CPMA RECENT EXAMS TEST PAPER QUESTIONS AND
ANSWERS SURE A+
✔✔Core requirements in CIAs - ✔✔Hiring a compliance officer/appointing a compliance
committee; developing written standards and policies; implementing a comprehensive
employee training program; retaining an independent review organization (IRO) to
conduct annual reviews; establishing a confidential disclosure program; restricting
employment of ineligible persons; reporting overpayments, reportable events, and
ongoing investigations/legal proceedings; providing an implementation report and
annual reports to the OIG on the status of the entity's compliance activities
✔✔Independent review organization (IRO) - ✔✔Acts as a 3rd party medical review
resource that provides objective, unbiased audits and reports
✔✔How many sampling units are selected for review in a Discovery Sample under a
CIA? - ✔✔50
✔✔Purpose of a Discovery Sample - ✔✔Used to determine the net financial error rate; if
the error rate exceeds 5%, a Full Sample must be reviewed, along with a Systems
Review
✔✔What is the name of the statistical sampling program provided by the OIG to
randomly select and determine the size of the Discovery Sample? - ✔✔RAT-STATS
,✔✔What percent of precision and confidence are required to estimate the
overpayment? - ✔✔90% confidence and 25% precision level
✔✔Certificate of Compliance Agreement (CCA) - ✔✔Require the provider to certify that
is will continue to operate its existing compliance programs and to report to OIG for a
lesser period of time (usually 3 years); introduced in Inspector General Janet
Rehnquist's An Open Letter to Healthcare Providers in November 2011
✔✔Compliance Plan - ✔✔Represents comprehensive documentation that a provider,
practice, facility, or other healthcare entity is taking steps to adhere to the federal and
state laws that affect it
✔✔Voluntary compliance plan guidance (CPG) documents - ✔✔Developed by the OIG
for a variety of healthcare settings; indicate the comprehensive framework, standards,
and principles by which an effective internal compliance program may be established
and maintained
✔✔Are compliance plans mandatory? - ✔✔No, they are currently voluntary. The
Affordable Care Act makes compliance programs mandatory for providers and other
healthcare providers but there is not yet an implementation date
✔✔How many elements has the OIG identified that should be present in every
compliance plan? - ✔✔7
✔✔Elements identified by the OIG that should be present in every compliance plan
(except for individual or small group practices) - ✔✔Implementing written policies,
procedures and standards of conduct; designating a compliance officer and/or
compliance committee; conducting effective training and education; developing effective
lines of communication; enforcing standards through well-publicized disciplinary
guidelines; conducting internal monitoring and auditing; and responding promptly to
detected offenses and developing corrective action
✔✔What should be included in the documentation of a finding of non-compliant
conduct? - ✔✔Date of incident, name of reporting party, name of the person responsible
for taking action, and the follow-up action taken
✔✔When was the CPG for individual and small group physician practices issued? -
✔✔October 5, 2000 in the Federal Register
✔✔What components of the compliance plan should be adopted by the practice? -
✔✔Based on the practice's specific history with billing problems and other issues, the
practice should begin by adopting only those components most likely to provide an
identifiable benefit
,✔✔Potential benefits of a compliance program for individual and small group practices -
✔✔Increasing accuracy of documentation; increasing the speed and optimization of
proper payment of claims; minimizing billing mistakes; reducing the chances that an
audit will be conducted by CMS or the OIG; and avoiding conflicts with the self-referral
and anti-kickback statutes
✔✔Potential risk areas for individual and small group practices indicated by the OIG in
the CPG - ✔✔Coding and billing, reasonable and necessary services, documentation,
and improper inducements, kickbacks, and self-referrals
✔✔Additional risk area for physicians listed in the appendix at the end of the CPG -
✔✔Reasonable and necessary services; physician relationships with hospitals;
physician billing practices; and other risk areas (rental of space in physician offices by
persons or entities to which physicians refer and unlawful advertising)
✔✔For which healthcare entities are CPGs listed on the OIG website? - ✔✔Nursing
facilities; hospitals; recipients of PHS research awards; pharmaceutical manufacturers;
