CHC Compliance Program Administration
Health care Fraud is key priority in the Justice Department, and an effective _________ program safeguards the organization's legal responsibility to abide by applicable laws and regulations
"Compliance"
Fill out the blank: Boards have vital roles in Compliance: They should have diverse expertise; provide __________ of the compliance program; assist in developing the __________ of the compliance program and ___________ compliance standards and processes for effectiveness.
"oversight" "structure" "evaluating"
Compliance Committee Purpose
"to advise the compliance officer and assist in the implementation of the compliance program" Ref: OIG Compliance Program Guidance, pg 12 of PFD: https://oig.hhs.gov/authorities/docs/cpgnf.pdf
What are the three roles of a board member?
1. Compliance oversight. 2. Structuring your compliance program 3. Evaluating effectiveness of the compliance standards and processes.
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; 6. 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.
The board should review reports on the status of the compliance program, how often?
At least annually
The Hospital is attempting to open its files to a new Compliance Officer for review. What documentation is not critical for his review? A. The patient charts for the OB floor. B. The record of PHI breaches. C. The labs billing records. D. Contracts with Acme DME suppliers.
B. Records of PHI breaches Explanation: PHI breaches fall under Information security not Compliance activities. Records under Compliance activities include billing records, patient records, vendor contracts.
When creating and implementing a compliance plan, the compliance officer should have A. no approval B. board approval and resolution. C. patient approval. D. legal approval
B. board approval and resolution.
Which of the following are MOST relevant in evaluating the effectiveness of a compliance training program? 1. percent of target audience that has attended 2. whether the training is computer-based or classroom-based 3. whether training adequately addresses areas of concern 4. improvement shown in pre- and post-training quizzes A. 1 and 3 only B. 1 and 4 only C. 1, 3, 4 only D. 2, 3, 4 only
C. 1, 3, 4 only
OIG urges the ____________ to assist in the implementation of the compliance program and serves as advisors. A. Board B. CEO C. Compliance Committee D. Quality Committee
C. Compliance Committee
Which of the following is not a form of ethical behavior? Deception Loyalty Fairness Competition
Deception
True or False: In order to function at our company, you may be required to give up your personal sense of right and wrong
FALSE
OIG Work Plan, what's its main purpose?
Identifies high risk & key areas of focus for auditing. Active Work Plan Items reflect OIG audits, evaluations, and inspections that are underway or planned. Ref: https://oig.hhs.gov/reports-and-publications/workplan/index.asp
One of the processes for risk identification is document review, including OIG key compliance documents. Name some of the OIG documents that should be considered for review.
OIG workplan and bulletins, Advisory Opinions, Special Fraud Alerts, and other guidance https://oig.hhs.gov/compliance/compliance-resource-portal/
True or False: A company Code of Conduct acts as one of the guidelines as to how the company operates day-to-day and conducts business
True
In compliance regulation and risk assessment key performance indicators usually include (select all that apply): a. fines or penalties b. customer/employee complaints c. regulatory criticism from a regulator or internal/external auditors d. none of the above
a, b and c ref. ABA CRCM (certified regulatory compliance manager)
Information provided from a hotline call involves a senior manager and indicates potential research misconduct. The caller is concerned about losing her job. Which of the following should the compliance professional tell the employee: a. "retaliation is prohibited by policy" b. "confidentiality will always be maintained" c. "HIPAA regulations ensure confidentiality" d. "the ORI must be notified of this hotline call"
a. "retaliation is prohibited by policy"
What is considered an appropriate start to implementing an effective compliance program for compliance officers of small physician group practices with limited resources? a. Adopt only those components which, based on the practice's specific history with billing problems and other compliance issues, are most likely to provide an identifiable benefit. b. A compliance program will not be effective unless every element is fully implemented. c. Have a manual of policies and procedures available for review in the manager's office. d. Small practices are low-risk so they don't need to implement a compliance program.
a. Adopt only those components which, based on the practice's specific history with billing problems and other compliance issues, are most likely to provide an identifiable benefit. Note: practice question from AAPC CPCO Ch2
An individual's understanding of the compliance aspects of their job can be BEST enhanced by including compliance in a. annual evaluations b. exit interviews c. HR benefit material d. audit committee meetings
a. annual evaluations
Which of the following is the BEST question to include in an employee exit interview? a. Why are you leaving your job? b. Did you ever observe anything that made you feel uncomfortable? c. How many times did you use the compliance hotline? d. Do you think your patients knew about the hotline?
b. Did you ever observe anything that made you feel uncomfortable?
