CHC Compliance Program Administra on/ CHC EXAM:
Compliance Program Administra on 2 SETS COMPILED
WITH COMPLETE SOLUTION RATED A+ NEW EDITION
A compliance program at its most basic level would be: (think of the 1st CP element) - Ans A
set of internal policies and procedures that you put into place to help your organiza!on comply
with the law.
Before developing a Compliance Program, FIRST, conduct a ___ _______, then, NEXT, _____
risks to help you define the basis for what the compliance program should focus on for the next
year in its plan. - Ans risk assessment;
priori!ze
There is no established template for documen!ng compliance risks. Each organiza!on should
develop a Risk Assessment that fits its risk profile. The components that are commonly used
throughout the industry are as follows EXCEPT:
a. Risk Assessment
b. Measuring key risk indicators
c. Iden!fying key performance indicators
d. Training the leadership of compliance regula!on program - Ans d. Training the leadership of
compliance regula!on program
Ref. ABA CRCM (cer!fied regulatory compliance manager)
The compliance program should address plans to verify adherence to applicable laws and
regula!ons through:
a. ongoing monitoring to evaluate the program, self-monitoring and correc!ve ac!on
,b. self-monitoring
c. Periodic reviews
d. Ongoing monitoring to evaluate the program, self-monitoring and period reviews - Ans a.
ongoing monitoring to evaluate the program, self-monitoring and correc!ve ac!on
Ref. ABA CRCM (cer!fied regulatory compliance manager)
ABC Hospital is under a 5-year CIA with government-imposed requirements for development of
a Compliance Program and use of external auditor for periodic claim reviews. Which of the
following is TRUE:
a. Costs to mee!ng terms of the CIA are permi8ed to be included in the cost report like any
other opera!onal cost.
b. Because the hospital agreed to a se8lement and was not convicted for alleged viola!ons, the
Compliance Program is considered a voluntary program.
c. The government chooses and pays for the external auditors.
d. None of the above - Ans d. None of the above.
Explana!on:
• CIA-related costs CANNOT be included in the cost report.
• Government-imposed Compliance Program ARE NOT considered a voluntary program.
• Hospital is required to choose and pay for any auditors (with government review and right to
object)
Most expenses related to developing and implemen!ng a compliance program are considered
the cost of doing business and are tax deduc!ble for the organiza!on. Which of the following is
NOT tax deduc!ble?
a. When the expense costs are more than the na!onal average
b. When the expenses are a result of the imposi!on of a penalty
,c. The annual maintenance of the program
d. The salary of the compliance officer - Ans b. When the expenses are a result of the
imposi!on of a penalty.
CIA is a penalty imposed upon the organiza!on and, as with any other governmental penalty;
the expense of the development, implementa!on, and maintenance of this program cannot be
included as a deduc!ble expense to the organiza!on.
Note: prac!ce ques!on from AAPC CPCO Ch2
Sue works for ABC Family Physicians. The providers at this office ask her to research the
department that helps protect pa!ents from unfair treatment or discrimina!on. What
department or agency would that be?
a. Equality in Employment Agency
b. Office for Civil Rights
c. Department of Jus!ce
d. Office of Inspector General - Ans b. Office for Civil Rights (OCR)
DOL oversees employment discrimina!on;
DOJ enforces federal criminal law and implements criminal law policies;
OIG combats FWA in Medicare, Medicaid and HHS Programs.
Note: prac!ce ques!on from AAPC CPCO Ch1
Payers expect all providers to refund monies that are overpayments. By law, how long does the
provider have to refund overpayments once discovered?
a. A !mely manner, the specific number of days is not specified
b. 60 days aDer receipt of overpayment
c. 60 days aDer iden!fica!on of overpayment
d. 90 days aDer a request by the payer - Ans c. 60 days aDer iden!fica!on of overpayment
, Under Sec!on 6402 of the ACA, a provider must refund Medicare and Medicaid within 60 days
of iden!fying the overpayment. If an en!ty iden!fies billing mistakes or other non-compliance
with program rules leading to an overpayment, the en!ty must repay the overpayments to
Medicare and Medicaid to avoid False Claims Act liability.
Benefits of Compliance Programs. List a few - Ans • Safeguards organiza!on legal
responsibility to abide by applicable laws and regula!ons
• Demonstrate organiza!on's commitment to good corporate conduct
• Provide a more accurate view of employee and contractor behavior rela!ng to fraud and
abuse
• Iden!fy and prevent criminal and unethical conduct
• Improve the quality of pa!ent care
• Create a centralized source of info on healthcare regula!ons
• Develop a methodology to encourage employees to report poten!al problem
• Develop procedures that allow the prompt and through inves!ga!on of alleged misconduct
• Ini!ate immediate and appropriate correc!ve ac!on
• Reduce organiza!on remedies, such as program exclusion
Ref: OIG CPG for Hospitals
Which statement is TRUE regarding compliance programs?
a. Compliance programs are not mandated by law.
b. Compliance programs are only effec!ve aDer the baseline audit has been performed and
policies wri8en.
c. Compliance programs are only required by law for healthcare en!!es that have more than
$500,000 in annual revenue.
