CHC EXAM: COMPLIANCE PROGRAM ADMINISTRATION
UPDATED ACTUAL QUESTIONS AND CORRECT
ANSWERS
Question:
1. Advocating for compliance resources
Answer:
Conduct research, provide data, search for free resources, negotiate, communicate benefits to organization,
developed a resource management plan
Question:
2. Report and Compliance program activity
Answer:
Provide regular reports generally at least quarterly as well as an annual report, provide clear and concise
explanations to reduce the need for unnecessary questioning, provide an outline of report to the members,
update any new area of risk so the members are not caught off guard when issues arise, present supporting
data, utilize the same reporting process for each presentation so the members know what to expect,
encourage input from members and show respect for their contributions, fall through on any advice or
directions for action
Question:
3. Responsibilities of compliance oversight committee
Answer:
The OIG recommends that organizations have both a compliance officer to manage and moderate
compliance issues in a compliance oversight committee to provide advice in guidance to the compliance
officer. The clients committee must have autonomy in authority to enforce Compliance. Functions include:
1. Analyze the legal requirements for industry in areas of increased risk. 2Assessment of existing policies
and procedures.
3. Development of standards of conduct in collaboration with other departments to share compliance
4. Development of internal systems and controls for monitoring and carrying out organizations policies
and procedures in collaboration with other departments.
5. Ensuring proper reporting of misconduct and violations.
Question:
4. Fundamental elements and complains programs
Answer:
1.Written policies and procedures
2. Compliance professional
3. Effective training
4. Effective communication
5. Internal monitoring program
6. Enforcing of standards
7. Prompt response
Question:
5. Fraudulent practices
, Answer:
Billing for items or service is not provided, providing services that are medically unnecessary, upcoding
claims, DRG creep, billing for outpatient services provided to inpatients, Teaching position and resident
requirements for teaching institutions, duplicate billing, false costs reports, Unbundling charges, Billing
for discharge instead of transfer, patience freedom of choice, failure to refund credit balance, violations of
anti-kickback statute or other federal or state statute and regulations, joint ventures that may violate
anti-kickback statue, financial arrangements between hospitals and hospital-based physicians, stark law
violations, knowing failure to provide covered services or necessary care to members of an HMO, patient
dumping
Question:
6. Areas of concern for compliance for home health agencies
Answer:
Billing for services to patients who are not homebound, billing for services to patients who do not qualify
for care, Overutilization or Underutilization of services, knowingly billing for inadequate or substandard
care, insufficient Documentation to support reimbursement, billing for unallowable costs,Billing for
unqualified unlicensed clinical personnel, fall stating of amendments to nurses notes, falsified plans of
care, forge beneficiary signatures on visit slips or logs that verify performance of services, improper
patient solicitation activities, inadequate oversight of contracted services, discrimination and discharge or
admission,Improper influence over referrals by hospitals that on HH agencies, patient abandonment
Question:
7. Areas of OIG concern for compliance for nursing facilities
Answer:
In adequate assessment of residential functional capacity and lack of comprehensive plan of care,
inappropriate or insufficient Treatment or series to address resident's conditions, Failure to accommodate
resident needs or preferences, failure to properly prescribe/administer/monitor prescription drugs, In
adequate staffing or insufficiently train staff, tell her to apply appropriate therapy services and to assist
with ADLs, failure to prove an ongoing activities program to meet individual needs, failure to report
incidence of miss treatment abuse neglect to administrator and officials as required by law
Question:
8. Areas of OIG concern for compliance for hospices
Answer:
Uninformed consent for use of Medicare hospital benefit, omission of patients who are not terminally ill,
arrangement with other healthcare provider who is submitting claims for services already covered by
Medicare hospice benefit, phosphide medical records/Plans of care/untimely or Forge position certification
of care, inadequate or a complete services by interdisciplinary group, Insufficient patient oversight,
violations of anti-kickback or some other statues or regulations, overlap of services provided by nursing
home, providing nursing home hospice services prior to finalized written agreement , if required, Billing
for higher level than needed for inadequate or substandard care, Pressure on patients to revoke hospice
benefit when care becomes expensive to provide, billing or services provided by unqualified or unlicensed
personnel, high-pressure marketing to an eligible beneficiaries, in adequate management or oversight of
subtracted services, sales commissions based on length of stay in hospice, deficient coordination of
volunteers, non-response to late referrals or underutilization of services, Failure to adhere to licensing
requirements and Medicare conditions pf participation/misuse of provider certification numbers/ failure to
return over payments
UPDATED ACTUAL QUESTIONS AND CORRECT
ANSWERS
Question:
1. Advocating for compliance resources
Answer:
Conduct research, provide data, search for free resources, negotiate, communicate benefits to organization,
developed a resource management plan
Question:
2. Report and Compliance program activity
Answer:
Provide regular reports generally at least quarterly as well as an annual report, provide clear and concise
explanations to reduce the need for unnecessary questioning, provide an outline of report to the members,
update any new area of risk so the members are not caught off guard when issues arise, present supporting
data, utilize the same reporting process for each presentation so the members know what to expect,
encourage input from members and show respect for their contributions, fall through on any advice or
directions for action
Question:
3. Responsibilities of compliance oversight committee
Answer:
The OIG recommends that organizations have both a compliance officer to manage and moderate
compliance issues in a compliance oversight committee to provide advice in guidance to the compliance
officer. The clients committee must have autonomy in authority to enforce Compliance. Functions include:
1. Analyze the legal requirements for industry in areas of increased risk. 2Assessment of existing policies
and procedures.
