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A privacy professional is reviewing a program for an academic medical center that include a
faculty group practice, hospital, student health center, and self-funded group health plan. The
privacy professional should evaluate if the program has notices for:
GINA
FMLA
HIPAA
FISMA ✔✔c. HIPAA
A health system implemented an EHR in 55 clinics. The privacy professional is told employees
are inconsistently interpreting the policy addressing employee access to EHR. Which of the
following is the privacy professional's BEST strategy?
Collaborate with HR to ensure appropriate discipline
Perform an audit under Attorney-Client Privilege
Conduct surveys of clinic employees concerns
Audit a random sampling of clinics across the organization ✔✔c. Conduct surveys of clinic
employees concerns
,Under the US Federal Sentencing Guidelines, there is an expectation that effective compliance
programs include due diligence in discretionary authority and hiring. Which of the following is
MOST important process to include?
Periodic background checks
Drug Testing
Monthly exclusion verifications through OIG database
Monthly exclusion verifications through SAMS GSA Exclusion database ✔✔d. Monthly
exclusion verifications through SAMS GSA Exclusion database.
Explanation: Starting from the top: GSA administers SAM, which contains debarment actions
taken by various Federal agencies, including OIG's exclusions. The LEIE contains only the
exclusion actions taken by OIG.
What are the 2 types of OIG exclusions? ✔✔Mandatory and Permissive.
See definitions: https://oig.hhs.gov/exclusions/background.asp
Concurrent Audit ✔✔Real time - Ongoing review/inspection of records, policies and procedures.
More difficult to execute but best way to change behavior. Identify and address problems as they
arise - Example: Auditing claims before claims are billed
, What is DRG Creep ✔✔Using a Diagnosis Related Group (DRG) code that provides a higher
payment rate than the DRG code that accurately reflects the service furnished to the patient.
In Compliance Auditing & Monitoring, Contemporaneous Reviews:
Involves matter that either have not yet been billed by provider or have not yet been paid by the
third party payor
Appropriate to determine an initial baseline view of a particular billing practice or activity
Can uncover existence of past problems
All of the above
A and B only ✔✔e. All of the above
Compliance means (Compliance Program) ✔✔Adherence to laws and regulations, as well as
principles of ethical conduct
OIG urges the ____________ to assist in the implementation of the compliance program and
serves as advisors.
Board
CEO