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CPCO EXAM GUIDE QUESTIONS AND ANSWERS COMPLETE SOLUTIONS

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CPCO EXAM GUIDE QUESTIONS AND ANSWERS COMPLETE SOLUTIONS

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February 17, 2025
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CPCO EXAM GUIDE QUESTIONS AND
ANSWERS COMPLETE SOLUTIONS
The DOJ's current strategic plan (2018-2022) includes the following overarching goals: -
ANSWER-- Enhance national security and counter the threat of terrorism;
- Secure the borders and enhance immigration enforcement and adjudication;
- Reduce violent crime and promote public safety; and
- Promote rule of law, integrity, and good government.

What are CIA (Corporate Integrity Agreements)? - ANSWER-Used to enforce
compliance within a healthcare organization. Used as a part of a civil settlement with a
provider or organization when there has been an investigation into the claims submitted
to a federal payer. I

What is HHS OCR (Office of Civil Rights)? - ANSWER-Responsible to enforce the
HIPAA Privacy Rule and Security Rule provisions. The Civil Rights Act of 1964 as it
applies to limited English proficiency (see below), the confidentiality provisions of the
Patient Safety Act and Rule, the Church Amendments, section 245 of the Public Health
Service Act, and the Weldon Amendment.

What is required for a compliance program to be effective?
a. The compliance program needs to be reviewed daily for any compliance updates.
b. Regularly review and update the compliance program.
c. The compliance program must be reviewed by healthcare lawyers.
d. The compliance program needs to be reviewed weekly for any compliance updates. -
ANSWER-b. Regularly review and update the compliance program.
Rationale: Simply implementing a compliance program is not enough. It will need to be
reviewed and updated on a regular basis.

Which federal government departments is the OIG NOT responsible for overseeing?
a. Centers for Medicare & Medicaid Services
b. Centers for Disease Control and Prevention
c. U.S. Food & Drug Administration
d. Drug Enforcement Agency - ANSWER-d. Drug Enforcement Agency
Rationale: The OIG is responsible for overseeing the Centers for Medicare & Medicaid
Services (CMS), and programs under other HHS agencies, including the Centers for
Disease Control and Prevention (CDC), National Institutes of Health (NIH), and the U.S.
Food and Drug Administration (FDA). The Drug Enforcement Agency (DEA) is overseen
by DOJ.

In what year did the OIG post guidance for hospitals?
a. 1996
b. 1997
c. 1998

,d. 1999 - ANSWER-c. 1998
Rationale: The first set of OIG guidance for hospitals was created in 1998.

Which of the following can be a result of an effective compliance program?
a. Keep a provider from facing criminal penalties
b. Make sure a practice or medical organization is 100 percent compliant with federal
regulations
c. Help create financial success, customer loyalty, community support, and employee
satisfaction
d. Require starting fresh with new policies and procedures and expensive changes -
ANSWER-c. Help create financial success, customer loyalty, community support, and
employee satisfaction
Rationale: There is no guarantee that a compliance program will keep a provider from
facing criminal penalties. However, it will help create a culture of compliance, which will
lead to customer loyalty and increased employee satisfaction.

Which entity below could NOT bill for medically unnecessary services?
a. Hospitals
b. Physicians
c. Ancillary providers
d. Patients - ANSWER-d. Patients
Rationale: There is tremendous pressure to contain healthcare costs, and government
payers necessarily must be on guard against hospitals, physicians, and ancillary
providers billing for wasteful or medically unnecessary services.

Which government department is comprised thousands of employees who enforce the
nation's federal criminal laws and help develop and implement criminal law policies?
a. Office of Inspector General
b. Centers for Medicare & Medicaid Services
c. Health Care Lawyers Association
d. Department of Justice - ANSWER-d. Department of Justice
Rationale: The Department of Justice (DOJ) works closely with the OIG. It is comprised
of more than 105,000 employees, including hundreds of lawyers who enforce the
nation's federal criminal laws and help to develop and implement criminal law policies.
Their role in healthcare fraud and healthcare compliance is to investigate and prosecute
healthcare crimes.

