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Privacy Officer Compliance

Location:
Clearwater, FL
Posted:
April 03, 2024

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Resume:

Joseph R. McKee, RPh, JD

**** **** *** **, #***

Clearwater, FL. 33760

804-***-****

ad4rqp@r.postjobfree.com

EDUCATION

May 1987 JURIS DOCTOR (LAW DOCTORATE); Duquesne University,

Pittsburgh, Pennsylvania.

May 1977 BACHELOR OF SCIENCE (PHARMACY); West Virginia University,

Morgantown, West Virginia.

LICENSURE

Bar Admissions: Active- Virginia.

Inactive- Pennsylvania.

Pharmacist Licenses: Active-Virginia.

Inactive- Pennsylvania, West Virginia, South Carolina, Kentucky, Tennessee, Maryland, Ohio.

EMPLOYMENT

01/23-11/23 CRESTWOOD BEHAVIORAL HEALTH INC, Sacramento, CA

PRIVACY OFFICER, Clearwater, FL (Remote)

Responsibilities included reviewing and updating all Privacy policies and procedures from 2013;

privacy oversight, training and reporting for the 27 CBHI provider and business facilities; investigation and determination of potential and actual HIPAA Privacy incidents for all provider and business facilities; determination of client-reportable HIPAA Privacy Unauthorized Disclosures (UDs)/potential HIPAA Breaches; meet with impacted accounts at the request of CBHI account teams; review Business Associate Agreements (BAAs), documents for all RFP potential new accounts,plus all renewal contracts; advise on offshore data privacy policies; advise on questions and concerns regarding Privacy Statutes: HIPAA, HITECH, Omnibus Rule, 42 CFR Part 2 Federal Substance Abuse Treatment Regulations, FAR Privacy requirements for Federal Govt contracts, CCPA- & CPRA CA Privacy Acts, GDPR- European Privacy Law; complete Privacy Attestations for annual client FDR requirements; advise on information permitted to be left on voice mail systems; advise on use of secured email and other HIPAA-approved methods to share PHI with external entities; advise on when and how member PHI can be shared with third parties (AUDs, AORs, PAs); advise on the application of Good Faith Reliance and Minimum Necessary concepts as mitigation for unauthorized disclosures; advise on HIPAA Breach policies concerning Covered Entity & Provider unauthorized recipients; advise on application of Conflict of Interest Laws and Policies; oversight of contract-required MRx employee privacy attestations; oversight of Privacy and Security Corrective Action Plans; advise on Application and Interpretation of CMS Exclusion and Preclusion requirements for Medical UM contracts; support licensing for Corporate Compliance: PBM, UM, Dispensing Pharmacy licenses; support subpoena requests; support Client requests for claims records; support Member requests for Accounting of Disclosures; support Annual Disclosure of Ownership requirements for Medicaid clients.

06/05-12/22 MAGELLAN Rx MANAGEMENT, Scottsdale, AZ

PRIVACY OFFICER, (MRx) Glen Allen, VA, Tampa, FL, 08/18-12/22

As a result of continued company growth through acquisitions and new business lines &

accounts, Compliance Officer and Privacy Officer duties were split into two separate positions.

Responsibilities included privacy oversight, analysis, and reporting for all MRx business units:

Govt/Medicaid FFS, National PBM, Mid-Market Employer, Specialty Pharmacy Distribution &

Medical UM, Magellan Medicare D Health Plans and MRx Method; investigation and determination

of potential and actual HIPAA Privacy incidents for all MRx business segments; determination of client-reportable HIPAA Privacy Unauthorized Disclosures (UDs)/potential HIPAA Breaches; meet with impacted accounts at the request of MRx account teams; review BAA documents for all RFP potential new accounts plus all renewal contracts; advise on offshore data privacy policies; advise on questions and concerns regarding Privacy Statutes: HIPAA, HITECH, Omnibus Rule, 42 CFR Part 2 Federal Substance Abuse Treatment Regulations, FAR Privacy requirements for Federal Govt contracts, CCPA- CA Privacy Act, GDPR- European Privacy Law; completing Privacy Attestations for annual client FDR requirements; advise on information permitted to be left on voice mail systems; advise on use of secured email and other HIPAA-approved methods to share PHI with external entities; advise on when and how member PHI can be shared with third parties (AUDs, AORs, PAs); advise on the application of Good Faith Reliance and Minimum Necessary concepts as mitigation for unauthorized disclosures; advise on HIPAA Breach policies concerning Covered Entity & Providers as unauthorized recipients; advise on application of Conflict of Interest Laws and Policies; oversight of contract-required MRx employee privacy attestations in SABA, the company online training module; oversight of Privacy and Security Corrective Action Plans; Advise on Application and Interpretation of CMS Exclusion and Preclusion requirements for Medical UM contracts; support licensing for Corporate Compliance: PBM, UM, Dispensing Pharmacy licenses; support subpoena requests; support Client requests for claims records; support Member requests for Accounting of Disclosures; support Annual Disclosure of Ownership requirements for Medicaid clients.

