CPCO CHAPTER #3 - EXAM Q&A
What law(s) does not require that nursing facilities conduct state or Federal FBI
Bureau of Investigation criminal background checks?
False Claims law
Federal law
Federal and state laws
State law - ANSWER-Federal law
Federal law does not require that nursing facilities conduct state or Federal Bureau
of Investigation FBI criminal background checks. State laws may, however. It is
important to confirm both sources for applicable laws.
Why should compliance officers have set disciplinary policies for non-compliance?
Employees need rules to follow.
Employees should know the consequences for non-compliance of set policies.
Employees should know what is expected of them.
Employees need to understand policies set in place. - ANSWER-Employees should
know the consequences for non-compliance of set policies.
There should be clear communication of what is expected of employees and equally
clear communication of the consequences for not following written policies.
Tim is the Compliance Officer for a billing company. The CEO wants to know, in
addition to policies & procedures, what other item is important for third parties to
integrate into their compliance program. What should Tim's response be?
The compliance plan should be written to a national level and include federal health
insurance program guidelines only.
The compliance plan should be written to state level and include state health
insurance program guidelines only.
The compliance plan should be written to a local level and include local regulations
only.
The compliance plan should include regulations that affect the billing company,
including federal and state statutes, regulations, and health insurance guidelines. -
ANSWER-The compliance plan should include regulations that affect the billing
company, including federal and state statutes, regulations, and health insurance
guidelines.
Besides policies & procedures, third parties should integrate federal and state
statutes, regulations, and health insurance guidelines into their compliance program.
Which factor is NOT considered in the OIG Work Plan?
Mandatory requirements for OIG reviews, as set forth in laws, regulations, or other
directives.
Requests made or concerns raised by Congress, HHS management, or the Office of
Management and Budget.
Top management and performance challenges facing HHS.
Inconvenience to the healthcare industry. - ANSWER-Inconvenience to the
healthcare industry.
The OIG Work Plan considers a number of factors including: Mandatory
requirements for OIG reviews, as set forth in laws, regulations, or other directives;
requests made or concerns raised by Congress, HHS management, or the Office of
, Management and Budget; top management and performance challenges facing
HHS; work performed by partner organizations; management's actions to implement
our recommendations from previous reviews; and timeliness.
As the new Compliance Officer for XYZ Billing Company, when should Tim start a
compliance program for the third party healthcare company?
Within the next few years because it is not a requirement
Now, to be proactive
Within the next few years because it's always best to be reactive with compliance
Tim should wait and determine how many fraud violations occur within the next year
before creating a compliance program. - ANSWER-Now, to be proactive
The time is right now for third-party healthcare companies to implement strong,
compliance programs.
Kim is the Compliance Officer at ABC Hospital. A provider asks her if Medicare pays
for all tests ordered by providers. Based on the OIG compliance guidance, how
should Kim respond?
Yes, Medicare will pay for tests as long as the physician believes it is appropriate.
No, Medicare only pays for preventive screening tests.
No, the tests must be reasonable and necessary to diagnose or treat a patient's
medical condition.
Yes, as long as the tests are ordered by a provider with an NPI. - ANSWER-No, the
tests must be reasonable and necessary to diagnose or treat a patient's medical
condition.
Physicians can order any tests they believe are appropriate; however, Medicare will
only pay for those tests which are covered, reasonable and medically necessary.
Third party billing companies should have policies and procedures for addressing
risk areas resulting from internal audits according to the OIG. Which risk area does
this include?
Adherence to MGMA benchmarks
Employee turnover
Marketing services
Tax status - ANSWER-Marketing services
Billing company incentives that violate the Anti-Kickback Statute or other similar
federal or state statutes or regulations - For billing companies that provide marketing
services, percentage arrangements may implicate the anti-kickback statute.
When a provider believes that Medicare will not cover the service, what must the
provider have signed by the patient prior to the service?
A DME form
An ABN form
Nothing when a signature is on file
A promise to pay form - ANSWER-An ABN form
Use of Advance Beneficiary Notices (ABNs)—All providers and staff, including
clinical laboratories, need to understand the proper use of ABNs. Important items
include, but are not limited to:• Ensuring that the ABN is presented to the patient
before the service is provided and providing an estimate of possible patient out-of-
pocket expenses due to test not being covered by CMS• Using the most up-to-date
CMS designated form• Never asking the beneficiary to sign a blank ABN• Used only
What law(s) does not require that nursing facilities conduct state or Federal FBI
Bureau of Investigation criminal background checks?