Which department is the largest inspector general's office in the federal government?
a. HHS Office of Inspector General
b. Office of Civil Rights
c. Department of Justice
d. Centers for Medicare & Medicaid Services - ANSWER-a. HHS Office of Inspector
General
Rationale: The HHS OIG is the largest inspector general's office in the federal
government, with approximately 1,600 workers dedicated to combating fraud, waste,
and abuse.

,Sue works for ABC Family Physicians. The providers at this office ask her to research
the department that helps to protect patients from unfair treatment or discrimination?
What department or agency would that be?
a. Employment Equality Agency
b. Office for Civil Rights
c. Department of Justice
d. Office of Inspector General - ANSWER-b. Office for Civil Rights
Rationale: Civil rights help to protect individuals from unfair treatment or discrimination
because of race, color, national origin, disability, age, sex (gender), or religion.

What term would be used for actions that, either directly or indirectly, result in
unnecessary costs to the Medicare program?
a. Fraud
b. Mistake
c. Waste
d. Abuse - ANSWER-d. Abuse
Rationale: "Abuse describes practices that, either directly or indirectly, result in
unnecessary costs to the Medicare Program."

How many elements are required to have a successful compliance program?
a. Five
b. Seven
c. Eight
d. Nine - ANSWER-b. Seven
Rationale: The OIG guidance documents the seven elements of the Federal Sentencing
Guidelines as the basis of an effective compliance program.

Which component of the OIG operates the OIG hotline?
a. Office of Counsel to the Inspector General
b. Office of Management & Policy
c. Office of Evaluations & Inspections
d. Office of Investigations - ANSWER-d. Office of Investigations

Rationale: Office of Investigations (OI) conducts criminal, civil, and administrative
investigations of fraud and misconduct related to HHS programs, operations, and
beneficiaries. The OI also operates an OIG hotline.

Compliance certification agreements (CCAs) require providers to certify they will
continue to operate their existing compliance program for a fixed term. What is the
typical term of a corporate integrity agreement (CIA)?
a. One year
b. Three years
c. Five years
d. Seven years - ANSWER-c. Five years.

, Rationale: The typical term for a Corporate Integrity Agreement (CIA) is five years.

In what year was the Patient Protection and Affordable Care Act (PPACA) enacted?
a. 2010
b. 1996
c. 2001
d. 2008 - ANSWER-a. 2010

Rationale: The Patient Protection and Affordable Care Act was signed by President
Obama on March 23, 2010.

Which department of the OIG conducts audits resulting in reduced waste, abuse, and
mismanagement?
a. Office of Investigations
b. Office of Audit Services
c. Office of Evaluations & Inspections
d. Office of Management & Policy - ANSWER-b. Office of Audit Services

Rationale: The Office of Audit Services provides independent assessments of HHS
programs and operations. These assessments help reduce waste, abuse, and
mismanagement and promote economy and efficiency throughout HHS.

USSC is important as it related to the Federal Sentencing Guidelines and is thus related
to the core elements of compliance. What does the USSC acronym stand for?
a. United States Security Commission
b. United States Sentencing Commission
c. United States Sentencing Committee
d. United States Security Committee - ANSWER-b. United States Sentencing
Commission

Jill is the compliance officer for Dr. X. Jill wants to send all lab referrals to the lab that
her physician owns. Is this considered fraud?
a. No, it is considered waste.
b. Yes, it is considered fraud.
c. No, it is considered abuse.
d. Yes, only because lab services owned by providers is a special category so therefore
it is fraud. - ANSWER-b. Yes, it is considered fraud.

Rationale: Making prohibited referrals for certain designated health services is
considered fraud.

In 1992, the General Accounting Office (GAO) identified Medicare claims to be at high
risk for fraud and abuse(GAO/ HR-93-6, Dec. 1992). Subsequent to this determination,
in 1996, what was initiated?
a. An audit of HCFA (CMS) Medicare claims payment system.
b. OIG compliance program documents for each provider type.

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