CPCO CHAPTER #2 TEST QUESTIONS
COMPLETE SOLUTIONS
Kelly reported Dr. X to the Compliance Officer for inappropriately billing higher levels
of E/M services than performed. Matthew, the supervisor at the same practice is
providing bonuses for members of his staff. Because Kelly had cost the company
money in auditing Dr. X, she was not given a bonus. Is this a compliance risk? If yes,
why?
Yes; this is considered a violation of HIPAA.
Yes; this is considered retaliation for reporting compliance issues.
No; the supervisor made a valid decision in balancing the finances for the practice.
No; the lack of a bonus is not sufficient enough to be considered a compliance risk. -
ANSWER-Yes; this is considered retaliation for reporting compliance issues.
There should be written confidentiality and non-retaliation policies for employees as
part of the compliance program to encourage communication, asking questions,
obtaining clarification of policies and procedures outlined in the compliance program,
and reporting of all incidents of actual and/or potential misconduct. Non-retaliation—
In policies, this refers to protection against retaliation (adverse action taken because
an individual has engaged in protected activities), threats of retaliation, discharge, or
other discrimination including discrimination.
What does the OIG consider the minimum requirement for a well-publicized guideline
that includes disciplinary steps?
Consultants that come into the organization and do an in depth HR training.
Frequent emails and information given on the Intranet.
Meeting with each employee to get a signature that they understand the guidelines.
Including the disciplinary steps in the company's in-house training and procedure
manuals. - ANSWER-Including the disciplinary steps in the company's in-house
training and procedure manuals.
The OIG states that inclusion of disciplinary guidelines for in-house training and
procedure manuals is sufficient to meet the well-publicized standard.The levels of
non-compliance:• Intentional or reckless disregard for policies and regulations•
Failure to detect a violation• Failure to report a violation
The providers at ABC Family Medicine provide the codes for their services to the
billing department. The compliance plan requires a review of the coding once a
month. What is this an example of?
Auditing
A Work Plan
Monitoring
Internal Review - ANSWER-Monitoring
An audit is a more formal review of compliance with a particular set of standards. For
example, an audit might be performed once a year to look at the overall
effectiveness of the compliance program. Monitoring is conducted on a regular
(scheduled) basis to confirm compliance is ongoing. For example, performed on a
regular basis (weekly, monthly, etc.) to see if procedures are working as intended.
The staff can perform both, or the office might want to have an external source
perform the audit so that it is more objective.
, Failure to respond quickly to suspected or alleged instances of non-compliance
threatens the organization's reputation as trustworthy, law-abiding, and
______________ .
the organization's ability to accept cash patients
the organization's ability to participate with federally funded healthcare plans and/or
third party payers
the organization's ability to hire new employees
the organization's ability to scrutinize practices for other providers - ANSWER-the
organization's ability to participate with federally funded healthcare plans and/or third
party payers
Non-compliance with the Corporate Compliance Program and all applicable laws and
regulation threatens the organization's reputation as a trustworthy, law-abiding
organization and threatens the organization's ability to participate with federally
funded healthcare plans and third party payers. It is for these reasons that the
Compliance Program has been developed and why responding quickly to suspect or
alleged instances of non-compliance is imperative.
Payers expect all providers to refund monies that are overpayments. By law, how
long does the provider have to refund overpayments once discovered?
In a timely manner, the specific number of days is not specified
60 days after receipt of overpayment
60 days after identification of an overpayment
90 days after a request by the payer - ANSWER-60 days after identification of an
overpayment
Under Section 6402 of the ACA, a provider must return an overpayment within 60
days of identifying the overpayment.
What is considered an appropriate start to implementing an effective compliance
program for compliance officers of small physician group practices with limited
resources?
Adopt only those components which, based on the practice's specific history with
billing problems and other compliance issues, are most likely to provide an
identifiable benefit.
A compliance program will not be effective unless every element is fully
implemented.
Have a manual of policies and procedures available for review in the manager's
office.
Small practices are low-risk so they don't need to implement a compliance program.
- ANSWER-Adopt only those components which, based on the practice's specific
history with billing problems and other compliance issues, are most likely to provide
an identifiable benefit.
