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CHC Random Study Questions 2 with Verified Answers.
Fill in the blank: The ___________ ____ Act further required that the HHS Secretary, in consultation with HHS-OIG, establish "core elements" for provider and supplier compliance programs within a particular industry or sector. - ✔✔✔ Affordable Care Pursuant to 42 C.F.R. §§ 422.503(b)(4)(vi), 423.504(b)(4)(vi), and as incorporated into Chapter 21, Section 30 of the "Medicare Managed Care Manual": All sponsors are required to adopt and implement an effective compliance program, which must include measures to prevent, detect and correct Part C or D program noncompliance as well as FWA. The compliance program must, at a minimum, include the following core requirements: 1. Written Policies, Procedures and Standards of Conduct; 2. Compliance Officer, Compliance Committee and High Level Oversight; 3. Effective Training and Education; 4. Effective Lines of Communication; 5. Well Publicized Disciplinary Standards;
- Effective System for Routine Monitoring and Identification of Compliance Risks; and 7. Procedures and System for Prompt Response to Compliance Issues. These seven elements are functionally equivalent to the seven elements of an effective compliance plan identified by HHS-OIG in its publication, Compliance Program for Individual and Small Group Physician Practices. Fill in the blanks: The OIG CPG states: Standards of _______ should articulate hospital's commitment to comply with Federal and state standards..... they should state the organization's mission, goals, and ethical requirements of compliance and reflect a carefully crafted, clear expression of expectations for all hospital governing body members, officers, managers, employees, physicians, and, where appropriate, _______ and other agents. - ✔✔✔ conduct; contractors You are the new Compliance Officer, hired after ABC Hospital reorganized and decided that the General Counsel should no longer also serve in that role. Upon review of the Code of Conduct (CoC), you find that it is written using lots of legal jargon. What action do you take: a. Keep CoC as it is. b. Pull a sample off the internet and insert hospital name to save time as it was most likely written by experts. c. Rewrite the CoC in plain and concise language tailored to the hospital so employees can use a general guidance. d. Rewrite the CoC with detailed restating hospital's P&Ps, and all laws and regulations possible so that employees can't say they were not aware of requirements. - ✔✔✔ c. Rewrite the CoC in plain and concise language tailored to the hospital so employees can use a general guidance. Explanation:
CoC should be clear and concise language easy to understand, and should be tailored to specific issues of the organization What should CCO be able to do? (What skills should this person have?) Choose all that apply. a. Leadership skills. b. Oversee the coding department. c. Skills to design and implement a compliance program. d. Be able to anticipate new risk areas. e. Practical experience with documenting medical necessity. - ✔✔✔ a. c. and d. Life cycle of records management - ✔✔✔ Creation Use Maintenance Retention Disposition New Employee Policy - three checks OIG recommends to do/perform: - ✔✔✔ OIG recommends: perform background checks, reference checks, and exclusion list checks Which of the following is responsible for clinical trial billing compliance and enforcement: a. FDA b. OIG c. ORI d. OCR - ✔✔✔ b. OIG ABC Hospital is under a 5 - year CIA with government-imposed requirements for development of a Compliance Program and use of external auditor for periodic claim reviews. Which of the following is TRUE: a. Costs to meeting terms of the CIA are permitted to be included in the cost report like any other operational cost. b. Because the hospital agreed to a settlement and was not convicted for alleged violations, the Compliance Program is considered a voluntary program. c. The government chooses and pays for the external auditors. d. None of the above - ✔✔✔ d. None of the above. Explanation:
- CIA-related costs CANNOT be included in the cost report.
- Government-imposed Compliance Program ARE NOT considered a voluntary program.
