Prep Test 3

Question 1

Code of Conduct

Answer 1

Must be distributed within 90 days of hire

Question 2

OIG can impose mandatory exclusion for a minimum of

Answer 2

5 years

Question 3

OIG suggests training be separated into two sessions:

Answer 3

• The first a general session on compliance for all employees and
• The second covering more specific information for appropriate personal

Question 4

OIG Work Plan

Answer 4

Identifies high risk and key areas of focus for auditing

Question 5

72 hour rule

Answer 5

Stipulates that diagnostic tests provided on an outpatient basis within 72 hours of an admission must be billed as part of the admission DRG.

Question 6

Anti-kickback statute

Answer 6

Prohibits any Knowing and willful conduct involving solicitation, receipts, offers, or payments of any kind of remuneration in return for referral an individual or for recommendations or arranging the purchase, lease, or ordering of an item or service that may be wholly or partly paid for under a federal healthcare program.

Question 7

Project Bad Bundled

Answer 7

OIG effort to identify a laboratory test proceeded in groups but reported individually at a higher rate of reimbursement; also known as unbundling

Question 8

Lincoln’s Law

Answer 8

Refers to the false claim act giving that the FCA was introduced during the Civil War

Question 9

Compliance Committee

Answer 9

“To advise the compliance officers and assist in the implementation of the compliance program.”

Question 10

Function of Compliance Committee

Answer 10

• analyzing legal requirement in specific risk areas
• regularly reviewing and assessing policies and procedures
• Assisting with the development of standards of conduct and policies and procedures
• monitoring internal systems related to standardspolicies and procedures
• determining the appropriate strategy to promote compliance
• developing a system to solicit, Evaluate and respond to complaints and problems

Question 11

Compliance Program Responsibilities according to OIG

Answer 11

1. ) oversight and implementation of a compliance program
2. ) reporting on a regular basis to government body, CEO, and compliance committee
3. ). Revising compliance program as needed
4. ) developing, coordinating, and participating in training and education
5. ). Ensuring contractors and agents are aware of compliance program requirements
6. ) ensuring background checks are done to eliminate sanctioned individuals and contractors
7. ). Assisting with internal compliance reviews and monitoring activities
8. ) Independently investigating and acting on matters related to compliance

Question 12

HCCA prepared and published Code of Ethic for Healthcare Compliance Professional addressing 3 principles

Answer 12

1. ) obligation to public
2. ) Obligation to employing organizations - should serve organization with highest sense of integrity, unprejudiced, and unbiased judgment
3. ) obligation to profession - uphold integrity and dignity of profession, To advance effectiveness of compliance program and to promote professionalism in healthcare compliance

Question 13

Caremark international Derivative Litigation

Answer 13

Makes the board responsible for implementation of system to gather information on the company’s efforts to rent in detect fraud and abuse

Question 14

FSG suggests offering

Answer 14

Incentive to those who carry all the complaints fromEthics program

Question 15

Federal Sentencing Guidelines(FSG)

Answer 15

Very clear on the expected board commitment

Question 16

A teaching hospital may want their support for compliance program

Answer 16

To come from the Dean

Question 17

DRG Creep

Answer 17

Using a Diagnosis Related Group(DRG) code that provides a higher payment rate than the DRG code that accurately reflects the service furnished to the patient.

Question 18

Teaching physician Rule

Answer 18

Special documentation requirement for services provided by residents and teaching physicians.

Question 19

Every organization needs policies and procedures for:

Answer 19

1) internal assessment
2) record retention(where, how long)
3) self-disclosure
4) Medicare sanction check(LEIE)
5) billing policies
6) unbundling
7) credit balance
8) no charge visit
9) incomplete/unsuccessful procedure
10) documentation requirement

Question 20

Upcoming

Answer 20

Using a billing code that provides a higher reimbursement rate than the billing code that was actually reflecting the service furnished. Major focus of OIG enforcement efforts and HIPAA added additional seven monetary penalties to OAG sanctions

Question 21

In all OIG program guidance

Answer 21

The first prescribed element calls for the development and distribution of written standards of conduct, as well as written policies and procedures that promote a commitment to compliance.

Question 22

Code of Conduct: Content Checklist

Answer 22

1) demonstrates system wide emphasis on compliance with all applicable laws and regulations
2) written plainly and concisely so all employees can understand the standards
3) . Includes internal and external regulations
4) mentions organizational policies without completely restating them
5) is consistent with company policies and procedures

Question 23

Obstacles to Effective Compliance Implementation (1-5)

Answer 23

1) commitment and buy-in
2) lack of funding
3) too many roles for compliance professional
4) interpreting laws and regulations
5) lack of resources and staff

Question 24

Obstacles to Effective Compliance Implementation (6-10)

Answer 24

1) lack of education and training
2) resistance to change
3) lack of or poor communication
4) fear of retaliation/retribution
5) no internal enforcement

Question 25

Code of Conduct and Employees

Answer 25

1) all employees must receive, read, and understand the standards 2) a supervisor should explain the standards and answer any questions 3) employee should attest in writing that they have received, read, and understand the standards 4) employee compliance with standards must enforce through appropriate discipline when necessary 5) disciple for non-compliance should be stated in the standards

Question 26

Code of Conduct Purpose

Answer 26

1) to present specific guidelines for employees to follow 2) to confirm that all employees comprehend what is required of them 3) to provide a process for proper decision making 4) to confirm that employee put standards into everyday practice 5) to elevate corporate performance in basic business relationship 6) to confirm that the organization upholds and supports proper compliance conduct

Question 27

Compliance policies and procedures should be integrated into existing policies

Answer 27

Only thing worse than not having a policy is having a policy and not following it. Develop policies carefully and review them regularly. Make sure they realistic and measurable.

Question 28

Development of policies and procedures begin with areas of risk

Answer 28

Targeting areas on OIG Work Plan that apply to your organization and adequately address them in your policies and procedures.