CPCO Certification Exam: Questions With Expert
Solutions
According the Social Security Act, Sec. 1877. [42 U.S.C. 1395], prohibitions on
certain referral arrangements include those that involve financial
arrangements between entities and physician practices. In the law, rental of
office space is considered not to be a compensation arrangement under
certain conditions and as such are considered exceptions as long as which of
the following exists?
A. The lease would be commercially reasonable even if no referrals were made
between the parties and has a term or rental or lease for at least one 1 year.
B. The lease provides for a term of rental or lease for at least 1 year
C. The space rented or leased does not exceed that which is reasonable and
necessary for the legitimate business purposes of the lease or rental and is
used exclusively by the lessee when being used by the lessee
D. The rental charges over the term of the lease are set in advance, are
consistent with fair Right Ans - E. All of the above
According to the Federal Register, the OIG has listed a number of potential
risk areas for physician practices. These risk areas include: (a) coding and
billing, (b) reasonable and necessary services, and (c) documentation. Which
of the following scenarios would be considered a risk area or areas for a
physician practice?
A. Dr. Y bills Medicare using a covered office visit code when the actual service
was a non-covered annual physical. This could be considered improper coding
or billing and therefore is considered a risk area.
B. Dr. X bills Medicare using a CPT surgical code including dressings and
instruments for a minor procedure in which dressings and instruments are
included in a single fee. This could be considered improper coding or billing
and therefore is considered a risk area.
C. Dr. Z bills Medicare for a preventive medicine service code when the actual
service was a non-covered annual physical. This c Right Ans - A. Dr. Y bills
Medicare using a covered office visit code when the actual service was a non-
covered annual physical. This could be considered improper coding or billing
and therefore is considered a risk area.
,There can be a variety of risks associated with joint ventures between
hospitals and physicians. What law(s) could be violated for improper joint
ventures?
A. False Claims Act
B. Stark Laws
C. Anti-kickback Statute
D. All of the above Right Ans - D. All of the above
Dr. Appleton is an orthopedic surgeon in a large orthopedic practice. Due to
the success of their clinic, the practice is opening a new orthopedic hospital
that will be owned by all of the physicians in the group. In addition to Stark
Law issues, what other compliance concern may be present?
A. Dr. Appleton's referral of patients to the orthopedic hospital will violate the
False Claims Act and subject him to the associated penalties and fines.
B. Dr. Appleton and his colleagues will be paid a set amount of the profits,
regardless of the value or volume of referrals.
C. Dr. Appleton's ownership in the orthopedic hospital represents a conflict of
interest because his decisions on the care needed by his patients may be
biased by his potential financial gain for referring patients to the facility.
D. There is no compliance concern. By opening a new orthopedic hospital, the
practice is helping to assure needed orthopedi Right Ans - C. Dr. Appleton's
ownership in the orthopedic hospital represents a conflict of interest because
his decisions on the care needed by his patients may be biased by his potential
financial gain for referring patients to the facility.
According to the Federal Sentencing Guidelines, "To have an effective
compliance and ethics program..., an organization shall exercise due diligence
to prevent and detect criminal conduct." The FSGs also state organizations
shall:
A. Promote an organizational culture that encourages ethical conduct and a
commitment to compliance with the law.
B. Implement mandatory compliance programs.
C. Perform annual audits to detect criminal conduct.
D. Immediately report evidence of misconduct to the authorities. Right Ans
- A. Promote an organizational culture that encourages ethical conduct and a
commitment to compliance with the law.
, If a physician practice uses another entity's standards of conduct, the practice
must:
A. Implement the standards of conduct as received because they have already
been approved.
B. Tailor those materials to the physician practice where they will be applied.
C. Only select those standards that represent high risk issues for the practice.
D. None of the above. Physician practices must create their own standards of
conduct. It would be a compliance violation to copy another entity's standards
of conduct. Right Ans - B. Tailor those materials to the physician practice
where they will be applied.
As the compliance contact for your physician practice, you are charged with
developing the policies and procedures related to coding and billing. When
developing these policies and procedures, which of the following statements
should be included?
A. If a new physician joins the practice and the new physician's NPI has not
been received, services performed should be reported using the practice
medical director's NPI.
B. For any services billed, documentation must be present in the patient's
medical record to support the services.
C. To avoid compliance risk, coding for E/M services should be based solely on
medical record documentation, even if it appears the level of service is not
warranted.
D. For denied services, billing staff should notify the physician to change the
reported diagnosis to allow for resubmission and payment of the claim.
Right Ans - B. For any services billed, documentation must be present in the
patient's medical record to support the services.
City Orthopedics, a large physician group practice employs several physician
assistants and nurse practitioners. There have been several questions by the
physicians on how incident to services should be billed. The compliance
officer has called the Medicare Administrative Contractor for the practice and
was given some information on how incident to services should be billed.