- Hospital is required to choose and pay for any auditors (with government review and right to object) The IRO is conducting a Claim Review for a hospital under a CIA and discovers that there is a discrepancy between the dollar difference between the amount that was reimbursed and the amount that should have been reimbursed when conducting a Discovery Sample. Which of the following is false:
If during the course of an internal investigation, the compliance officer believes the integrity of the investigation might be compromised by the continued presence of work force members who are the subject of the investigation. In the best interest of the attorney-client privilege, which action would you take? a. Conduct employee background checks b. Counsel obtains employee's depositions c. Destroy documents and other evidence d. Re-assign employees to other responsibilities until the investigation is completed e. All of the above - ✔✔✔ d. Re-assign employees to other responsibilities until the investigation is completed. Explanation: he/she should recommend that such individuals be temporarily removed from their current responsibilities until the investigation is completed. Ref. Healthcare Compliance Professional's Manual A research team begins a systematic review of research related documents to determine Medicare billing status of a study prior to contract finalization. A billing grid is prepared, and a Pet scan is determined to be non-billable to third-party payors. Which of the following is the MOST appropriate information to include in the informed consent: a. the facility is obligated to pay for procedures outside the normal standard of care that are not covered by the sponsor b. the subject's co-pays and deductibles will be reimbursed by the sponsor c. the subject may be responsible for costs when procedures are outside of the normal standards of care d. all care on protocol will be covered by the sponsor, and the subject will have no costs to participate - ✔✔✔ c. the subject may be responsible for costs when procedures are outside of the normal standards of care The most important communication device for a compliance program is: a. Code of Conduct b. Education c. Open door policy d. All of the above - ✔✔✔ c. Open door policy Which is not considered part of the 3 C's of Communication? a. Creative b. Confident c. Clear d. Concise - ✔✔✔ b. Confident True or False: The OIG states "an open line of communication between the CO and personnel is equally important to the successful implementation of a compliance program and the reduction of any potential fraud, waste and abuse" - ✔✔✔ True
A healthcare provider must repay to Medicare money paid for a specific type of billed claim. What type of audit is the MOST likely one used to identify the amount of repayment? a. probe audit b. concurrent audit c. proactive audit d. full statistical audit - ✔✔✔ d. full statistical audit Your Hospital recently did a contemporaneous review. What may they uncover and then what might be warranted? a) May uncover recent future errors and warrant a retrospective review. b) May uncover recent past errors and warrant retrospective review. c) May uncover recent past errors and warrant a baseline audit. d) May uncover recent future errors and warrant a baseline audit. - ✔✔✔ b) May uncover recent past errors and warrant retrospective review. Explanation: "Recent future errors" - you can't uncover errors that haven't happened yet. A contemporaneous audit is one of current claims but if you found an error it would be on something that was already done just from a logical perspective. If an error is found in current billing practices then it may warrant looking at past bills (retrospective review) to determine if the issue is more wide spread. From Chapter 3 of the Auditing and Monitoring book 2nd ed. A process effected by an entity's board of directors, management, and other personnel designed to provide reasonable assurance regarding the achievement of objectives is called....? - ✔✔✔ Internal Controls Benefits of conducting a Control Self Assessment may include: - ✔✔✔ • Increases scope
- Targets audit work
- Frees internal audit resources
- Increases awareness
- Motivates personnel First thing one should do when considering an effective compliance program? - ✔✔✔ Conduct a Risk Assessment (focus on organizational risks) What can be an effective support system of the desired organizational culture? a. Auditing and monitoring b. HR policies and procedures c. Management d. Security personnel - ✔✔✔ b. HR policies and procedures. P&P should match and improve workplace culture as well as its commitments to regulatory and corporate compliance when governing its employees. Note: practice question from AAPC CPCO Ch
a. authorization from the individual b. consent from the individual c. authorization from the healthcare entity d. consent from the healthcare entity - ✔✔✔ a. authorization from the individual What key item(s) can protect a medical practice from harassment liability? a. Keys to the office b. Management plans c. Physical safeguards d. A zero tolerance policy for harassment - ✔✔✔ d. A zero tolerance policy for harassment. Having a zero tolerance policy on harassment protects a company from liability. Note: practice question from AAPC CPCO Ch At which level of the Medicare Part A or Part B appeals process is the appeal reconsidered by a qualified independent contractor? a. first level of appeal b. second level of appeal c. third level of appeal d. fourth level of appeal - ✔✔✔ b. second level of appeal First level - redetermination by Medicare contractor Second level - reconsideration by Independent contractor Third appeal - Administrative Law Judge (ALJ) hearing Fourth appeal - review by Medicare Appeal Council