QUESTIONS AND CORRECT DETAILED
ANSWERS (VERIFIED ANSWERS)
|ALREADY GRADED A+||BRAND NEW!!
compliance program - Answers - ✔✔prevention, detection, collaboration, and
enforcement
Effective compliance program - Answers - ✔✔must be an ongoing process and
commitment to an ethical way of conducting business
Office of Inspector General and Justice Department - Answers - ✔✔is responsible for
enforcing the rules and regulations under the Medicare and Medicaid laws outline as
part of the SSA by CMS.
Benefits of compliance program addressed by OIG - Answers - ✔✔safeguards the
organizations' legal responsibility to abide by applicable laws and regulations.
Corporate Integrity Agreement (CIA) - Answers - ✔✔government imposed compliance
program
Why compliance programs are essential - Answers - ✔✔prevent paybacks, probation,
government designed programs, exclusion, reduce threat of lawsuits from
whistleblowers (qui tam).
OIG Top 10 reasons to implement a compliance program - Answers - ✔✔demonstrates
a strong commitment to honesty and responsible corporate relations, reinforces
employees sense of right and wrong, fulfill legal duty to payers, cost effective, more
accurate view of what is going on, quality of care to clients, provides procedures to
promptly correct misconduct, mitigate any sanction imposed by government.
Health Insurance Portability and Accountability Act of 1996 (HIPAA) - Answers - ✔✔a
criminal offense to submit claims based on incorrect codes or medically unnecessary
services, and government has the power to exclude an organization from Medicare/caid
and other govt programs.
Balanced Budget Act of 1997 - Answers - ✔✔three strikes and your out clause ,
requiring permanent expulsion if found guilty of fraud a third time.
False Claims Act (FCA) - Answers - ✔✔empowers the govt to investigate and bring civil
action in fraud cases. Implemented in Civil War to control price gouging.
, Qui tam - Answers - ✔✔is a whistleblower who brings the fraud to light.
A whistleblower can receive a % of the govt's total award - Answers - ✔✔15-25% if DOJ
assumes the case or 25-30% if DOJ declines
To avoid lengthy and expensive litigation, an organization can negotiate a
____________with the govt admits no fault or liability but does submit to a govt plan for
corrective action. - Answers - ✔✔CIA
Length of CIAs - Answers - ✔✔3-5 yrs with some lasting up to 8 yrs
1984 Congress enacted Sentencing reform act which includes FSG - Answers - ✔✔act
designed to correct inequities in federal sentencing and give guidance for assessing
fines and methods for calculation of culpability score.
The culpability score - Answers - ✔✔calculation of the degree of blame or guilt used to
determine fines, restitution, forfeiture, and probation.
If an upper level employee has participated in or was willfully ignorant of an offense, -
Answers - ✔✔the likelihood of culpability score will be increased.
If an organization reports a violation promptly, - Answers - ✔✔the culpability score may
be mitigated.
An aggravating factor in FSG - Answers - ✔✔is that the organization has had a
repeated offense
A mitigating factor for FSG - Answers - ✔✔is that the organization cooperated with the
govt investigators
2010 FSG amendment changes includes way to further reduce culpability scores: -
Answers - ✔✔C&E program has responsibility- to report directly to board or appropriate
subgroup, to detected offense before external discovery, prompt reporting, no one with
OP responsibility participated in, condoned, or was willfully ignorant of the offense.
Which of the following is an aggravating factor to a culpability score in the Federal
Sentencing Commission released "Chapter 8 Part B - Remedying Harm from Criminal
Conduct, and Effective Compliance and Ethics Program?" - Answers - ✔✔If the violation
was a repeat offense;
The OIG believes every effective compliance Program begins with a formal commitment
to seven basic elements, based on and expanding upon the seven steps of the Federal
Sentencing Guidelines. Which of the following is not one of the seven elements in the