What provided the groundwork for compliance program development? a. HHS b. FSG c. DOJ d. CMS
b. FSG - Federal Sentencing Guidelines - ref Ch 8 B2.1 https://guidelines.ussc.gov/gl/%C2%A78B2.1 (Enactment of the Sentencing Reform Act and Creation of the Commission)
What types of gifts or favors are acceptable under the Code of Conduct? a. A $100 gift card from a vendor to influence you to form an agreement that involves buying certain products b. Receiving a coffee mug with your facility's logo on it c. Free tickets to Hawaii from a company in exchange for buying products from them d. A tip from a family to ensure their loved one receives "special care"
b. Receiving a coffee mug with your facility's logo on it
After a compliance officer develops a base of knowledge, he/she must begin the art of applying regulations in a risk management environment. Which of the following is NOT out of a few things to be kept in mind when determining what to do FIRST? A. think practically about your role as an advisor, involve all department units in the decision process rather than making decisions from them b. calculate the organization's consolidated risk profile c. make sure you understand the level of risk that the organization will tolerate, so decisions do not exceed this limit d. add value by analyzing regulatory requirements for the department units before you present proposed/final rules or solutions
b. calculate the organization's consolidated risk profile (determine risk tolerance) ref. ABA CRCM (certified regulatory compliance manager)
Payers expect all providers to refund monies that are overpayments. By law, how long does the provider have to refund overpayments once discovered? a. A timely manner, the specific number of days is not specified b. 60 days after receipt of overpayment c. 60 days after identification of overpayment d. 90 days after a request by the payer
c. 60 days after identification of overpayment Under Section 6402 of the ACA, a provider must refund Medicare within 60 days of identifying the overpayment. Note: practice question from AAPC CPCO Ch2
To be effective, compliance risk management professionals must design a framework to ensure that management understands the risks and steps to take to mitigate them. The many roles compliance professionals fill incorporate risk management aspects including: a. overseeing compliance training targeting higher risk areas b. tracking regulatory proposals or final rules to understand new risks c. both a and b
c. both a and b ref. ABA CRCM (certified regulatory compliance manager)
Fill in the blank: ______________ should include basic elements designed to understand and mitigate risk. It usually includes a written program and compliance related P&Ps. a. tactical compliance procedures b. rank solution c. compliance program d. none of the above
c. compliance program ref. ABA CRCM (certified regulatory compliance manager)
Which of these steps should not be taken when assisting in a code of conduct violation investigation? a. Follow the company policy to fairly discipline the involved parties. b. Document and report your findings. c. Treat every person involved with dignity and respect. d. Limit your interview to as few people as possible.
d. Limit your interview to as few people as possible.
Code of conduct supersedes which of the following: a. Department's policy and procedure b. State Law and Regulation c. Federal Laws and Regulation d. None of the answers
d. None of the answers
Compliance professionals have a duty to keep senior management and the board appraised of the state of compliance through which of the following: a. self-monitoring and audit results b. proactive compliance controls c. timely and accurante regulatory/compliance reporting d. all of the above
d. all of the above ref. ABA CRCM (certified regulatory compliance manager)
The following should be done during research and interpreting regulations Compliance professionals in mitigating compliance risks, EXCEPT: a. track regulatory proposals (proposed legislation/rules) b. implementing fial regulatory rules c. understanding the business units' operating environment and risk tolerance d. ranking solutions as High, Moderate, Low risk
d. ranking solutions as High, Moderate, Low risk ref. ABA CRCM (certified regulatory compliance manager)
A Compliance Program with well written policies and procedures: a. can be successful if consistently reviewed and maintained b. cannot be effective due to the sheer volume presented c. will be effective if read by management d. will not be successful without the proper oversight
d. will not be successful without the proper oversight
What are some obstacles to an effective compliance program? a. Lack of funding b. Resistance to change c. Fear of retaliation d. Lack of education and training e. All of the above
e. All of the above
Before developing a Compliance Program, FIRST, conduct a ___ _______, then, NEXT, _____ risks to help you define the basis for what the compliance program should focus on for the next year in its plan.
risk assessment; prioritize
Examples of current Compliance activities in many organizations
• Equal Employment Opportunity Commission (EEOC) • Employee Retirement Income Security Act (ERISA) • Wage and Hour Rule • Occupational Safety and health Administration (OSHA) • Nuclear Regulatory Commission • Joint Commission on Accreditation of Healthcare Organization (JCAHO) • Research compliance
What are the two primary focus areas of a Board of Directors (BOD) in compliance?
