Certification Exam Study Guide 2026
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HCF Investigator Assumptions -ANSWER✅✅✅*General knowledge of the Health care
Delivery System
*Health plan policy and procedures relative to the delivery of services
*Able to identify Red Flags, behaviors & indicators of health care fraud schemes
Know applicable federal & state laws related to health care fraud
*Law enforcement & regulatory agencies that have oversight responsibilities for HCF
*Local & regional investigative groups that have similar interests
Fraud, by it's very nature, is decptive. -ANSWER✅✅✅As such, nobody really knows
what the impact and cost of fraud is. However there are some common industry
estimates
Conservative US Healthcare spending in 2015 was $3.2Trillion
Conservative estimate of fraud is 3-5% (means tens of billions of dollars each year)
Estimate of $96 billion -> $320 Billion / year (if we estimate between 5% and 10%)
Anatomy of an investigation -ANSWER✅✅✅Each fraud case is unique, however,
under the surface of the specific schemes, all HCF investigatons have a common
structure, or process.
Anatomy of an investigation - 1) Detection -ANSWER✅✅✅The process of uncovering
potential fraud waste and abuse utilizing human and technical resources and
techniques
,Anatomy of an investigation - 2) Assessment -ANSWER✅✅✅The primary objective of
the assessment phase is to establish PREDICATION for the continued investigation
Predication -ANSWER✅✅✅to proclaim; declare; assert
Anatomy of an Investigation - 3) Investigative Strategy -ANSWER✅✅✅Devoloping an
investigative plan to identify and gather evidence to support the statuatory elements to
prove
Anatomy of an investigation - 4) Case Investigation -ANSWER✅✅✅The process of
utilizing legal and appropriate techniques to prove or disprove the allegations
Antomy of an investigation - 5) Report Writing -ANSWER✅✅✅The process of
documenting the investigative tasks in a final comprehensive investigative report.
Anatomy of an investigation - 6) Determination of action -ANSWER✅✅✅Evaluating the
totality of the documented case facts to determine the best action to resolve the
investigation.
Anatomy of an investigation - 1) Detection - Case Management -
ANSWER✅✅✅Includes:
*Behavioral & Pattern Analysis
Emergings Schemes - being familiar enough with new schemes to be able to recognize
that something is "off"
"Hot Spots": Know where the "hot-spots" are in the country
The top Red Flags for Health Care Fraud in 2018 -ANSWER✅✅✅1) Opioids: 12
hotspots (Florida, Tennessee, Alaska, Texas); focus investigations and prosecuting "pill
mills" (pharmacies that improperly divert and dispense Rx opioid and other opioid-
related issues)
2) Home Health Care:
3) Use of data:
4) Robosigning: Involves a doctor blindly writing Rx or order that authorize care without
first making an individualized determination of medical necessity.
5) Kickbacks:
, 6) Upcoding: The improper practice of a medical professional billing for a more
expensive medical service than was actually provided to the patient. The DOJ focuses
on service-based, location-based or time-based upcoding
7) Billing for unqualified workers:
Upcoding -ANSWER✅✅✅The DOJ focuses on service-based, location-based and/or
time-based upcoding
Service-based upcoding: A doctor may perform a simple check-up, but bill for a more
extensive examination or even a surgery
Location-based upcoding: Billing for a procedure that occurred in an operating room
when, in fact, it had occurred in a less-expensive setting such as an office
Time-based-upcoding: When a doctor sees a patient for 10-minutes, but bills for a more
expensive 45-minute consultation.
Robosigning -ANSWER✅✅✅Involves a doctor blindly writing Rx or order that
authorize care without first making an individualized determination of medical necessity.
(Opioids; home health care; power wheelchairs; sleep studies) **The authorizing
medical professional must make a case-by-case analysis of medical necessity before
ordering drugs or services. And importantly, the company should be able to re-create
and affirmatively prove this process was actually used
Billing for unqualified workers -ANSWER✅✅✅Unqualified or unlicensed workers.
Clinics using a less qualified worker (such as a P.A.) to render services to a patient, but
the services are billed as if they were provided by a medical professional with a higher
reimbursement rate.
Or billing of lower-level medical professionals (physical therapy assistants) who are
supposed to be supervised by a higher-level medical professional (a physical therapist)
but operate without supervision
Kickbacks -ANSWER✅✅✅The payment of kickbacks or other illicit benefits to patients,
recruiters who procure such patients, or even to doctors or other medical professionals..
Look for patients who are "frequent-flyers", or who present with a number of different
ailments over time that seem implausible
Use of data in uncovering fraud -ANSWER✅✅✅Identifying geographic hotbeds for
fraud (top biller in the country for a specific code is not a good thing);
looking for a disconnect between the size of the medical practice and the volume of
billing;