The OIG acknowledges that full implementation of all components may not be
feasible for all physician practices. Some physician practices may never fully
implement all of the components. However, as a first step, physician practices can
begin by adopting only those components which, based on a practice's specific
history with billing problems and other compliance issues, are most likely to provide
an identifiable benefit. Reference: https://oig.hhs.gov/authorities/docs/physician.pdf -
page
COMPLETE SOLUTIONS
Kelly reported Dr. X to the Compliance Officer for inappropriately billing higher levels
of E/M services than performed. Matthew, the supervisor at the same practice is
providing bonuses for members of his staff. Because Kelly had cost the company
money in auditing Dr. X, she was not given a bonus. Is this a compliance risk? If yes,
why?
Yes; this is considered a violation of HIPAA.
Yes; this is considered retaliation for reporting compliance issues.
No; the supervisor made a valid decision in balancing the finances for the practice.
No; the lack of a bonus is not sufficient enough to be considered a compliance risk. -
ANSWER-Yes; this is considered retaliation for reporting compliance issues.
There should be written confidentiality and non-retaliation policies for employees as
part of the compliance program to encourage communication, asking questions,
obtaining clarification of policies and procedures outlined in the compliance program,
and reporting of all incidents of actual and/or potential misconduct. Non-retaliation—
In policies, this refers to protection against retaliation (adverse action taken because
an individual has engaged in protected activities), threats of retaliation, discharge, or
other discrimination including discrimination.
What does the OIG consider the minimum requirement for a well-publicized guideline
that includes disciplinary steps?
Consultants that come into the organization and do an in depth HR training.
Frequent emails and information given on the Intranet.
Meeting with each employee to get a signature that they understand the guidelines.
Including the disciplinary steps in the company's in-house training and procedure
manuals. - ANSWER-Including the disciplinary steps in the company's in-house
training and procedure manuals.
The OIG states that inclusion of disciplinary guidelines for in-house training and
procedure manuals is sufficient to meet the well-publicized standard.The levels of
non-compliance:• Intentional or reckless disregard for policies and regulations•
Failure to detect a violation• Failure to report a violation
The providers at ABC Family Medicine provide the codes for their services to the
billing department. The compliance plan requires a review of the coding once a
month. What is this an example of?
Auditing
A Work Plan
Monitoring
Internal Review - ANSWER-Monitoring
An audit is a more formal review of compliance with a particular set of standards. For
example, an audit might be performed once a year to look at the overall
effectiveness of the compliance program. Monitoring is conducted on a regular
(scheduled) basis to confirm compliance is ongoing. For example, performed on a
regular basis (weekly, monthly, etc.) to see if procedures are working as intended.
The staff can perform both, or the office might want to have an external source
perform the audit so that it is more objective.
, Failure to respond quickly to suspected or alleged instances of non-compliance
threatens the organization's reputation as trustworthy, law-abiding, and
______________ .
the organization's ability to accept cash patients
the organization's ability to participate with federally funded healthcare plans and/or
third party payers
the organization's ability to hire new employees
the organization's ability to scrutinize practices for other providers - ANSWER-the
organization's ability to participate with federally funded healthcare plans and/or third
party payers
Non-compliance with the Corporate Compliance Program and all applicable laws and
regulation threatens the organization's reputation as a trustworthy, law-abiding
organization and threatens the organization's ability to participate with federally
funded healthcare plans and third party payers. It is for these reasons that the
Compliance Program has been developed and why responding quickly to suspect or
alleged instances of non-compliance is imperative.
Payers expect all providers to refund monies that are overpayments. By law, how
long does the provider have to refund overpayments once discovered?
In a timely manner, the specific number of days is not specified
60 days after receipt of overpayment
60 days after identification of an overpayment
90 days after a request by the payer - ANSWER-60 days after identification of an
overpayment
Under Section 6402 of the ACA, a provider must return an overpayment within 60
days of identifying the overpayment.
What is considered an appropriate start to implementing an effective compliance
program for compliance officers of small physician group practices with limited
resources?
Adopt only those components which, based on the practice's specific history with
billing problems and other compliance issues, are most likely to provide an
identifiable benefit.
A compliance program will not be effective unless every element is fully
implemented.
Have a manual of policies and procedures available for review in the manager's
office.
Small practices are low-risk so they don't need to implement a compliance program.
- ANSWER-Adopt only those components which, based on the practice's specific
history with billing problems and other compliance issues, are most likely to provide
an identifiable benefit.
The OIG acknowledges that full implementation of all components may not be
feasible for all physician practices. Some physician practices may never fully
implement all of the components. However, as a first step, physician practices can
begin by adopting only those components which, based on a practice's specific
history with billing problems and other compliance issues, are most likely to provide
an identifiable benefit. Reference: https://oig.hhs.gov/authorities/docs/physician.pdf -
page
