. Donald E. Koenig, Jr., Vice President and Assistant General Counsel of Corporate Responsibility and Enterprise Risk Management for Catholic Healthcare Partners (CHP) in Cincinnati, and Nickie Braxton, Corporate Compliance Officer for Hartford Hospital/Hartford Health Care Corp. (Conn.)

World Research Group, Compliance Conference: Preventative Compliance for Medicare & Medicaid Audit Processes for Hospitals & Health Systems, Boston MA, July 14 & 15, 2008, Presentation: Implementing Effective Tools and Metrics for Integrating Compliance Into Your Organization

PROFESSIONAL AFFILIATIONS

ACHE

Health Care Compliance Association (HCCA)

American Healthcare Lawyers Association (AHLA)

Healthcare Financial Management Association (HFMA)

Connecticut Hospital Association (CHA)

Greater New York Hospital Association (GNYHA)

Contact this candidate