False Claims law
Federal law
Federal and state laws
State law - ANSWER-Federal law
Federal law does not require that nursing facilities conduct state or Federal Bureau
of Investigation FBI criminal background checks. State laws may, however. It is
important to confirm both sources for applicable laws.
Why should compliance officers have set disciplinary policies for non-compliance?
Employees need rules to follow.
Employees should know the consequences for non-compliance of set policies.
Employees should know what is expected of them.
Employees need to understand policies set in place. - ANSWER-Employees should
know the consequences for non-compliance of set policies.
There should be clear communication of what is expected of employees and equally
clear communication of the consequences for not following written policies.
Tim is the Compliance Officer for a billing company. The CEO wants to know, in
addition to policies & procedures, what other item is important for third parties to
integrate into their compliance program. What should Tim's response be?
The compliance plan should be written to a national level and include federal health
insurance program guidelines only.
The compliance plan should be written to state level and include state health
insurance program guidelines only.
The compliance plan should be written to a local level and include local regulations
only.
The compliance plan should include regulations that affect the billing company,
including federal and state statutes, regulations, and health insurance guidelines. -
ANSWER-The compliance plan should include regulations that affect the billing
company, including federal and state statutes, regulations, and health insurance
guidelines.
Besides policies & procedures, third parties should integrate federal and state
statutes, regulations, and health insurance guidelines into their compliance program.
Which factor is NOT considered in the OIG Work Plan?
Mandatory requirements for OIG reviews, as set forth in laws, regulations, or other
directives.
Requests made or concerns raised by Congress, HHS management, or the Office of
Management and Budget.
Top management and performance challenges facing HHS.
Inconvenience to the healthcare industry. - ANSWER-Inconvenience to the
healthcare industry.
The OIG Work Plan considers a number of factors including: Mandatory
requirements for OIG reviews, as set forth in laws, regulations, or other directives;
requests made or concerns raised by Congress, HHS management, or the Office of
, Management and Budget; top management and performance challenges facing
HHS; work performed by partner organizations; management's actions to implement
our recommendations from previous reviews; and timeliness.
As the new Compliance Officer for XYZ Billing Company, when should Tim start a
compliance program for the third party healthcare company?
Within the next few years because it is not a requirement
Now, to be proactive
Within the next few years because it's always best to be reactive with compliance
Tim should wait and determine how many fraud violations occur within the next year
before creating a compliance program. - ANSWER-Now, to be proactive
The time is right now for third-party healthcare companies to implement strong,
compliance programs.
Kim is the Compliance Officer at ABC Hospital. A provider asks her if Medicare pays
for all tests ordered by providers. Based on the OIG compliance guidance, how
should Kim respond?
Yes, Medicare will pay for tests as long as the physician believes it is appropriate.
No, Medicare only pays for preventive screening tests.
No, the tests must be reasonable and necessary to diagnose or treat a patient's
medical condition.
Yes, as long as the tests are ordered by a provider with an NPI. - ANSWER-No, the
tests must be reasonable and necessary to diagnose or treat a patient's medical
condition.
Physicians can order any tests they believe are appropriate; however, Medicare will
only pay for those tests which are covered, reasonable and medically necessary.
Third party billing companies should have policies and procedures for addressing
risk areas resulting from internal audits according to the OIG. Which risk area does
this include?
Adherence to MGMA benchmarks
Employee turnover
Marketing services
Tax status - ANSWER-Marketing services
Billing company incentives that violate the Anti-Kickback Statute or other similar
federal or state statutes or regulations - For billing companies that provide marketing
services, percentage arrangements may implicate the anti-kickback statute.
When a provider believes that Medicare will not cover the service, what must the
provider have signed by the patient prior to the service?
A DME form
An ABN form
Nothing when a signature is on file
A promise to pay form - ANSWER-An ABN form
Use of Advance Beneficiary Notices (ABNs)—All providers and staff, including
clinical laboratories, need to understand the proper use of ABNs. Important items
include, but are not limited to:• Ensuring that the ABN is presented to the patient
before the service is provided and providing an estimate of possible patient out-of-
pocket expenses due to test not being covered by CMS• Using the most up-to-date
CMS designated form• Never asking the beneficiary to sign a blank ABN• Used only