Fifth appeal - review in Federal District Court Fill in the blank: Fundamentally, compliance efforts are designed to establish a ______ within a hospital that promotes prevention, detection and resolution of instances of conduct that do not conform to Federal and State law..." - ✔✔✔ Culture The compliance professional is at the step of the risk assessment process that is primarily based around risk tolerance information and inherent risk assessment information. What step is MOST closely associated with this information? a. Assess inherent likelihood of determined risks. b. Determine risk tolerance. c. Assess residual impact of the risks. d. Evaluate the portfolio of risk and determine what the risk responses will be. - ✔✔✔ d. Evaluate the portfolio of risk and determine what the risk responses will be. To provide patients with appointment reminders, an organization should: a. Confirm the appointment with the treating physician b. Speak directly with the patient regarding future appointments c. Address patient reminders in the NPP d. Mark all patient reminder mailings as "confidential" - ✔✔✔ c. Address patient reminders in the NPP
HCCA 2 components of a compliance program - ✔✔✔ 1. structural component (OIG 7 elements to create the framework - "nuts and bolts"); 2. substantive component (applicable laws and regulations) A CIA (Corporate Integrity Agreement) can be imposed instead of exclusions. How long are CIA's typically? a. 8 years b. 2 years c. 5 years - ✔✔✔ c. 5 years generally (CIAs can range from 3 - 8 years) A Whistleblower recently identified a number of fraudulent Medicare claims. Her husband is asking about a potential reward, which statement is true. a. She must inform the organization about the claims before notifying the government b. If DOJ takes the case, she could receive at least 15% of government total award c. She must at least try to resolve the claims issue d. None of the above - ✔✔✔ b. she could receive at least 15% of total reward Explanation: The government has no requirements about a whistleblower informing or resolving an issue first. The government wants to encourage an environment of trust where problems are brought forward. If a referred patient to your practice has hearing deficit and needs an appointment, what steps should your practice take when scheduling? a. Ask the patient to bring an interpreter with them to the visit. b. Kindly explain to the patient that he or she can't be seen because the practice doesn't have the ability to communicate with the hearing impaired. c. Schedule the appointment a few days ahead and make arrangements for an interpreter. d. Schedule the appointment, advise the patient of the charge for the interpreter, and ask how he or she will pay for the services. - ✔✔✔ c. Schedule the appointment a few days ahead to make arrangements for an interpreter. The ADA requires businesses to take steps necessary to communicate effectively with patients with vision, hearing, and speech disabilities. Note: practice question from AAPC CPCO Ch FSG - 4 Aggravating Factors to a culpability score - ✔✔✔ 1. Willfully Ignorant - If an upper level employee has "participated in, condoned, or was willfully ignorant of the offense", involvement or tolerance in criminal activity
- Prior history of misconduct - the violation is a repeat offense
- Violation of an order or condition of probation
- Obstruction of Justice - If the government was hindered during its investigation Ref: https://www.ussc.gov/guidelines/2018-guidelines-manual-annotated
An officer of a federal agency whose primary function is to conduct and supervise audits and investigations relating to operations and procedures over which the agency has jurisdiction - ✔✔✔ Office of Inspector General (OIG) Coding for a higher level than the documentation warrants. This is known as: - ✔✔✔ Upcoding Guidelines issued by the OIG for the suggested development of compliance programs - ✔✔✔ Compliance Program Guidelines (CPG) How should an organization handle an error in spelling of a patient's name on the medical record? a. Ask the patient for guidance b. Amend the record c. Create a new record - ✔✔✔ b. Amend the record Explanation: This common issue involves maintaining integrity of the medical record and patient safety. Ideally, your EHR will provide the ability to amend and track the correction of the individual's identity without losing other important notes. The date, time, reason for the change and the person making the change should be recorded/stamped within the record. Ref. from 1st HC Compliance Is it okay to send X-rays to specialists when referring patients if our email is not encrypted? a. Always b. Never c. It depends - ✔✔✔ c. It depends Explanation: Encryption is strongly recommended as the best practice. If the individual is requesting PHI in the form of X-rays be sent to the third party and the individual is notified prior to sending via unencrypted email and the individual agrees to sending via unencrypted email, this is permitted under HIPAA. HHS provides clear guidance on sending PHI in an e-mail. Please remember that state laws may apply as well. Ref. from 1st HC Compliance Which is the underlying principal of the Equal Employment Opportunity law? a. This law requires all persons to be entitled to equal employment opportunity regardless of race, religion, or national origin. b. This law requires all minorities to be entitled to equal employment opportunity regardless of race, color, religion, sex, national origin, age, disability, or any other characteristic protected by law. c. This law requires all persons to be entitled to equal employment opportunity regardless of race, color, religion, sex, national origin, age, disability, or any other characteristic protected by law.
