Asst General Counsel

Location: Chicago, Illinois Hospital: Rush University Medical Center Department: RUSH Legal Affairs Work Type: Full Time Work Schedule: 8 Hr (9:00 AM - 5:00 PM) Rush offers exceptional rewards and benefits learn more at our Rush benefits page (https://www.rush.edu/rush-careers/employee-benefits).

Pay Range

$79.20 - $118.01 per hour Rush salaries are determined by many factors including, but not limited to, education, job-related experience and skills, as well as internal equity and industry specific market data. The pay range for each role reflects Rush’s anticipated wage or salary reasonably expected to be offered for the position.

Offers may vary depending on the circumstances of each case. This role has a corresponding incentive plan based on multiple factors. incentive compensation and additional benefits can be found on our Rush benefits page (https://www.rush.edu/rush-careers/employee-benefits) Summary: Under the direction of the Vice President/General Counsel and Associate General Counsel for Compliance, the Assistant General Counsel provides oversight of RUMC’s Central Contract Database and RUMC’s processes for contract review.

Reviews contract files for sufficiency of required regulatory documentation. Reviews arrangements, agreements and contracts for compliance with all relevant Federal regulatory law. Performs legal research to ensure Rush remains compliant with federal and state rules and regulations. Assists in RUMC’s legal analysis and compliance with state and federal non-profit, charitable organization and tax-exempt status.

Exemplifies the Rush mission, vision and values and acts in accordance with Rush policies and procedures. Other information: Required Job Qualifications: •Juris Doctorate (J.D.) and strong financial background. •Basic knowledge of health care law, non-profit organizational structures, securities and tax regulations are necessary.

•Highly developed degree of business judgment, initiative, and ability to work independently and as a team. •Strong working knowledge of Microsoft Office, Lotus Notes and Internet search applications. •Analytical, creative problem solving skills and attention to detail.

Responsibilities

1. Assists in the compilation and review of all RUMC’s written contracts and agreements with special focus and responsibility for physician related agreements and compliance with the Stark self-referral regulations.
2. Performs analysis for sufficiency of documentation in relation to payments and services to physicians under Stark III.
3. Assists Associate General Counsels, Transactions Counsel and Department/Practice Leaders in the development of appropriate contract terms especially with respect to Stark and Anti-Kickback laws.
4. Performs analysis of RUMC’s current policies and processes in relation to State and Federal requirements for 501(c)/charitable purpose/nonprofit status.
5. Provide legal opinion and research relating to use of tax-exempt bond income for private business use and tax-exempt purpose (as related to management/service arrangements, research contracts, naming rights contracts, ownership, leases, subleases, leasehold improvement contracts, joint venture arrangements, and LLC or LP arrangements).
6. Identify and locate relevant records to tax-exempt bonds.
7. Relating to general recordkeeping for 501(c) (3) determination, organizing documents for RUMC and joint ventures, audited financial statements, and debt financing documents (Certifications, issuance documentation, publications, government grants associated with bond financed construction, and trustee statements).
8. Relating to allocations of investments and arbitrage from bond financing proceeds (including documentation related to computations of bond yield, rebate and yield reduction payments).
9. Relating to allocations of bond-financing proceeds to expenditures (documenting construction, renovation or purchase and use in performance of exempt purpose through bond financed proceeds).
10. Work with debt counsel, RUMC departments and the Tax-Exempt Financed Assets Workgroup to identify and document use of tax-exempt bond income, create efficient processes to ensure subsequent uses and agreements maintain tax exemption, and facilitate compliance with arbitrage/rebate requirements.
11. Provide assistance and support to bond offerings.
12. Provide legal opinions regarding Stark transactional review, processes and documentation on unwritten transactions and current contracts.
13. Identify applicable Stark exception for financial relationships between RUMC and physicians to determine and reform legal sufficiency of contracts as necessary.
14. Develop framework for on-going Stark regulations compliance with other offices including Corporate Compliance, Office of Medical Affairs, individual departments of the Medical College, and all other contracting components of Rush University Medical Center.
15. Identify and coordinate an analysis of contracting components of Rush University Medical Center by examining joint ventures, affiliations and other institutional financial relationships.
16. Prepare and maintain a Stark Regulations Guidebook.
17. Utilizes position to create synergies in compliance process throughout RUMC.
18. Oversees and creates an internal annual legal review process of Compliance policies. Rush is an equal opportunity employer. We evaluate qualified applicants without regard to race, color, religion, sex, sexual orientation, gender identity, national origin, disability, veteran status, and other legally protected characteristics.