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There is no requirement to hire a consultant or counsel, but such assistance may be beneficial during
certain phases of development and/or if issues arise.
There is no requirement that outside consultants or legal counsel be involved in a Compliance Program.
However, during certain phases of program development and implementation, both consultants and
legal counsel may be beneficial. - CORRECT ANSWERS When is an outside consultant and/or
legal counsel necessary?
Only when an overpayment is identified.
There is no requirement to hire a consultant or counsel, but such assistance may be beneficial during
certain phases of development and/or if issues arise.
In the beginning of plan development.
Never.
when the expenses are a result of the imposition of a penalty
A CIA is a penalty imposed upon the organization and, as with any other governmental penalty, the
expense of the development, implementation, and maintenance of this program cannot be included as a
deductible expense to the organization. - CORRECT ANSWERS Most expenses related to
developing and implementing a compliance program are considered the cost of doing business and are
tax-deductible for the organization. Which, of the following, is NOT tax-deductible?
• when the expense costs are more than the national average
• when the expenses are a result of the imposition of a penalty
• for the annual maintenance of the program
• except the salary of the Compliance Officer
,Implementation
Without adherence to the stated goals and objectives, there is no purpose to the document itself.
Having all the components of a compliance program in place will not matter if they are not
implemented. - CORRECT ANSWERS What is the most important aspect of a Compliance
Program?
• Training
• Implementation
• Development
• Discipline
Fraudulent billing is a willful act with the intent to receive payment for services not rendered.
Fraudulent billing is willful and is undertaken with the intent to receive payment for services not
legitimately rendered. - CORRECT ANSWERS Fraud, waste, and abuse are all areas that must be
controlled when providing services to beneficiaries. Which statement is TRUE regarding fraudulent
billing?
• A series of errors is considered fraudulent billing.
• Fraudulent billing is only an issue if the erroneous billing is identified and not resolved.
• Fraudulent billing only occurs when refunds are not issued in a timely manner.
• Fraudulent billing is a willful act with the intent to receive payment for services not rendered.
The compliance program should be continually a work in progress.
The program should be monitored and updated at least annually, and more likely more often, to provide
for up-to-date compliance. - CORRECT ANSWERS Because of the changing nature of healthcare
regulation, which statement is TRUE regarding the compliance program?
, • The compliance program should only be updated annually to ensure all the changed regulations are
captured.
• The compliance program should be updated biannually.
• Hiring a consultant to review the program for accuracy is necessary.
• The compliance program should be continually a work in progress.
Compliance programs are considered more dangerous if they are developed but not implemented.
The only thing worse than not having a Compliance Program is to have a Compliance Program that is not
implemented. - CORRECT ANSWERS Which statement is true regarding compliance programs?
• Compliance programs are not mandated by law.
• Compliance programs are only effective after the baseline audit has been performed and policies
written.
• Compliance programs are only required by law for healthcare entities that have more than $500,000 in
annual revenue.
• Compliance programs are considered more dangerous if they are developed but not implemented.
It shows that the practice is making a good faith effort to be compliant.
Compliance programs provide a further benefit by showing that the physician practice is making a good
faith effort to submit claims appropriately. - CORRECT ANSWERS There are many benefits of
having an effective compliance program. Which, of the below, is one such benefit?
• It shows that the practice is making a good faith effort to be compliant.
• It provides a means to cover errors until they can be fixed.