100% Correct (2023/ 2024)
QUESTION
The CMP fine amounts are increased annually based on what act?
a. Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015
b. Medicare Modernization Act of 2003
c. Health Insurance Portability and Accountability Act of 1996
d. Deficit Reduction Act of 2005
Answer:
a. Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015.
The Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015 (the 2015 Act)
(Public Law 114-74, Sec. 701), which further amended the Federal Civil Penalties Inflation
Adjustment Act of 1990 (the Inflation Adjustment Act) (Public Law 101-410) was enacted on
November 2, 2015. The 2015 Act requires agencies to adjust the level of applicable CMPs with
an initial "catch-up" adjustment, through interim final rulemaking (IFR); and, make subsequent
annual adjustments for inflation. The Office of Management and Budget (OMB) publishes the
adjustment multiplier based on the Consumer Price Index for All Urban Consumers (CPI-U).
The catch-up adjustment was published in 2016. The annual adjustments are to be published in
the Federal Register no later than January 15 of each calendar year.
Note: practice question from AAPC CPCO Ch4
QUESTION
A physician who fails to respond to an emergency situation when she is assigned as the on-call
physician:
a. May be in violation of EMTALA, and may subject herself and the hospital to a penalty.
b. May be in violation of EMTALA because she should be on the hospital campus at all times
when she is on call.
c. Is not in violation of EMTALA because she is only on call.
d. Is not in violation of EMTALA because EMTALA only relates to hospitals.
Answer:
a. May be in violation of EMTALA, and may subject herself and the hospital to a penalty.
Section 1395dd(d)(1)(C) imposes a penalty on a physician who fails to respond to an emergency
situation when he or she is assigned as the on-call physician. A physician who is on call and fails
,or refuses to appear after being called by another physician may be subject to a penalty under the
statute or may subject the hospital to a penalty under the statute.
Note: practice question from AAPC CPCO Ch6
QUESTION
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?
Answer:
b. Did you ever observe anything that made you feel uncomfortable?
QUESTION
A component of the DOL that develops and administers standards relating to the well-being of
works at the job site, develops and issues regulations in this area, conducts investigations and
inspections to determine status of compliance with safety and health standards and regulations,
and issues citations and proposes penalties for noncompliance
Answer:
Occupational Safety and Health Administration (OSHA)
QUESTION
You are performing a regular inventory of the controlled substances in the pharmacy. You
discover a minor inventory discrepancy. What should you do?
A. Call the local law enforcement
B. Perform another review
C. Contact your compliance department
D. Discuss your concerns with your supervisor
E. Follow your pharmacies procedures
Answer:
E. Follow your pharmacies procedures
,Since this is a minor discrepancy in the inventory you are not required to notify the DEA. You
should follow your pharmacies procedures to determine the next steps.
QUESTION
You are in charge of payment of claims submitted from providers. You notice a certain
diagnostic provider ("Doe Diagnostics") has requested a substantial payment for a large number
of members. Many of these claims are for a certain procedure. You review the same type of
procedure for other diagnostic providers and realize that Doe Diagnostics' claims far exceed any
other provider that you reviewed. What do you do?
A. Call Doe Diagnostics and request additional information for the claims
B. Consult with your immediate supervisor or Compliance Department for next steps
C. Reject the claims
D. Pay the claims
Answer:
B. Consult with your immediate supervisor for next steps or contact the compliance department
(via compliance hotline, Special Investigations Unit [SIU], or other mechanism).
You do not want to contact the provider. This may jeopardize an investigation. Nor do you want
to pay or reject the claims until further discussions with your supervisor or the compliance
department have occurred, including whether additional documentation is necessary.
QUESTION
Related to Corporate Integrity Agreements with the government, what is an IRO and what are the
details of how it works? Choose 2 answers.
a. Independent Reorganization Operation.
b. They do the auditing required by a CIA.
c. The OIG hires them.
d. They need to be fair and unbiased and can't have a financial relationship with the hospital.
Answer:
b. They do the auditing required by a CIA.
d. They need to be fair and unbiased and can't have a financial relationship with the hospital.
Explanation: IROs need to meet criteria and follow the AICPA and SEC guidance (unbiased
judgement, honest neutrality, and demonstrate independence among other requirements)
, QUESTION
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.
Answer:
a. c. d.
QUESTION
Related to Legal Doctrines for Protection from Disclosure to protect certain documents during
the course of discovery.
What is the work product doctrine?
a. Ensures that attorney documentation is accessible to the hospital.
b. Ensures that attorney documentation is accessible to the OIG.
c. Protects attorney documents that were prepared for litigation purposes.
d. Allows the hospital to protect documents sent to the attorney.
Answer:
c. Protects attorney documents that were prepared for litigation purposes.
Differs from attorney-client privilege (ACP) in that it protects only documents from discovery
including interviews, memos, correspondence, notes and briefs, which evidence "mental
impressions, conclusions, opinions or legal theories of any attorney.
Documents must have been prepared in anticipation of litigation or in anticipation of a disclosure
to the government.
QUESTION
A common reporting system, administered in house or by outside consultants, giving anonymous
telephone access to employees seeking to report possible instances of wrongdoing
Answer:
Hotline or Helpline