CPCO Chapter 2 Exam Questions
Complete Solutions
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
What does the OIG Compliance Program Guidance acknowledge patient care as?
irrelevant to having an effective compliance program. They are not related.
important, but should not get in the way of implementing all seven recommended
elements.
Providers should put patients first in a compliance program.
the main reason offices fail to implement compliance programs in the first place. -
ANSWER-Providers should put patients first in a compliance program.
Compliance Officers (COs) should implement a "patients first" compliance model,
and enlist buy-in from clinicians by demonstrating that compliance programs improve
patient care.
, Records associated with a compliance inquiry will include the nature of the inquiry or
report, the investigation procedures and outcomes, and all actions taken by the
Compliance Officer and the organization to rectify any non-compliance uncovered.
Who should the Compliance Officer keep apprised of ongoing investigations and the
results when managing incidents and investigations?
CMS
The Board of Directors
Staff
OIG - ANSWER-The Board of Directors
The organization will maintain a file of all records associated with an inquiry to the
Compliance Officer and any reports of suspected noncompliance within the
organization. Files will include the nature of the inquiry or report, the investigation
procedures and outcomes, and all actions taken by the Compliance Officer and the
organization to rectify any non-compliance uncovered. The owner(s), managing
physician(s), or Board of Directors will be kept apprised of all ongoing investigations
and the results of all closed investigations.
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
Complete Solutions
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
What does the OIG Compliance Program Guidance acknowledge patient care as?
irrelevant to having an effective compliance program. They are not related.
important, but should not get in the way of implementing all seven recommended
elements.
Providers should put patients first in a compliance program.
the main reason offices fail to implement compliance programs in the first place. -
ANSWER-Providers should put patients first in a compliance program.
Compliance Officers (COs) should implement a "patients first" compliance model,
and enlist buy-in from clinicians by demonstrating that compliance programs improve
patient care.
, Records associated with a compliance inquiry will include the nature of the inquiry or
report, the investigation procedures and outcomes, and all actions taken by the
Compliance Officer and the organization to rectify any non-compliance uncovered.
Who should the Compliance Officer keep apprised of ongoing investigations and the
results when managing incidents and investigations?
CMS
The Board of Directors
Staff
OIG - ANSWER-The Board of Directors
The organization will maintain a file of all records associated with an inquiry to the
Compliance Officer and any reports of suspected noncompliance within the
organization. Files will include the nature of the inquiry or report, the investigation
procedures and outcomes, and all actions taken by the Compliance Officer and the
organization to rectify any non-compliance uncovered. The owner(s), managing
physician(s), or Board of Directors will be kept apprised of all ongoing investigations
and the results of all closed investigations.
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