1 - structural (needs to understand compliance program SOW) 2 - operational (need to understand compliance program needs to operate) Additional resource: "The Health Care Director's Compliance Duties" https://oig.hhs.gov/compliance/compliance-guidance/docs/Health_Care_Directors_Compliance_Duties.pdf
HCCA 2 basic components of a compliance program:
1. structural component (OIG 7 elements) 2. substantive component (specific laws and regulations) https://compliancecosmos.org/chapter-2-seven-essential-elements
Which of the following violations could result in immediate termination? 1. Egregious acts of misconduct 2. Violence in the workplace 3. Stealing/Embezzlement 4. All of the answers
4. All of the answers
A compliance program at its most basic level would be: (think of the 1st CP element)
A set of internal policies and procedures that you put into place to help your organization comply with the law.
Who should participate in developing goals and objectives for the compliance program? A. Compliance Committee B. Risk Managers C. Board D. MDs
A. Compliance Committee
OIG urges the ____________ to assist in the implementation of the compliance program and serve as advisors. A. Board B. CEO C. Compliance Committee D. Quality Committee
C. Compliance Committee
Fill in the blank: The OIG in conjunction with DOJ is responsible for enforcing the rules and regulations under the Medicare and Medicaid laws outlined as part of the Social Security Act and administered by ______
Centers for Medicare and Medicaid Services (CMS)
The compliance committee should develop objective and goals on: A. monthly basis B. continuous basis C. quarterly basis D. annual basis
D. annual basis
February 27, 1997, what does this date represent?
Date of OIG open letter to all providers - encourages health care organization to implement compliance programs in order to protect themselves from fraud and abuse. With that letter, Model compliance plan for Clinical Laboratory was offered as guidance. Since that time, a Model compliance plan has been implemented in many areas. See OIG Compliance Guidelines page: https://oig.hhs.gov/compliance/compliance-guidance/index.asp
When we anticipate what the government will measure if our compliance program is under review, we should assume the following: A. The FSG is the basis of the assessment B. What determines "effectiveness?" C. Are there specific resources on what it is we need to demonstrate? D. Resource: Corporate Integrity Agreements/Settlement Letters E. All of the above
E. All of the above
You have done a compliance plan. What comprises a compliance program? A. Budget B. Resources C. Board D. CO E. All of the above
E. All of the above
True or False: Does Compliance Officer impose disciplinary actions?
FALSE - no, only recommend (HR/management imposes discipline)
HCCA prepared and published "Code of Ethics for Health Care Compliance Professional" addressing 3 principles. Name them
Principle 1 - Obligation to public Principle 2 - Obligation to employing organization - should serve organization with highest sense of integrity, unprejudiced, and unbiased judgment Principle 3 - Obligation to profession - uphold integrity and dignity of profession, to advance effectiveness of compliance program and to promote professionalism in health care compliance Ref: https://assets.hcca-info.org/Portals/0/PDFs/Resources/HCCACodeOfEthics.pdf
True or False: A good compliance program will identify problems from time to time, if it doesn't, that's a sign that what you're doing is NOT effective.
TRUE
True or False: Experienced compliance health care personnel can do, and want to do, what is called "double duty" as trainers and line performers
TRUE
True or False: The board should ensure that the compliance officer has sufficient power, independence, and resources to implement, maintain, and monitor the entity's compliance program and advise the board about the entity's compliance operations and risk.
TRUE Ref. OIG CPG
True or False: As a CO, you are tasked with identifying risk. Knowing some document reviews may never apply to your organization, should you review Special Advisory Bulletins?
TRUE The bulletins provide guidance to the health care industry on the scope and frequency of screening employees and contractors to determine whether they are excluded persons. https://oig.hhs.gov/exclusions/advisories.asp
In all OIG program guidance, what's the first element they call for?