COMPLIANCE & PRIVACY OFFICER (MRx), Glen Allen, Virginia 07/11-8/17

Responsibilities included oversight of the regulatory and contractual compliance and program integrity policies and procedures for the company; monitoring the timely completion of the company online privacy and security training programs; managing internal and external audits and preparing the company responses; assisting Account Management in the development of responsive corrective action plans (CAPs); after consultation with our legal counsel, responding to questions regarding the interpretation and/or analysis of statutes and regulations that impact our business; reviewing policies, documents, and correspondence with our customers, providers, and members for adherence with statutory/regulatory requirements; staying abreast of new and existing regulatory/legislative requirements to effectively assist our Account/Clinical Management and Operations Managers in their efforts to stay compliant with these requirements. Duties also included those of Privacy Officer, described above, concurrent with the Compliance Officer duties described here.

11/02-03/05 CVS CORPORATION, Woonsocket, RI

REGIONAL DIRECTOR, PHARMACY ACQUISITIONS, Richmond, Virginia

Responsibilities included visiting independent pharmacies, identifying pharmacy

acquisition opportunities, establishing relationships with independent pharmacy owners,

analyzing the financials and demographics of potential acquisitions for value, preparing and

delivering offers to the owners and preparing and presenting deal packages to corporate

for final approval. Geographic responsibilities included all independent community pharmacies in VA, WV, MD, PA, DE, TN and KY.

01/99- 11/02 ANCHOR PHARMACIES, INC., Hampstead, Maryland

DIRECTOR OF OPERATIONS

Worked with the CEO and COO of this start-up pharmacy chain to establish prospective pharmacy acquisition evaluation parameters, to define the operations management structure, and to develop and implement operational policies and procedures. Responsible for the day-to-day operations of the pharmacies, including all P/L statement-related activities. This company grew to 15 pharmacies in the first year of operations before losing funding from its financial backer, Cardinal Health, due to Cardinal corporate budget cuts.

03/96-12/98 HERITAGE INFORMATION SYSTEMS, INC., (acquired by ACS-Xerox), Richmond, Virginia

DIRECTOR, CLIENT AUDITING SERVICES, Richmond, VA

Reviewed and analyzed pharmacy claims submissions for abnormal dispensing and billing patterns compared to proprietary claim pattern metrics. Managed a team of auditors composed of clinical pharmacists and registered nurses to complete contracted onsite and desk review audits of retail pharmacies for private and publicly funded Pharmacy Benefits Management companies, including VA Medicaid, Trigon Blue Cross and Blue Shield in VA, Rx Solutions Mail Order Pharmacy in TX, Anthem BlueCross of Connecticut, Massachusetts Medicaid, and Ohio Blue Cross and Blue Shield.

08/77-02/96 RITE AID CORPORATION, Harrisburg, Pennsylvania

REGIONAL DIRECTOR, PHARMACY OPERATIONS, Rite Aid Corporation,

Harrisburg, Pennsylvania, 07/92-2/96

Responsibilities included overseeing and advising four Pharmacy Divisions, totaling

over 500 pharmacy locations, 1100 Registered Pharmacists, and 1800 Certified Pharmacy Technicians. Duties included setting Pharmacy Operations policies and procedures

for the pharmacies. Participated in the preparation and administration of bi-monthly

professional sales and training meetings directed at the Pharmacy Division Managers.

Traveled three to four days per week to the individual regions throughout the northeast, mid-west and mid-Atlantic regions to visit pharmacies with the respective Division Managers, in order to assess, evaluate, and report on pharmacy operations.

DIRECTOR, THIRD PARTY ADMINISTRATION, Rite Aid Corporation,

Harrisburg, Pennsylvania, 01/91-6/92

Responsibilities included serving as liaison between 144 pharmacy field operations executives

and corporate third-party operations personnel, tracking (with the goal of reducing) third

party receivables, reviewing third party contracts, and developing a more responsive

management structure within the Department. Participated in developing and implementing

policies and procedures designed to result in substantial reductions in the number of

outstanding third-party rejects at the retail pharmacy level and in significant increases in

collection rates at the corporate level.

REFERENCES

Available upon request.



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