Summary
Overview
Work History
Education
Skills
Websites
Affiliations
Timeline
Awards & Recognition
Speaking Engagements
Generic

Keith Carrington

Summary

Dynamic and results-oriented senior compliance executive with extensive experience in healthcare compliance, privacy, and regulatory affairs. Dedicated to supporting physicians, clinical laboratories, medical centers, and government payors. Proven expertise in developing, implementing, and overseeing comprehensive compliance programs that protect healthcare providers and patients, minimize risk, and enhance patient services. Strong track record in regulatory adherence and risk management underscores a commitment to organizational integrity through effective policy development and internal audits. Recognized for fostering collaboration within teams and delivering exceptional results in fast-paced, high-stakes environments.

Overview

11
11
years of professional experience

Work History

Chief Compliance & Privacy Officer

Baptist Health Care, Inc.
06.2023 - Current
  • Hospital Move Support – Provided privacy and compliance/regulatory guidance to departments and clinics relevant to the September 2023 main hospital campus relocation and post move audits for records retention and medication transfers.
  • Compliance Training Refresh – Redesigned and authored the current Integrity & Ethics training module for new hire orientation.
  • Quality Assurance – Developed and implemented the organization’s first quality assurance program for internal compliance audits.
  • Audit Program Optimization – Restructured the compliance audit program and established audit protocols for ambulatory services. Expanded the compliance audit program to offer system wide audit support for inpatient and outpatient services.
  • Program & Departmental Restructuring – Conducted an internal assessment of the compliance program and department resulting in the design and implementation of a complete restructuring of the compliance department and program optimization plan that allows for expanded support for the health system operations and strategic initiatives through audit, monitoring, education, and increased efficiencies in core compliance operations including investigations and sanctions screenings.
  • Led compliance initiatives to align organizational practices with regulatory requirements.
  • Developed and implemented risk assessment frameworks to identify compliance vulnerabilities.
  • Analyzed regulatory changes to update organizational policies and ensure ongoing compliance.
  • Engaged with external regulators during audits, fostering positive relationships and transparency.
  • Enhanced regulatory compliance by developing and implementing comprehensive policies and procedures.
  • Mentored junior staff members by offering insights into complex compliance-related problems while promoting professional development opportunities.
  • Provided expert guidance on complex compliance issues, enabling informed decision-making at the executive level.
  • Conducted performance reviews against key metrics to evaluate the effectiveness of compliance program and identify any areas requiring attention.
  • Managed a high-performing team of compliance professionals, setting clear expectations and providing ongoing support for career growth.
  • Reduced potential legal exposure by conducting thorough investigations into alleged misconduct and recommending appropriate corrective actions.
  • Advised senior leadership on strategic initiatives from a compliance perspective, ensuring alignment with organizational values and objectives.
  • Actively participated in industry committees or associations for better understanding of trends affecting peers in similar roles.
  • Implemented robust monitoring systems to identify areas of concern and ensure timely resolution of identified issues.
  • Ensured timely completion of all regulatory filings, maintaining a strong reputation with governing bodies.
  • Implemented a culture of continuous improvement within the compliance department by regularly reviewing processes, policies, and systems for potential enhancements.
  • Collaborated with legal counsel on matters related to enforcement actions, litigation, or settlement negotiations, protecting company interests.
  • Improved cross-functional collaboration with key stakeholders, fostering a culture of compliance throughout the organization.
  • Evaluated emerging risks in the industry to proactively address potential challenges and maintain business continuity.
  • Leveraged data analytics tools for improved trend identification and risk assessment capabilities within the compliance program.
  • Established effective communication channels between functional departments to facilitate information sharing related to regulatory requirements and best practices.

Vice President, Chief Compliance & Privacy Officer

Get Heal, Inc. | Heal Doctors, P.C.
07.2022 - 05.2023
  • Billing & Coding Compliance – Resolved multiple, multi-year billing and coding investigations resulting in the successful partnership with multiple Medicare Administrative Contractors (MACs) and Medicare Advantage payors to return extrapolated overpayments and successfully mitigate compliance risks related to prior computer assisted coding (CAC) and insurance eligibility and verification deficiencies, thus avoiding administrative and regulatory sanctions.
  • RCM/PCM Turnaround – Audited the organization’s third-party RCM/PCM provider resulting in the issuance of a formal Corrective Action Plan and eventual restructuring of the third-party engagement to resolve claims integrity deficiencies with vendor processes leading to improved claims acceptance and payment for the organization.
  • Enterprise Risk Management – Developed and executed the first of its kind Enterprise Risk Assessment for the organization linking compliance, cybersecurity, data privacy, and business risks into a holistic assessment.
  • DEA Licensing Compliance – Worked closely with the DEA to ensure the development and implementation of opioid prescribing protocols and provider oversight to support the licensing of Primary Care providers in eight states for Heal’s in-home care delivery model and overcoming a New York State barrier to licensing.
  • Medicaid Program Compliance – Conducted a Gap Analysis and implemented corrective measures including new policies, procedures, and processes to ensure alignment and compliance with multiple state Medicaid programs.
  • Company Wind Down and Transition – Led the regulatory, records custodian management, insurance, and contract/lease termination responsibilities for the company winddown and transfer of assets to purchasers.