The first prescribed elements calls for the development and distribution of written standards of conduct, as well as written policies and procedures that promote a commitment to compliance.
Which department is the largest inspector general's office in the federal government? a. HHS Office of Inspector General b. Office of Civil Rights c. Department of Justice d. Centers for Medicare & Medicaid Services
a. HHS Office of Inspector General Note: practice question from AAPC CPCO Ch1
There are many benefits of having an effective compliance program. Which, of the below, is one such benefit? a. It shows that the practice is making a good faith effort to be compliant. b. It provides a means to cover errors until they can be fixed. c. It allows employees to retaliate against their employer when they believe they have been treated unfairly. d. It provides a basis for the OIG to create a CIA if a problem is identified.
a. It shows that the practice is making a good faith effort to be compliant. Note: practice question from AAPC CPCO Ch2
The compliance program should address plans to verify adherence to applicable laws and regulations through: a. ongoing monitoring to evaluate the program, self-monitoring and corrective action b. self-monitoring c. Periodic reviews d. Ongoing monitoring to evaluate the program, self-monitoring and period reviews
a. ongoing monitoring to evaluate the program, self-monitoring and corrective action Ref. ABA CRCM (certified regulatory compliance manager)
What is the most important aspect of a compliance program? a. Training b. Implementation c. Development d. Discipline
b. Implementation Having all the components of a compliance program in place will not matter if they are not implemented. Note: practice question from AAPC CPCO Ch2
The compliance professional is preparing a training session for the Board of Directors about the Yates Memo. Which of the following does the Yates Memo emphasize? a. Increased culpability score of organization b. Individuals will be prosecuted before the organization will. c. The Board is not responsible for bad decisions made by the organization d. None of the above
b. Individuals will be prosecuted before the organization will. Yates Memo discusses individual accountability for corporate wrongdoing. https://www.justice.gov/archives/dag/individual-accountability
Sue works for ABC Family Physicians. The providers at this office ask her to research the department that helps protect patients from unfair treatment or discrimination. What department or agency would that be? a. Equality in Employment Agency b. Office for Civil Rights c. Department of Justice d. Office of Inspector General
b. Office for Civil Rights (OCR) DOL oversees employment discrimination; DOJ enforces federal criminal law and implements criminal law policies; OIG combats FWA in Medicare, Medicaid and HHS Programs. Note: practice question from AAPC CPCO Ch1
What is required for a compliance program to be effective? a. The compliance program needs to be reviewed daily for any compliance updates. b. Regularly review and update the compliance program. c. The compliance program must be reviewed by healthcare lawyers. d. The compliance program needs to be reviewed weekly for any compliance updates
b. Regularly review and update the compliance program. Note: practice question from AAPC CPCO Ch1
When is an outside consultant and/or legal counsel necessary? a. Only when an overpayment is identified. b. There is no requirement to hire a consultant or counsel, but such assistance may be beneficial during certain phases of development and/or if issues arise. c. In the beginning of plan development. d. Never.
b. There is no requirement to hire a consultant or counsel, but such assistance may be beneficial during certain phases of development and/or if issues arise. Note: practice question from AAPC CPCO Ch2
Most expenses related to developing and implementing a compliance program are considered the cost of doing business and are tax deductible for the organization. Which of the following is NOT tax deductible? a. When the expense costs are more than the national average b. When the expenses are a result of the imposition of a penalty c. The annual maintenance of the program d. The salary of the compliance officer
b. When the expenses are a result of the imposition of a penalty. CIA is a penalty imposed upon the organization and, as with any other governmental penalty; the expense of the development, implementation, and maintenance of this program cannot be included as a deductible expense to the organization. Note: practice question from AAPC CPCO Ch2
A Compliance Officer can achieve a higher level of compliance and ethics engagement by: a. ensuring leadership reads the policies b. increasing management involvement c. responding to compliance hotline calls d. monitoring the code of conduct
b. increasing management involvement
Payers expect all providers to refund monies that are overpayments. By law, how long does the provider have to refund overpayments once discovered? a. A timely manner, the specific number of days is not specified b. 60 days after receipt of overpayment c. 60 days after identification of overpayment d. 90 days after a request by the payer
c. 60 days after identification of overpayment Under Section 6402 of the ACA, a provider must refund Medicare and Medicaid within 60 days of identifying the overpayment. If an entity identifies billing mistakes or other non-compliance with program rules leading to an overpayment, the entity must repay the overpayments to Medicare and Medicaid to avoid False Claims Act liability.