ambulance suppliers; Medicare+Choice organizations; hospices; durable medical
equipment; prosthetics, orthotics, and supply industry (DMEPOS); third-party medical
billing companies; clinical laboratories; and home health agencies
✔✔5 practical tips provided by CMS for creating a culture of compliance - ✔✔Make
compliance plans a priority now; know your fraud and abuse risk areas; manage your
financial relationships; just because your competitor is doing something doesn't mean
you can or should; and when in doubt, ask for help
✔✔Health Care Financing Administration (HCFA)/Centers for Medicare and Medicaid
Services (CMS) - ✔✔Established in 1977 to administer the Medicare and Medicaid
programs; renamed the Centers for Medicare and Medicaid Services (CMS) in 2001;
largest agency within the Department of Health and Human Services; administers
Medicare, Medicaid, and the Children's Health Insurance Program
✔✔CMS transmittals - ✔✔Communicate new or changed policies or procedures that will
be incorporated into the CMS Online Manual System; each one has a transmittal
number, an issue date, an implementation date, a Change Request number, and a
subject name
✔✔Medicare Learning Network (MLN) - ✔✔Provides education, information, and
resources for the healthcare professional community; offers educational products,
national provider calls, provider association partnerships, provider eNews, and provider
electronic mailing lists
, ✔✔Conditions of Participation (CoP) and Conditions for Coverage (CfC) - ✔✔Standards
set forth in the Federal Register that must be met to participate in Medicare and
Medicaid Programs; they include Ambulatory Surgical Centers (ASCs), Critical Access
Hospitals (CAHs), and hospitals
✔✔Conditions of participation for medical record services - ✔✔The conditions include
that each patient should have a medical record; medical records must be organized to
allow for prompt completion, filing, and retrieval; medical records must be retained for at
least 5 years; and patient confidentiality should be protected
✔✔Definition from the 1995 guidelines regarding types of exam - ✔✔The levels of E/M
services are based on 4 types of examination that are defined as follows: Problem-
Focused-a limited examination of the affected body area or organ system; Expanded
Problem Focused-a limited examination of the affected body area or organ system and
other symptomatic or related organ system(s); Detailed-an extended examination of the
affected body area(s) and other symptomatic or related organ system(s);
Comprehensive-a general multi-system examination or complete examination of a
single organ system
✔✔Definition from the 1997 guidelines regarding general multi-system examination -
✔✔To qualify for a given level of general multi-system examination, the following
content and documentation requirements should be met: Problem Focused
Examination-should include performance and documentation of one to five elements
identified by a bullet in one or more organ system(s) or body area(s); Expanded
Problem Focused Examination-should include performance and documentation of at
least 6 elements identified by a bullet in one or more organ system(s) or body area(s);
Detailed Examination-should include at least 6 organ systems or body areas. For each
system/area selected, performance and documentation of at least 2 elements identified
by a bullet is expected. A detailed examination may include performance and
documentation of at least 12 elements identified by a bullet in 2 or more organ systems
or body areas; Comprehensive Examination-should include at least 9 organ systems or
body areas. For each system/area selected, all elements of the examination identified
by a bullet should be performed, unless specific directions limit the content of the
examination. For each area/system, documentation of at least 2 elements identified by a
bullet is expected
✔✔Definition of the 1997 guidelines regarding single organ system examinations -
✔✔Variations among these examinations in the organ systems and body areas and in
the elements of the examinations reflect differing emphases among specialties. To
qualify for a given level of single organ system examination, the following content and
documentation requirements should be met: Problem Focused Examination-should
include performance and documentation of 1-5 elements identified by a bullet, whether
in a box with a shaded or unshaded border; Expanded Problem Focused Examination-
should include performance and documentation of at least 6 elements identified by a
bullet, whether in a box with a shaded or unshaded border; Detailed Examination-