d. This law requires all persons be entitled to equal employment opportunity regardless of sex, age, or disability. - ✔✔✔ c. This law requires all persons to be entitled to equal employment opportunity regardless of race, color, religion, sex, national origin, age, disability, or any other characteristic protected by law. It is important for a compliance officer to understand that all persons are legally entitled to equal employment regardless of their race, color, religion, sex, national origin, age, disability, or any other characteristic protected by law. Failure to abide by the Equal Employment Opportunity law can bring forth lawsuits based on unlawful discrimination. Note: practice question from AAPC CPCO Ch What federal agency is in charge of employee safety? a. Department of Health and Human Services b. National Institute for Employee Health c. Occupational Safety and Health Administration d. Centers for Disease Control and Prevention - ✔✔✔ c. Occupational Safety and Health Administration. OSHA is the federal agency charged with ensuring employee safety in the workplace. Note: practice question from AAPC CPCO Ch Primary safety concerns in the medical setting include bloodborne pathogens, radiation, bio-hazardous waste, and ________. a. closed spaces b. chemicals c. patient care equipment d. non-patient care equipment - ✔✔✔ b. chemicals Key issues in a medical setting are bloodborne pathogens, radiation, chemicals, and bio- hazardous waste. Note: practice question from AAPC CPCO Ch Which of the following is considered the primary means of minimizing employee exposure? a. Policies and procedures b. Engineering controls c. Personal protective equipment d. Drills - ✔✔✔ b. Engineering controls. Engineering controls remove the hazard from the workplace or create a barrier between the worker and the hazard. Engineering controls are the primary means of eliminating or minimizing employee exposure, and include training and the use of safer medical devices, such as needleless devices, shielded needle devices, and plastic capillary tubes. Note: practice question from AAPC CPCO Ch
A compliance professional has received a complaint through the compliance hotline. The employee making the complaint alleged that she received discipline that was unfair because she had a co-worker who committed the same violation and received a lesser punishment. What should the compliance professional do FIRST? a. Review performance evaluation to see if there were any performance issues for the employee who made the complaint b. Review policy concerning disciplinary action c. Review the disciplinary actions taken against the two employees to see if the allegation is true. d. Contact the employee to obtain or gather information about her allegation - ✔✔✔ d. Contact the employee to obtain or gather information about her allegation Any laboratory performing testing on specimens derived from a human being for purposes of providing diagnosis, prevention, treatment, or assessment of health, regardless of whether they participate in Medicare, must: a. Participate in a quality assurance program b. Maintain adequate hours of operation for the underserved community c. Enroll in the CLIA program d. Have a certificate of compliance - ✔✔✔ c. Enroll in the CLIA program Note: practice question from AAPC CPCO Ch A privacy official is asked to approve a transfer form that would have the patient's SS# on the top of the page when a patient is transferred from the privacy officer's facility to another facility. The nursing leadership at the facility is insisting that they "have to have" the patient's SS# when making transfer arrangements from one facility to another. The BEST course of action for the privacy officer to take is: A. Ask the nursing leadership to update the policy on transfers to include that social security numbers must be included on transfer paperwork. B. Have the appropriate forms updated/revised/edited so that they can now accommodate the social security numbers. C. Confirm with nursing any regulations or other requirements that state social security numbers must be included on transfer forms D. Contact the legal department. - ✔✔✔ C. Confirm with nursing any regulations or other requirements that state social security numbers must be included on transfer forms A privacy professional is assisting IT with the development of proper controls to protect the privacy of the organization's data. Which of the following is an employee-related control? a. Breach response procedures b. Annual evaluations c. Contractual requirements d. User passwords - ✔✔✔ d. User passwords Reporting systems should be: a. marketed to contractors
b. outsourced to a vendor c. operated by management d. publicized to all employees - ✔✔✔ d. publicized to all employees A Physician practice is having a hard time determining which claims have been paid in full, and which claims have not been paid at all. What test would be practical for the group to perform to validate the claims that have been paid or not paid. A. Statistical Sampling B. Rat-Stats C. Snap Shots D. Random Sampling - ✔✔✔ A. Statistical Sampling An employee reports a potential problem with the attending physician's presence for surgery. Which of the following is the compliance professional's BEST action? a. investigate the issue b. approach the surgeon c. notify the OIG d. request copies of the records - ✔✔✔ a. investigate the issue In a home health agency, the compliance officer will find that which of the following is identified by the OIG as one of the most risk prone areas for fraud, waste and abuse: a. Services provided by individuals who do not have appropriate credentials b. Home Health Orders being signed by the certifying physician in a timely manner c. Homebound status verification d. All of the above e. None of the above - ✔✔✔ a. Services provided by individuals who do not have appropriate credentials Lincoln's Law - ✔✔✔ Refers to the False Claims Act given that the FCA was introduced during the Civil War Res Ipsa Loquitur - the principle of law that allows the use of circumstantial evidence as proof. The Latin phrase means: - ✔✔✔ "the thing speaks for itself" The Physician Payment Sunshine Act must report ______to a covered recipient which is defined as a ______or teaching hospital - ✔✔✔ payment/anything of value; physician True or False: Under the Anti-Kickback Statute, it is illegal to provide free or discounted services to uninsured people - ✔✔✔ False What Act included a new requirement that providers repay identified overpayments to Medicare and Medicaid within 60 days or be subject to penalties? - ✔✔✔ The Affordable Care Act