Because the practice will be relying on the information received from the
Medicare Administrative Contractor, what steps should the compliance officer
Solutions
According the Social Security Act, Sec. 1877. [42 U.S.C. 1395], prohibitions on
certain referral arrangements include those that involve financial
arrangements between entities and physician practices. In the law, rental of
office space is considered not to be a compensation arrangement under
certain conditions and as such are considered exceptions as long as which of
the following exists?
A. The lease would be commercially reasonable even if no referrals were made
between the parties and has a term or rental or lease for at least one 1 year.
B. The lease provides for a term of rental or lease for at least 1 year
C. The space rented or leased does not exceed that which is reasonable and
necessary for the legitimate business purposes of the lease or rental and is
used exclusively by the lessee when being used by the lessee
D. The rental charges over the term of the lease are set in advance, are
consistent with fair Right Ans - E. All of the above
According to the Federal Register, the OIG has listed a number of potential
risk areas for physician practices. These risk areas include: (a) coding and
billing, (b) reasonable and necessary services, and (c) documentation. Which
of the following scenarios would be considered a risk area or areas for a
physician practice?
A. Dr. Y bills Medicare using a covered office visit code when the actual service
was a non-covered annual physical. This could be considered improper coding
or billing and therefore is considered a risk area.
B. Dr. X bills Medicare using a CPT surgical code including dressings and
instruments for a minor procedure in which dressings and instruments are
included in a single fee. This could be considered improper coding or billing
and therefore is considered a risk area.
C. Dr. Z bills Medicare for a preventive medicine service code when the actual
service was a non-covered annual physical. This c Right Ans - A. Dr. Y bills
Medicare using a covered office visit code when the actual service was a non-
covered annual physical. This could be considered improper coding or billing
and therefore is considered a risk area.
,There can be a variety of risks associated with joint ventures between
hospitals and physicians. What law(s) could be violated for improper joint
ventures?
A. False Claims Act
B. Stark Laws
C. Anti-kickback Statute
D. All of the above Right Ans - D. All of the above
Dr. Appleton is an orthopedic surgeon in a large orthopedic practice. Due to
the success of their clinic, the practice is opening a new orthopedic hospital
that will be owned by all of the physicians in the group. In addition to Stark
Law issues, what other compliance concern may be present?
A. Dr. Appleton's referral of patients to the orthopedic hospital will violate the
False Claims Act and subject him to the associated penalties and fines.
B. Dr. Appleton and his colleagues will be paid a set amount of the profits,
regardless of the value or volume of referrals.
C. Dr. Appleton's ownership in the orthopedic hospital represents a conflict of
interest because his decisions on the care needed by his patients may be
biased by his potential financial gain for referring patients to the facility.
D. There is no compliance concern. By opening a new orthopedic hospital, the
practice is helping to assure needed orthopedi Right Ans - C. Dr. Appleton's
ownership in the orthopedic hospital represents a conflict of interest because
his decisions on the care needed by his patients may be biased by his potential
financial gain for referring patients to the facility.
According to the Federal Sentencing Guidelines, "To have an effective
compliance and ethics program..., an organization shall exercise due diligence
to prevent and detect criminal conduct." The FSGs also state organizations
shall:
A. Promote an organizational culture that encourages ethical conduct and a
commitment to compliance with the law.
B. Implement mandatory compliance programs.
C. Perform annual audits to detect criminal conduct.
D. Immediately report evidence of misconduct to the authorities. Right Ans
- A. Promote an organizational culture that encourages ethical conduct and a
commitment to compliance with the law.
, If a physician practice uses another entity's standards of conduct, the practice
must:
A. Implement the standards of conduct as received because they have already
been approved.
B. Tailor those materials to the physician practice where they will be applied.
C. Only select those standards that represent high risk issues for the practice.
D. None of the above. Physician practices must create their own standards of
conduct. It would be a compliance violation to copy another entity's standards
of conduct. Right Ans - B. Tailor those materials to the physician practice
where they will be applied.
As the compliance contact for your physician practice, you are charged with
developing the policies and procedures related to coding and billing. When
developing these policies and procedures, which of the following statements
should be included?
A. If a new physician joins the practice and the new physician's NPI has not
been received, services performed should be reported using the practice
medical director's NPI.
B. For any services billed, documentation must be present in the patient's
medical record to support the services.
C. To avoid compliance risk, coding for E/M services should be based solely on
medical record documentation, even if it appears the level of service is not
warranted.
D. For denied services, billing staff should notify the physician to change the
reported diagnosis to allow for resubmission and payment of the claim.
Right Ans - B. For any services billed, documentation must be present in the
patient's medical record to support the services.
City Orthopedics, a large physician group practice employs several physician
assistants and nurse practitioners. There have been several questions by the
physicians on how incident to services should be billed. The compliance
officer has called the Medicare Administrative Contractor for the practice and
was given some information on how incident to services should be billed.
Because the practice will be relying on the information received from the
Medicare Administrative Contractor, what steps should the compliance officer