ANSWERS SURE A+
✔✔Core requirements in CIAs - ✔✔Hiring a compliance officer/appointing a compliance
committee; developing written standards and policies; implementing a comprehensive
employee training program; retaining an independent review organization (IRO) to
conduct annual reviews; establishing a confidential disclosure program; restricting
employment of ineligible persons; reporting overpayments, reportable events, and
ongoing investigations/legal proceedings; providing an implementation report and
annual reports to the OIG on the status of the entity's compliance activities
✔✔Independent review organization (IRO) - ✔✔Acts as a 3rd party medical review
resource that provides objective, unbiased audits and reports
✔✔How many sampling units are selected for review in a Discovery Sample under a
CIA? - ✔✔50
✔✔Purpose of a Discovery Sample - ✔✔Used to determine the net financial error rate; if
the error rate exceeds 5%, a Full Sample must be reviewed, along with a Systems
Review
✔✔What is the name of the statistical sampling program provided by the OIG to
randomly select and determine the size of the Discovery Sample? - ✔✔RAT-STATS
,✔✔What percent of precision and confidence are required to estimate the
overpayment? - ✔✔90% confidence and 25% precision level
✔✔Certificate of Compliance Agreement (CCA) - ✔✔Require the provider to certify that
is will continue to operate its existing compliance programs and to report to OIG for a
lesser period of time (usually 3 years); introduced in Inspector General Janet
Rehnquist's An Open Letter to Healthcare Providers in November 2011
✔✔Compliance Plan - ✔✔Represents comprehensive documentation that a provider,
practice, facility, or other healthcare entity is taking steps to adhere to the federal and
state laws that affect it
✔✔Voluntary compliance plan guidance (CPG) documents - ✔✔Developed by the OIG
for a variety of healthcare settings; indicate the comprehensive framework, standards,
and principles by which an effective internal compliance program may be established
and maintained
✔✔Are compliance plans mandatory? - ✔✔No, they are currently voluntary. The
Affordable Care Act makes compliance programs mandatory for providers and other
healthcare providers but there is not yet an implementation date
✔✔How many elements has the OIG identified that should be present in every
compliance plan? - ✔✔7
✔✔Elements identified by the OIG that should be present in every compliance plan
(except for individual or small group practices) - ✔✔Implementing written policies,
procedures and standards of conduct; designating a compliance officer and/or
compliance committee; conducting effective training and education; developing effective
lines of communication; enforcing standards through well-publicized disciplinary
guidelines; conducting internal monitoring and auditing; and responding promptly to
detected offenses and developing corrective action
✔✔What should be included in the documentation of a finding of non-compliant
conduct? - ✔✔Date of incident, name of reporting party, name of the person responsible
for taking action, and the follow-up action taken
✔✔When was the CPG for individual and small group physician practices issued? -
✔✔October 5, 2000 in the Federal Register
✔✔What components of the compliance plan should be adopted by the practice? -
✔✔Based on the practice's specific history with billing problems and other issues, the
practice should begin by adopting only those components most likely to provide an
identifiable benefit
,✔✔Potential benefits of a compliance program for individual and small group practices -
✔✔Increasing accuracy of documentation; increasing the speed and optimization of
proper payment of claims; minimizing billing mistakes; reducing the chances that an
audit will be conducted by CMS or the OIG; and avoiding conflicts with the self-referral
and anti-kickback statutes
✔✔Potential risk areas for individual and small group practices indicated by the OIG in
the CPG - ✔✔Coding and billing, reasonable and necessary services, documentation,
and improper inducements, kickbacks, and self-referrals
✔✔Additional risk area for physicians listed in the appendix at the end of the CPG -
✔✔Reasonable and necessary services; physician relationships with hospitals;
physician billing practices; and other risk areas (rental of space in physician offices by
persons or entities to which physicians refer and unlawful advertising)
✔✔For which healthcare entities are CPGs listed on the OIG website? - ✔✔Nursing
facilities; hospitals; recipients of PHS research awards; pharmaceutical manufacturers;