The Board of Directors involvement with compliance includes all except: a. Written endorsement b. Allocating sufficient budgetary resources c. Active role in the daily compliance operations d. Establishing compensation structures that reward compliance
c. Active role in the daily compliance operations
The Federal Sentencing Guidelines uses key mitigating factor, which are: a. Effective compliance program, reporting the violation promptly, awareness of the violation, and accepts responsibility for the violation. b. Willfully ignorant of the offense, repeat violation, government investigation was hindered and tolerance of the violation was pervasive. c. Effective compliance program, reporting the violation promptly, cooperate with government investigation and accepts responsibility for the violation. d. Effective compliance program, first offense, cooperate with government investigation and accepts responsibility for the violation.
c. Effective compliance program, reporting the violation promptly, cooperate with government investigation, and accepts responsibility for the violation (self-reporting) Ref: FSG Chapter 8 - https://www.ussc.gov/guidelines/2018-guidelines-manual/2018-chapter-8
Which of the following can be a result of an effective compliance program? a. Keep a provider from facing criminal penalties b. Make sure a practice or medical organization is 100 percent compliant with federal regulations c. Help create financial success, customer loyalty, community support, and employee satisfaction d. Require starting fresh with new policies and procedures and expensive changes
c. Help create financial success, customer loyalty, community support, and employee satisfaction. Note: practice question from AAPC CPCO Ch1
What does the OIG Compliance Program Guidance acknowledge patient care as? a. Irrelevant to having an effective compliance program. They are not related. b. Important, but should not get in the way of implementing all seven recommended elements. c. Providers should put patients first in a compliance program. d. The main reason offices fail to implement compliance programs in the first place.
c. Providers should put patients first in a compliance program. In order to improve patient care, you need to put patients first! Note: practice question from AAPC CPCO Ch2
Regarding Compliance Program effectiveness, which of the following is NOT a true statement: a. Compliance programs must be audited and monitored on an ongoing basis so vulnerabilities can be identified and fixed b. Federal Sentencing Guideline call for the use of monitoring and auditing systems c. Testing compliance program doesn't give you assurance that everyone is aware of the risk areas that require priority attention d. Can be done through forming a compliance committee with key line and staff members
c. Testing compliance program doesn't give you assurance that everyone is aware of the risk areas that require priority attention
The annual OIG work plan is a document that outlines the OIG's annual: a. staffing needs b. budget plans c. investigation ideas d. education agenda
c. investigation ideas
Which of the following is an absolute necessity in order to have a successful Compliance Program? a. continuous training and improvements b. effective reporting path c. non-retaliation for whistleblowers d. reliable and equal discipline
c. non-retaliation for whistleblowers
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
What term would be used for actions that, either directly or indirectly, results in unnecessary costs to the Medicare program, for instance, improper payments for services not medically necessary? a. Fraud b. Mistake c. Waste d. Abuse
d. Abuse Abuse - Abuse is similar to fraud, except that the investigator cannot establish the act was committed knowingly, willfully, and intentionally. The difference between fraud and abuse is the individual's intent. Fraud - knowingly/intentionally. Waste - misuse of resources. Note: practice question from AAPC CPCO Ch1
The compliance plan should be reviewed: a. When the OIG issues new guidelines b. When a new regulation is passed c. At least annually d. All of the above
d. All of the above
Why is a Corporate Compliance Program important? a. Helps ensure strict compliance with all required laws and regulations b. Helps prevent and detect fraudulent behavior c. Helps staff provide the highest quality of care to members d. All of the answers
d. All of the answers
Which statement is TRUE regarding compliance programs? a. Compliance programs are not mandated by law. b. Compliance programs are only effective after the baseline audit has been performed and policies written. c. Compliance programs are only required by law for healthcare entities that have more than $500,000 in annual revenue. d. Compliance programs are considered more dangerous if they are developed but not implemented.