3. Development of standards of conduct in collaboration with other departments to share compliance
4. Development of internal systems and controls for monitoring and carrying out organizations policies
and procedures in collaboration with other departments.
5. Ensuring proper reporting of misconduct and violations.
Question:
4. Fundamental elements and complains programs
Answer:
1.Written policies and procedures
2. Compliance professional
3. Effective training
4. Effective communication
5. Internal monitoring program
6. Enforcing of standards
7. Prompt response
Question:
5. Fraudulent practices
, Answer:
Billing for items or service is not provided, providing services that are medically unnecessary, upcoding
claims, DRG creep, billing for outpatient services provided to inpatients, Teaching position and resident
requirements for teaching institutions, duplicate billing, false costs reports, Unbundling charges, Billing
for discharge instead of transfer, patience freedom of choice, failure to refund credit balance, violations of
anti-kickback statute or other federal or state statute and regulations, joint ventures that may violate
anti-kickback statue, financial arrangements between hospitals and hospital-based physicians, stark law
violations, knowing failure to provide covered services or necessary care to members of an HMO, patient
dumping
Question:
6. Areas of concern for compliance for home health agencies
Answer:
Billing for services to patients who are not homebound, billing for services to patients who do not qualify
for care, Overutilization or Underutilization of services, knowingly billing for inadequate or substandard
care, insufficient Documentation to support reimbursement, billing for unallowable costs,Billing for
unqualified unlicensed clinical personnel, fall stating of amendments to nurses notes, falsified plans of
care, forge beneficiary signatures on visit slips or logs that verify performance of services, improper
patient solicitation activities, inadequate oversight of contracted services, discrimination and discharge or
admission,Improper influence over referrals by hospitals that on HH agencies, patient abandonment
Question:
7. Areas of OIG concern for compliance for nursing facilities
Answer:
In adequate assessment of residential functional capacity and lack of comprehensive plan of care,
inappropriate or insufficient Treatment or series to address resident's conditions, Failure to accommodate
resident needs or preferences, failure to properly prescribe/administer/monitor prescription drugs, In
adequate staffing or insufficiently train staff, tell her to apply appropriate therapy services and to assist
with ADLs, failure to prove an ongoing activities program to meet individual needs, failure to report
incidence of miss treatment abuse neglect to administrator and officials as required by law
Question:
8. Areas of OIG concern for compliance for hospices
Answer:
Uninformed consent for use of Medicare hospital benefit, omission of patients who are not terminally ill,
arrangement with other healthcare provider who is submitting claims for services already covered by
Medicare hospice benefit, phosphide medical records/Plans of care/untimely or Forge position certification
of care, inadequate or a complete services by interdisciplinary group, Insufficient patient oversight,
violations of anti-kickback or some other statues or regulations, overlap of services provided by nursing
home, providing nursing home hospice services prior to finalized written agreement , if required, Billing
for higher level than needed for inadequate or substandard care, Pressure on patients to revoke hospice
benefit when care becomes expensive to provide, billing or services provided by unqualified or unlicensed
personnel, high-pressure marketing to an eligible beneficiaries, in adequate management or oversight of
subtracted services, sales commissions based on length of stay in hospice, deficient coordination of
volunteers, non-response to late referrals or underutilization of services, Failure to adhere to licensing
requirements and Medicare conditions pf participation/misuse of provider certification numbers/ failure to
return over payments