ambulance suppliers; Medicare+Choice organizations; hospices; durable medical
equipment; prosthetics, orthotics, and supply industry (DMEPOS); third-party medical
billing companies; clinical laboratories; and home health agencies
✔✔5 practical tips provided by CMS for creating a culture of compliance - ✔✔Make
compliance plans a priority now; know your fraud and abuse risk areas; manage your
financial relationships; just because your competitor is doing something doesn't mean
you can or should; and when in doubt, ask for help
✔✔Health Care Financing Administration (HCFA)/Centers for Medicare and Medicaid
Services (CMS) - ✔✔Established in 1977 to administer the Medicare and Medicaid
programs; renamed the Centers for Medicare and Medicaid Services (CMS) in 2001;
largest agency within the Department of Health and Human Services; administers
Medicare, Medicaid, and the Children's Health Insurance Program
✔✔CMS transmittals - ✔✔Communicate new or changed policies or procedures that will
be incorporated into the CMS Online Manual System; each one has a transmittal
number, an issue date, an implementation date, a Change Request number, and a
subject name
✔✔Medicare Learning Network (MLN) - ✔✔Provides education, information, and
resources for the healthcare professional community; offers educational products,
national provider calls, provider association partnerships, provider eNews, and provider
electronic mailing lists
, ✔✔Conditions of Participation (CoP) and Conditions for Coverage (CfC) - ✔✔Standards
set forth in the Federal Register that must be met to participate in Medicare and
Medicaid Programs; they include Ambulatory Surgical Centers (ASCs), Critical Access
Hospitals (CAHs), and hospitals
✔✔Conditions of participation for medical record services - ✔✔The conditions include
that each patient should have a medical record; medical records must be organized to
allow for prompt completion, filing, and retrieval; medical records must be retained for at
least 5 years; and patient confidentiality should be protected
✔✔Definition from the 1995 guidelines regarding types of exam - ✔✔The levels of E/M
services are based on 4 types of examination that are defined as follows: Problem-
Focused-a limited examination of the affected body area or organ system; Expanded
Problem Focused-a limited examination of the affected body area or organ system and
other symptomatic or related organ system(s); Detailed-an extended examination of the
affected body area(s) and other symptomatic or related organ system(s);
Comprehensive-a general multi-system examination or complete examination of a
single organ system
✔✔Definition from the 1997 guidelines regarding general multi-system examination -
✔✔To qualify for a given level of general multi-system examination, the following
content and documentation requirements should be met: Problem Focused
Examination-should include performance and documentation of one to five elements
identified by a bullet in one or more organ system(s) or body area(s); Expanded
Problem Focused Examination-should include performance and documentation of at
least 6 elements identified by a bullet in one or more organ system(s) or body area(s);
Detailed Examination-should include at least 6 organ systems or body areas. For each
system/area selected, performance and documentation of at least 2 elements identified
by a bullet is expected. A detailed examination may include performance and
documentation of at least 12 elements identified by a bullet in 2 or more organ systems
or body areas; Comprehensive Examination-should include at least 9 organ systems or
body areas. For each system/area selected, all elements of the examination identified
by a bullet should be performed, unless specific directions limit the content of the
examination. For each area/system, documentation of at least 2 elements identified by a
bullet is expected
✔✔Definition of the 1997 guidelines regarding single organ system examinations -
✔✔Variations among these examinations in the organ systems and body areas and in
the elements of the examinations reflect differing emphases among specialties. To
qualify for a given level of single organ system examination, the following content and
documentation requirements should be met: Problem Focused Examination-should
include performance and documentation of 1-5 elements identified by a bullet, whether
in a box with a shaded or unshaded border; Expanded Problem Focused Examination-
should include performance and documentation of at least 6 elements identified by a
bullet, whether in a box with a shaded or unshaded border; Detailed Examination-