d. Compliance programs are considered more dangerous if they are developed but not implemented. The only thing worse than not having a Compliance Program is to have a Compliance Program that is not implemented. (same with P&Ps) Note: practice question from AAPC CPCO Ch2
In case you become aware that the person has been bribed to make a choice, what would you do? a. Make him give you half the money b. Blackmail him c. Do nothing d. Contact the relevant authority
d. Contact the relevant authority
Which government department is comprised of thousands of employees who enforce the nation's federal criminal laws and help develop and implement criminal law policies? a. Office of Inspector General b. Centers for Medicare & Medicaid Services c. Healthcare Lawyers Association d. Department of Justice
d. Department of Justice OIG combats FWA in Medicare, Medicaid and HHS Programs; CMS administers the nation's major healthcare programs including Medicare, Medicaid, and CHIP to eliminate FWA; HLA is an edu org (not a gov department). Note: practice question from AAPC CPCO Ch1
Which federal government department is the OIG not responsible for overseeing? a. Centers for Medicare & Medicaid Services b. Centers for Disease Control and Prevention c. U.S. Food & Drug Administration d. Drug Enforcement Agency
d. Drug Enforcement Agency DEA is overseen by or an agency under DOJ. Note: practice question from AAPC CPCO Ch1
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. Risk Tolerance - represents the specific maximum risk that a organization is willing to take for each type of risk. Based on your Risk Tolerance threshold, your Inherent and Residual Risks levels are determined: Inherent Risk - amount of risk that exists in the absence of controls (risk organization faces before implementing any countermeasures) Residual Risk - amount of risk that remains after controls are accounted for (risk that remains after organization has taken proper precautions)
Fraud, waste, and abuse are all areas that must be controlled when providing services to beneficiaries. Which statement is TRUE regarding fraudulent billing? a. A series of errors is considered fraudulent billing. b. Fraudulent billing is only an issue if the erroneous billing is identified and not resolved. c. Fraudulent billing only occurs when refunds are not issued in a timely manner. d. Fraudulent billing is a willful act with intent to receive payment for services not rendered.
d. Fraudulent billing is a willful act with intent to receive payment for services not rendered. Note: practice question from AAPC CPCO Ch2
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)
Which entity below could not bill for medically unnecessary services? a. Hospitals b. Physicians c. Ancillary providers d. Patients
d. Patients Note: practice question from AAPC CPCO Ch1
Because of the changing nature of healthcare regulation, which statement is TRUE regarding updating the compliance program? a. The compliance program should only be updated annually to ensure all the changed regulations are captured. b. The compliance program should be updated biannually. c. Hiring a consultant to review the program for accuracy is necessary. d. The compliance program should be continually a work in progress.
d. The compliance program should be continually a work in progress. Note: practice question from AAPC CPCO Ch2
There is no established template for documenting compliance risks. Each organization should develop a Risk Assessment that fits its risk profile. The components that are commonly used throughout the industry are as follows EXCEPT: a. Risk Assessment b. Measuring key risk indicators c. Identifying key performance indicators d. Training the leadership of compliance regulation program
d. Training the leadership of compliance regulation program Ref. ABA CRCM (certified regulatory compliance manager)
Compliance professionals have a duty to keep senior management and the board appraised of the state of compliance through which of the following: a. self-monitoring and audit results b. proactive compliance controls c. timely and accurate regulatory/compliance reporting d. all of the above
d. all of the above ref. ABA CRCM (certified regulatory compliance manager)
Examples of current Compliance activities in many organizations
• Equal Employment Opportunity Commission (EEOC) • Employee Retirement Income Security Act (ERISA) • Wage and Hour Rule • Occupational Safety and health Administration (OSHA) • Nuclear Regulatory Commission • Conditions of Participation • Joint Commission on Accreditation of Healthcare Organization (JCAHO) • Research compliance
Benefits of Compliance Programs. List a few
• Safeguards organization legal responsibility to abide by applicable laws and regulations • Demonstrate organization's commitment to good corporate conduct • Provide a more accurate view of employee and contractor behavior relating to fraud and abuse • Identify and prevent criminal and unethical conduct • Improve the quality of patient care • Create a centralized source of info on healthcare regulations • Develop a methodology to encourage employees to report potential problem • Develop procedures that allow the prompt and through investigation of alleged misconduct • Initiate immediate and appropriate corrective action • Reduce organization remedies, such as program exclusion Ref: OIG CPG for Hospitals