Chief Compliance & Privacy Officer

North American Dental Group
01.2021 - 07.2022
  • Compliance & Privacy Program – Developed and implemented compliance and privacy program and department structure to support a leading Dental Service Organization with 250+ practices in 15 states.
  • Clinical Compliance Turnaround – Redeveloped and implemented clinical compliance programs for the organization’s Infection Prevention and Control and Radiation Safety and Quality programs to align with state and federal requirements, avoiding state sanctions and monitoring agreements.
  • Privacy and Cybersecurity Turnaround – Developed and implemented privacy and cybersecurity/information security controls and policies to effectively respond to reported ransomware and credential harvesting breaches successfully resolving OCR and multiple state AG investigations.
  • Code of Conduct and Ethics – Authored and implemented the organization’s Code of Conduct and Ethics following board approval.
  • Risk Management / Insurance Management – Led the review and transition of the organization’s professional liability and cyber insurance coverages to include the development of a formal risk management program with staff dedicated to risk assessment and mitigation, adverse event reporting, and claims management.
  • Due Diligence – Restructured the organization’s clinical and corporate compliance, privacy, licensure, and risk management due diligence process and audit protocols for M&A transactions.

Interim Chief Compliance & Privacy Officer

Convey Health Solutions, Inc.
05.2019 - 01.2021
  • Due Diligence – Directed the compliance and regulatory due diligence for the private equity-backed sale of the enterprise for $325M. Reorganize the compliance, privacy and regulatory affairs department to support all healthcare organizations.
  • Compliance & Privacy Program – Restructured the Compliance Department to successfully implement an enterprise compliance program and model integrating three acquired companies.
  • Audit Protocols – Designed and delivered audit protocols to ensure audit readiness for internal, client and regulatory audits. Led a comprehensive FMV analysis and reevaluation of all products and services offered by Convey in accordance with federal guidelines. Designed and implemented an enterprise-wide Conflict of Interest Disclosure and Screening Program compliance with federal state guidelines and facilitated training for all employees.
  • Conflict of Interest Screening – Developed and delivered a comprehensive Conflict of Interest / Related Party Transactions Screening and Audit Program in accordance with federal laws and guidance.
  • Code of Ethical Business Conduct – Completely revamped the enterprise Code of Ethical Business Conduct and created 37 new policies and procedures for the expanded enterprise compliance with federal and international laws, including the Foreign Corrupt Practices Act because the enterprise acquired international holding

Independent Consultant
09.2018 - 09.2019
  • Client – Convey Health Solutions, Inc., Fort Lauderdale, FL
  • Regulatory Audit – Directed the regulatory audit for an MA-PD sponsor undergoing a Financial One Third audit and a program audit by CMS. Led all internal audit responses, communications and documentations, and submissions to the contracted auditors. Developed and submitted remediation plans, regulatory appeals, and challenges to audit findings and proposed sanctions. Successfully avoided $750,000 in civil penalties for a MAPD plan using effective remediation and management of the CMS program audit.
  • Compliance & Privacy Program – Developed and delivered a compliance and privacy program for a direct primary care organization following its divestiture from its publicly traded parent company. Defined a strategic plan for the compliance and privacy departments in adherence with HHS OIG and OCR guidance to support 57 clinics in 13 states.
  • Risk Mitigation – Developed policies, procedures and controls to ensure compliance while mitigating risk with federal and state privacy laws, state CPOM regulations, and delivery of care to unaccompanied minors.
  • Compensation Audit – Led audit of physician compensation for 137 physicians to ensure Stark and FMV compliance with all compensation components. Designed and annual review process for all physician contracts that was implemented into a large multi-state direct primary care organization with clinics in 13 states.

