The U.S. Ethics & Compliance Officer, Aesthetics and Dermatology will serve as the compliance business partner for two Bausch Health business units in the United States: Solta Medical and Ortho Dermatologics.  This person will work under the direction of the Chief Compliance Officer to design and implement an effective healthcare compliance program for both organizations, ensuring they operate in a manner consistent with relevant US laws, regulations, and industry codes.

As the primary compliance professional supporting Bausch Health’s medical device business in the US, he/she will be responsible for developing and maintaining policies, procedures and training that are consistent with the AdvaMed Code of Ethics.  He/she will also work closely with the US Region Compliance Officer to implement a compliance program for Ortho Dermatologics that is consistent with the company’s other US pharmaceutical business units.  He/she will be accountable for routine monitoring, risk assessment, and assigned misconduct investigations relevant to the assigned business units. 

Responsibilities:

• Provide advice and counsel to Solta Medical and Ortho Dermatologics’ leadership in the United States by evaluating business strategies and tactics for potential compliance risks.
• Review and pre-authorize transactions where indicated by company policies, including HCP engagements, commercial sponsorships, grant and IIS reviews, and medical device training events.
• In coordination with the US Region Compliance Officer, periodically update and maintain all relevant polices and procedures, ensuring they are appropriately tailored to the risks associated with each business.
• Assist in the development and roll-out of Compliance training and communication to Sales, Marketing, Medical Affairs, and other relevant departments.
• In partnership with the US Region Compliance Officer, maintain and enhance the processes underlying Bausch Health’s transparency reporting under the Physician Payments Sunshine Act.
• Support cross-border activities initiated by personnel based in the US, including by the Solta Global Strategic Marketing team.
• Execute a comprehensive compliance monitoring program relevant to each business unit, including periodic ride alongs, observation of speaker programs, advisory boards, sponsorship activities, and third-party due diligence of higher-risk vendors.
• Investigate suspected violations of Bausch Health’s Code of Conduct and Compliance policies.
• In partnership with the relevant privacy officer, evaluate and mitigate data privacy risks pertaining to the potential collection and use of personal data by Marketing, Clinical or other company personnel.
• Analyze and review metrics with business unit leaders to assist in raising awareness and remediate gaps in compliance.
• Participate in annual healthcare compliance risk assessments alongside the US Region Compliance Officer and Chief Compliance Officer.
• Maintain regular compliance committee meetings with leaders of the relevant Business Units.

Qualifications:

• Eight or more years of experience U.S. healthcare compliance experience, including experience in the medical device (preferred), diagnostic, or pharmaceutical industries and/or a law degree and four or more years of such experience.
• Subject matter experience with relevant laws and regulations, including:
• U.S. anticorruption and anti-kickback laws and regulations, including the Federal Antikickback Statute,
• The Physician Payments Sunshine Act
• Laws and regulations governing medical device and pharmaceutical product promotion,
• The AdvaMed Code of Ethics, and
• The PhRMA Code on Interactions with Healthcare Professionals.
• Robust communication skills, including experience performing live training in front of large audiences.
• Ability to work effectively with cross-functional teams, multiple levels of management, external advisors, and others.
• Experience performing internal monitoring and conducting misconduct investigations. 
• Education: Compliance and/or Legal background with a strong business partnership orientation; law degree or compliance certifications a plus. 

The range of starting base pay for this role is 178K - 245K. Actual starting pay will be based on a wide range of factors including, but not limited to, relevant skills, experience, qualifications, education and location. In addition to base pay, this position is eligible for participation in either (i) our annual bonus program or (ii) a sales incentive plan.

Benefits package includes a comprehensive Medical (includes Prescription Drug), Dental, Vision, , Flexible Spending Accounts, 401(k) with matching company contribution, discretionary time off, paid sick time, tuition reimbursement, parental leave, short-term and long-term disability, life insurance, accidental death & dismemberment insurance, paid holidays, employee referral bonuses and employee discounts. 

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