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When should Code of Conduct be distributed to new employees? - ANSWER -
Must be distributed within 90 days of hire
RAT-STATS is: (select all that apply)
a. statistical software to select randomized samples
b. government statistical rule software developed in the 1970s
c. free hospital statistical software
d. recommended by OIG, CMS and other agencies to select random samples -
ANSWER -a. b. d.
The software can be used by other entities other than hospitals, so option "c." is not
precisely accurate, but it is free to use and can be downloaded here:
https://oig.hhs.gov/compliance/rat-stats/index.asp
What is the term called for an organization's commitment to compliance by
management, employees, and contractors. Statement should summarize ethical
behavior and legal principles under which the healthcare organization operates? -
ANSWER -Code of Conduct
In the course of an audit, you find that disciplinary actions against certain
physicians and high level executives for non-compliance in the organization have
been unfair and inconsistent with current policies & procedures. What is your first
course of action
.a. Work with legal counsel to enforce proper disciplinary actions
b. Get HR involved and recommend the use of progressive discipline policies
c. Immediately terminate these individuals
,d. Get local and federal labor department involved for unfair discipline. -
ANSWER -b. Get HR involved and recommend the use of progressive discipline
policies
OIG recommends setting forth the degrees of disciplinary actions. Progressive
discipline provides a structure and a set of discipline standards for
managers/supervisors to follow to ensure discipline is fair, equitable and
consistent.
Documentation - ANSWER -• A&M should be documented
• Findings should be shared with dept managers
• If activity is part of risk priority then compliance committee, senior leadership
and board when necessary
• OIG calls for written evaluation to be presented to CEO, governing body,
committee annually
Non-retaliation in compliance - what is important to state in this policy: -
ANSWER -For any reporting method to be effective, employees must accept that
there will be no retaliation or retribution for coming forward.
The concept of non-retaliation is fundamental to the compliance program, and a
clearly stated policy regarding non-retribution is the first step.
• anonymous reporting and,
• no retaliation or retribution for bringing forth problems/concerns
Place to start with Enforcement is: - ANSWER -Standards of conduct and P&Ps
For Enforcement and Disciplinary Actions, Policies should include: - ANSWER -
1. non-compliant consequences
2. employees duty to report non-compliance
3. list parties responsible for appropriate action
4. outline of disciplinary actions or procedures
5. promise that discipline will be fair and consistent
, New Employee Policy - three checks OIG recommends to do/perform: -
ANSWER -OIG recommends: perform background checks, reference checks, and
exclusion list checks
Which two main documents become tools to build compliance program? -
ANSWER -Code of Conduct and P&Ps
You are the new Compliance Officer, hired after ABC Hospital reorganized and
decided that the General Counsel should no longer also serve in that role. Upon
review of the Code of Conduct (CoC), you find that it is written using lots of legal
jargon. What action do you take:
a. Keep CoC as it is.
b. Pull a sample off the internet and insert hospital name to save time as it was
most likely written by experts.
c. Rewrite the CoC in plain and concise language tailored to the hospital so
employees can use a general guidance.
d. Rewrite the CoC with detailed restating hospital's P&Ps, and all laws and
regulations possible so that employees can't say they were not aware of
requirements. - ANSWER -c. Rewrite the CoC in plain and concise language
tailored to the hospital so employees can use a general guidance.
Explanation:
• CoC should be clear and concise language easy to understand, and should be
tailored to specific issues of the organization
What is the term called for an organization's commitment to compliance by the
board, management, and employees? It summarizes ethical behavior and legal
principles the healthcare organization operates.
A) Code of Conduct
B) Federal Sentencing Guidelines
C) Internal Controls - ANSWER -A) Code of Conduct
The U.S. Federal Sentencing Commission was organized in _____, published its
initial set of guidelines manual in _____ (known today as the US Sentencing
, Guidelines), and included chapter eight of the Federal Sentencing Guidelines for
Organizations in _____.
a. 1980, 1987, 1999
b. 1985, 1987, 1991
c. 1980, 1985, 1987
d. 1985, 1990, 2001 - ANSWER -b. 1985, 1987, 1991
The US Sentencing Guidelines (USSG) can be found here:
https://www.ussc.gov/guidelines.
Chapter 8 - Sentencing of organizations, includes Parts A-F (Part B 2.b.1 outlines
the Compliance and Ethics Program)
Expectations have evolved since 1991 when the US Sentencing Guidelines
(USSG) were first drafted highlighting the importance of an effective compliance
program (and as a condition of probation) to help detect criminal conduct (USSG
chapter 8B2.1). DOJ has now set higher expectations for organizations to not only
have a designated compliance officer but a well designed compliance program that
is adequately resourced with independent authority function to work in practice.
Which of the following guidelines outlines those expectations:
a. HHS OIG - CPG (Compliance Program Guidance)
b. DOJ ECCP (Evaluation of Corporate Compliance Programs)
c. Monaco Memo
d. HHS OIG - CIA (Corporate Integrity Agreement) - ANSWER -b. DOJ ECCP
(Evaluation of Corporate Compliance Programs)
The ECCP and other related guidance can be downloaded here:
https://www.justice.gov/criminal/criminal-fraud/policy-materials
The most updated DOJ ECCP (Evaluation of Corporate Compliance Programs)
provides additional guidance to prosecutors. Which of the following are included
in the ECCP revisions (Sep 2024)?
a. expects company's compliance program to include safeguards to better monitor
and manage potential compliance risk regarding new technologies (e.g., A.I.)
b. expects company's to integrate these new technology related risks into broader
enterprise risk management (ERM) strategies