Director, Corporate Compliance

DaVita Inc.
04.2015 - 09.2018
  • Compliance Programs – Managed compliance programs in the clinical laboratory and primary care divisions. Developed and introduced first-of-its-kind medical necessity audit program for laboratory orders, training for medical providers on appropriate documentation standards for laboratory services while coordinating all OIG and MAC audits.
  • Compliance Program Audit – Designed and introduced an annual assessment of the compliance program efficacy for clinical laboratory and direct primary care divisions to ensure alignment with DOJ guidance and federal sentencing guidelines for effective compliance program measures.
  • Refund Analysis – Succeeded in extrapolated refund analysis that resulted in a multi-million refund to close an OIG audit.
  • Annual Risk Assessments – Led the clinical laboratory and direct primary care divisions’ annual risk assessments.
  • Revenue Management Audits – Led revenue management audits, monitored functions to address coding and billing compliance for laboratory services subject to the End Stage Renal Disease (ESRD) Prospective Payment System rules.
  • Audit Protocols – Designed and implemented medical necessity, coding and billing audit protocols for laboratory services billing for government and non-government payors for the clinical laboratory.
  • FMV Analysis – Facilitated in-house FMV analysis and led the external annual FMV certifications for all laboratory, physician compensation, and clinical services for assigned divisions.
  • Stark & AKS Analysis – Conducted Stark and AKS analysis for all strategic initiatives, new and renewing laboratory service agreements and all direct primary care and physician contracts prior to submission to the OIG Monitor.
  • Annual Review – Led annual review of all BAAs and contracts for HIPAA, Stark and AKS compliance for the clinical laboratory and primary care divisions. Partnered with Legal team to identify any compliance issues and develop corrective action plans to eliminate similar incidents.
  • Other: Scherr McClure, P.A. | CTC Health Services | eTrading Services | AmTrust Bank | Scala Business Solutions | Bertelsmann

Education

Executive Juris Doctor - Health Law

Concord Law School at Purdue University Global

Master of Business Administration - Marketing

DeVry University

Bachelor of Arts - Government, Minor in International Affairs

New Mexico University

Skills

  • HIPAA & State Privacy Laws
  • Enterprise Risk Management
  • Fair Market Value Analysis (FMV)
  • OIG/ CMS Compliance
  • Self-Disclosure Protocol
  • Private Equity
  • Government Payor Audits
  • Medicare & Medicaid Programs
  • Medical Necessity Audits
  • Compliance Program Design
  • Referral Source Agreements
  • Stark Law/Anti-Kickback (AKS)
  • Regulatory Surveillance
  • Training / Instructional Design
  • Extrapolated Refunds
  • Regulatory Audits
  • Complex Privacy Law Analysis
  • IRO Readiness
  • Government Investigations
  • Physician Arrangements
  • M&A Due Diligence
  • Regulatory expertise
  • Audit coordination
  • Compliance monitoring
  • Data privacy
  • Corporate governance
  • Internal audits
  • Internal controls
  • Investigations skills
  • Documentation review
  • Training delivery
  • Policy analysis
  • Risk management
  • Federal and state regulations
  • Compliance reviews
  • Regulations enforcement
  • Risk management strategies
  • Policy design
  • Compliance procedures
  • Teamwork and collaboration
  • Problem-solving
  • Leadership and people development
  • Relationship building
  • Strategic planning and execution
  • Executive leadership
  • Complex Problem-solving
  • Public speaking

Websites

Affiliations

  • American Health Law Association
  • Health Care Compliance Association
  • American Public Health Association
  • American College of Healthcare Executives
  • American College of Healthcare Trustees
  • AAPC
  • Society for Corporate Compliance and Ethics

Timeline

Chief Compliance & Privacy Officer

Baptist Health Care, Inc.
06.2023 - Current

Vice President, Chief Compliance & Privacy Officer

Get Heal, Inc. | Heal Doctors, P.C.
07.2022 - 05.2023

Chief Compliance & Privacy Officer

North American Dental Group
01.2021 - 07.2022

Interim Chief Compliance & Privacy Officer

Convey Health Solutions, Inc.
05.2019 - 01.2021

Independent Consultant
09.2018 - 09.2019

Director, Corporate Compliance

DaVita Inc.
04.2015 - 09.2018

Master of Business Administration - Marketing

DeVry University

Bachelor of Arts - Government, Minor in International Affairs

New Mexico University

Executive Juris Doctor - Health Law

Concord Law School at Purdue University Global

Awards & Recognition

DaVita Core Value Award for Service Excellence – 2017, Legal Writing Award – Concord Law School, 2014

Speaking Engagements

  • Privacy Program Management Strategies & Challenges – IAPP, December 2022
  • Risk 2.0: The Digital Transformation of Corporate Compliance – Bloomberg Law, April 2018
  • Compliance & Enforcement Issues for Clinical Laboratories – American Clinical Laboratory Association, March 2018

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Keith Carrington