Graded A+
compliance program - -prevention, Act of 1996 (HIPAA) - -a criminal offense to
detection, collaboration, and enforcement submit claims based on incorrect codes or
medically unnecessary services, and government
has the power to exclude an organization from
Effective compliance program - -must be Medicare/caid and other govt programs.
an ongoing process and commitment to an
ethical way of conducting business
Balanced Budget Act of 1997 - -three
strikes and your out clause , requiring permanent
Office of Inspector General and Justice expulsion if found guilty of fraud a third time.
Department - -is responsible for enforcing
the rules and regulations under the Medicare and
Medicaid laws outline as part of the SSA by False Claims Act (FCA) - -empowers the
CMS. govt to investigate and bring civil action in fraud
cases. Implemented in Civil War to control price
gouging.
Benefits of compliance program addressed by
OIG - -safeguards the organizations' legal
responsibility to abide by applicable laws and Qui tam - -is a whistleblower who brings
regulations. the fraud to light.
Corporate Integrity Agreement (CIA) - - A whistleblower can receive a % of the govt's
government imposed compliance program total award - -15-25% if DOJ assumes the
case or 25-30% if DOJ declines
Why compliance programs are essential - -
prevent paybacks, probation, government To avoid lengthy and expensive litigation, an
designed programs, exclusion, reduce threat of organization can negotiate a ____________with
lawsuits from whistleblowers (qui tam). the govt admits no fault or liability but does
submit to a govt plan for corrective action. -
-CIA
OIG Top 10 reasons to implement a compliance
program - -demonstrates a strong
commitment to honesty and responsible Length of CIAs - -3-5 yrs with some lasting
corporate relations, reinforces employees sense up to 8 yrs
of right and wrong, fulfill legal duty to payers,
cost effective, more accurate view of what is
going on, quality of care to clients, provides 1984 Congress enacted Sentencing reform act
procedures to promptly correct misconduct, which includes FSG - -act designed to
mitigate any sanction imposed by government. correct inequities in federal sentencing and give
guidance for assessing fines and methods for
calculation of culpability score.
Health Insurance Portability and Accountability
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, Compliance 101 Test Questions with Verified Answers
Graded A+
seven basic elements, based on and expanding
The culpability score - -calculation of the upon the seven steps of the Federal Sentencing
degree of blame or guilt used to determine fines, Guidelines. Which of the following is not one of
restitution, forfeiture, and probation. the seven elements in the guidance for hospitals?
- -Terminating employees who have been
investigated and found to have committed prior
If an upper level employee has participated in or fraudulent acts
was willfully ignorant of an offense, - -the
likelihood of culpability score will be increased.
According to the text, which of the following are
"overlooked groups" when it comes to Standards
If an organization reports a violation promptly, - of Conduct/Policies and Procedures? (Choose all
-the culpability score may be mitigated. that apply) - -Suppliers
Vendors
Independent Contractors
An aggravating factor in FSG - -is that the
organization has had a repeated offense
According to the text, the "lion's share of fraud
and abuse offenses is attributed to": - -
A mitigating factor for FSG - -is that the Documentation and billing irregularities
organization cooperated with the govt
investigators
: The practice of using a billing code that provides
a higher reimbursement rate than the billing code
2010 FSG amendment changes includes way to that actually reflects the service furnished is
further reduce culpability scores: - -C&E known as: - -Upcoding
program has responsibility- to report directly to
board or appropriate subgroup, to detected
offense before external discovery, prompt The main focus of the Compliance Officer should
reporting, no one with OP responsibility be all of the following, except: - -
participated in, condoned, or was willfully Administering discipline for those individuals that
ignorant of the offense. do not adhere to policies and procedures;
Which of the following is an aggravating factor to The Health Care Compliance Association has
a culpability score in the Federal Sentencing prepared and published the Code of Ethics for
Commission released "Chapter 8 Part B - Health Care Compliance Professionals. This
Remedying Harm from Criminal Conduct, and document addresses three principals, which are
Effective Compliance and Ethics Program?" - broad standards of an aspiration and inspirational
-If the violation was a repeat offense; nature. They include: - -Obligation to the
Public, Obligation to the employing organization,
and obligation to the profession.
The OIG believes every effective compliance
Program begins with a formal commitment to
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