Study teStbAnk (lAteSt 2026/2027
ReleASe) – Q&A
True or False:
The ACA requires that all providers adopt a compliance plan as a condition of
enrollment with Medicare, Medicaid, and Children's Health Insurance Program
(CHIP). - Answer-True
ref. ACA section 6102
According to HHS-OIG - what are three important reasons for proper
documentation in Compliance? (hint: protections) - Answer-1.Protect our
programs
2.Protect your patients
3.Protect the Provider
https://oig.hhs.gov/newsroom/podcasts/2011/heat/heat09-
trans.asp#:~:text=Proper%20documentation%2C%20both%20in%20patients,to%2
0protect%20you%20the%20provider.
At which level of the Medicare Part A or Part B appeals process is the appeal
decision by the Office of Medicare Hearings and Appeals (OMHA)?
a. first level of appeal
,b. second level of appeal
c. third level of appeal
d. fourth level of appeal - Answer-c. . third level of appeal
Frist level - redetermination by Medicare contractor
Second level - reconsideration by Independent contractor
Third appeal - Administrative Law Judge (ALJ) hearing
Fourth appeal - review by Medicare Appeals Council
Fifth appeal - review in Federal District Court
https://www.hhs.gov/about/agencies/omha/the-appeals-process/index.html
What is the term called for an organization's commitment to compliance by
management, employees, and contractors. Statement should summarize ethical
behavior and legal principles under which the healthcare organization operates? -
Answer-Code of Conduct
In the course of an audit, you find that disciplinary actions against certain
physicians and high level executives for non-compliance in the organization have
been unfair and inconsistent with current policies & procedures. What is your first
course of action
.a. Work with legal counsel to enforce proper disciplinary actions
b. Get HR involved and recommend the use of progressive discipline policies
c. Immediately terminate these individuals
d. Get local and federal labor department involved for unfair discipline. - Answer-
b. Get HR involved and recommend the use of progressive discipline policies
,OIG recommends setting forth the degrees of disciplinary actions. Progressive
discipline provides a structure and a set of discipline standards for
managers/supervisors to follow to ensure discipline is fair, equitable and
consistent.
Documentation - Answer-• A&M should be documented
• Findings should be shared with dept managers
• If activity is part of risk priority then compliance committee, senior leadership
and board when necessary
• OIG calls for written evaluation to be presented to CEO, governing body,
committee annually
Non-retaliation in compliance - what is important to state in this policy: - Answer-
For any reporting method to be effective, employees must accept that there will
be no retaliation or retribution for coming forward.
The concept of non-retaliation is fundamental to the compliance program, and a
clearly stated policy regarding non-retribution is the first step.
• anonymous reporting and,
• no retaliation or retribution for bringing forth problems/concerns
Place to start with Enforcement is: - Answer-Standards of conduct and P&Ps
For Enforcement and Disciplinary Actions, Policies should include: - Answer-1.
non-compliant consequences
2. employees duty to report non-compliance
3. list parties responsible for appropriate action
, 4. outline of disciplinary actions or procedures
5. promise that discipline will be fair and consistent
New Employee Policy - three checks OIG recommends to do/perform: - Answer-
OIG recommends: perform background checks, reference checks, and exclusion
list checks
Which two main documents become tools to build compliance program? -
Answer-Code of Conduct and P&Ps
You are the new Compliance Officer, hired after ABC Hospital reorganized and
decided that the General Counsel should no longer also serve in that role. Upon
review of the Code of Conduct (CoC), you find that it is written using lots of legal
jargon. What action do you take:
a. Keep CoC as it is.
b. Pull a sample off the internet and insert hospital name to save time as it was
most likely written by experts.
c. Rewrite the CoC in plain and concise language tailored to the hospital so
employees can use a general guidance.
d. Rewrite the CoC with detailed restating hospital's P&Ps, and all laws and
regulations possible so that employees can't say they were not aware of
requirements. - Answer-c. Rewrite the CoC in plain and concise language tailored
to the hospital so employees can use a general guidance.
Explanation:
• CoC should be clear and concise language easy to understand, and should be
tailored to specific issues of the organization