Corporate Compliance Programs
Questions and Answers.
Corporate Compliance Program(CCP) - Answer a formal, organizational-specific, and
organization-wide initiative designed to uncover, prevent, and eliminate inappropriate activity in
your health organization
fraud and abuse - Answer with a CCP a facility will be able to detect?
Benefits of a CCP - Answer -demonstrate commitment
-provide accurate view of behavior relating to fraud and abuse
-ID & prevent criminal & unethical conduct
-improve quality of patient care
-create centralized source
-develop a methodology to encourage reporting
-develop procedures that allow investigation
--immediate & appropriate corrective action
-early detection and reporting
OIG model - Answer how is a CCP made
7 - Answer how many elements are there for an effective compliance program (billing should
be one)
Model Compliance Plans - Answer a set of guidelines (ready-made program) that is intended
to assist providers in developing effective internal controls to assure regulatory adherence
Elements of a Compliance Plan - Answer -written policies and procedures
-designation of a compliance officer and compliance committee
-conducting training and education
-developing effective lines of communication
-enforcing standards
-auditing and monitoring
-responding to detected offenses and developing corrective action initiatives
, written policies and procedures - Answer -should include risk areas of a hospital and
developed under the direction of the chief compliance officer and committee and should be
provided to all employees affected by the policies
Should also include:
medical necessity
anti-kickback /self-referral concerns
bad debts
credit balances
retention of records
compliance as an element of a performance plan
standards of conduct
claims development and submission procedures - Answer areas included int he policies and
procedures
standards of conduct - Answer part of policies and procedures that includes risk areas like
billing, upcoding(CPT), MS-DRG, creep, and etc
claims development and submission procedures - Answer part of p&p that should reflect and
reinforce current federal and state statues and regulations regarding the submission of claims
and Medicare cost reports
claims development and submission procedures - Answer -provides proper and timely
documentation
-claims should be submitted only when documentation supports claims
-health records are organized in legible form
-diagnoses and procedures reported should be based on health record documentation
-should comply with Medicare billing
-take steps to ensure that all claims for lab testing are accurate and ID the services ordered
-should ensure that requirements for PATH are met
-procedures should be in place to ensure compliance with applicable statues regarding cost
reporting
focal point for compliance activities - Answer compliance officers serves as ?
Compliance Committee - Answer analyze the organization's industry environment, the legal
requirements with which it must comply and specific risk areas
Questions and Answers.
Corporate Compliance Program(CCP) - Answer a formal, organizational-specific, and
organization-wide initiative designed to uncover, prevent, and eliminate inappropriate activity in
your health organization
fraud and abuse - Answer with a CCP a facility will be able to detect?
Benefits of a CCP - Answer -demonstrate commitment
-provide accurate view of behavior relating to fraud and abuse
-ID & prevent criminal & unethical conduct
-improve quality of patient care
-create centralized source
-develop a methodology to encourage reporting
-develop procedures that allow investigation
--immediate & appropriate corrective action
-early detection and reporting
OIG model - Answer how is a CCP made
7 - Answer how many elements are there for an effective compliance program (billing should
be one)
Model Compliance Plans - Answer a set of guidelines (ready-made program) that is intended
to assist providers in developing effective internal controls to assure regulatory adherence
Elements of a Compliance Plan - Answer -written policies and procedures
-designation of a compliance officer and compliance committee
-conducting training and education
-developing effective lines of communication
-enforcing standards
-auditing and monitoring
-responding to detected offenses and developing corrective action initiatives
, written policies and procedures - Answer -should include risk areas of a hospital and
developed under the direction of the chief compliance officer and committee and should be
provided to all employees affected by the policies
Should also include:
medical necessity
anti-kickback /self-referral concerns
bad debts
credit balances
retention of records
compliance as an element of a performance plan
standards of conduct
claims development and submission procedures - Answer areas included int he policies and
procedures
standards of conduct - Answer part of policies and procedures that includes risk areas like
billing, upcoding(CPT), MS-DRG, creep, and etc
claims development and submission procedures - Answer part of p&p that should reflect and
reinforce current federal and state statues and regulations regarding the submission of claims
and Medicare cost reports
claims development and submission procedures - Answer -provides proper and timely
documentation
-claims should be submitted only when documentation supports claims
-health records are organized in legible form
-diagnoses and procedures reported should be based on health record documentation
-should comply with Medicare billing
-take steps to ensure that all claims for lab testing are accurate and ID the services ordered
-should ensure that requirements for PATH are met
-procedures should be in place to ensure compliance with applicable statues regarding cost
reporting
focal point for compliance activities - Answer compliance officers serves as ?
Compliance Committee - Answer analyze the organization's industry environment, the legal
requirements with which it must comply and specific risk areas