Compliance Program Administra on 2 SETS COMPILED
WITH COMPLETE SOLUTION RATED A+ NEW EDITION
A compliance program at its most basic level would be: (think of the 1st CP element) - Ans A
set of internal policies and procedures that you put into place to help your organiza!on comply
with the law.
Before developing a Compliance Program, FIRST, conduct a ___ _______, then, NEXT, _____
risks to help you define the basis for what the compliance program should focus on for the next
year in its plan. - Ans risk assessment;
priori!ze
There is no established template for documen!ng compliance risks. Each organiza!on should
develop a Risk Assessment that fits its risk profile. The components that are commonly used
throughout the industry are as follows EXCEPT:
a. Risk Assessment
b. Measuring key risk indicators
c. Iden!fying key performance indicators
d. Training the leadership of compliance regula!on program - Ans d. Training the leadership of
compliance regula!on program
Ref. ABA CRCM (cer!fied regulatory compliance manager)
The compliance program should address plans to verify adherence to applicable laws and
regula!ons through:
a. ongoing monitoring to evaluate the program, self-monitoring and correc!ve ac!on
,b. self-monitoring
c. Periodic reviews
d. Ongoing monitoring to evaluate the program, self-monitoring and period reviews - Ans a.
ongoing monitoring to evaluate the program, self-monitoring and correc!ve ac!on
Ref. ABA CRCM (cer!fied regulatory compliance manager)
ABC Hospital is under a 5-year CIA with government-imposed requirements for development of
a Compliance Program and use of external auditor for periodic claim reviews. Which of the
following is TRUE:
a. Costs to mee!ng terms of the CIA are permi8ed to be included in the cost report like any
other opera!onal cost.
b. Because the hospital agreed to a se8lement and was not convicted for alleged viola!ons, the
Compliance Program is considered a voluntary program.
c. The government chooses and pays for the external auditors.
d. None of the above - Ans d. None of the above.
Explana!on:
• CIA-related costs CANNOT be included in the cost report.
• Government-imposed Compliance Program ARE NOT considered a voluntary program.
• Hospital is required to choose and pay for any auditors (with government review and right to
object)
Most expenses related to developing and implemen!ng a compliance program are considered
the cost of doing business and are tax deduc!ble for the organiza!on. Which of the following is
NOT tax deduc!ble?
a. When the expense costs are more than the na!onal average
b. When the expenses are a result of the imposi!on of a penalty
,c. The annual maintenance of the program
d. The salary of the compliance officer - Ans b. When the expenses are a result of the
imposi!on of a penalty.
CIA is a penalty imposed upon the organiza!on and, as with any other governmental penalty;
the expense of the development, implementa!on, and maintenance of this program cannot be
included as a deduc!ble expense to the organiza!on.
Note: prac!ce ques!on from AAPC CPCO Ch2
Sue works for ABC Family Physicians. The providers at this office ask her to research the
department that helps protect pa!ents from unfair treatment or discrimina!on. What
department or agency would that be?
a. Equality in Employment Agency
b. Office for Civil Rights
c. Department of Jus!ce
d. Office of Inspector General - Ans b. Office for Civil Rights (OCR)
DOL oversees employment discrimina!on;
DOJ enforces federal criminal law and implements criminal law policies;
OIG combats FWA in Medicare, Medicaid and HHS Programs.
Note: prac!ce ques!on from AAPC CPCO Ch1
Payers expect all providers to refund monies that are overpayments. By law, how long does the
provider have to refund overpayments once discovered?
a. A !mely manner, the specific number of days is not specified
b. 60 days aDer receipt of overpayment
c. 60 days aDer iden!fica!on of overpayment
d. 90 days aDer a request by the payer - Ans c. 60 days aDer iden!fica!on of overpayment
, Under Sec!on 6402 of the ACA, a provider must refund Medicare and Medicaid within 60 days
of iden!fying the overpayment. If an en!ty iden!fies billing mistakes or other non-compliance
with program rules leading to an overpayment, the en!ty must repay the overpayments to
Medicare and Medicaid to avoid False Claims Act liability.
Benefits of Compliance Programs. List a few - Ans • Safeguards organiza!on legal
responsibility to abide by applicable laws and regula!ons
• Demonstrate organiza!on's commitment to good corporate conduct
• Provide a more accurate view of employee and contractor behavior rela!ng to fraud and
abuse
• Iden!fy and prevent criminal and unethical conduct
• Improve the quality of pa!ent care
• Create a centralized source of info on healthcare regula!ons
• Develop a methodology to encourage employees to report poten!al problem
• Develop procedures that allow the prompt and through inves!ga!on of alleged misconduct
• Ini!ate immediate and appropriate correc!ve ac!on
• Reduce organiza!on remedies, such as program exclusion
Ref: OIG CPG for Hospitals
Which statement is TRUE regarding compliance programs?
a. Compliance programs are not mandated by law.
b. Compliance programs are only effec!ve aDer the baseline audit has been performed and
policies wri8en.
c. Compliance programs are only required by law for healthcare en!!es that have more than
$500,000 in annual revenue.
