CHC Compliance Program Administration
2023-2024
A compliance program at its most basic level would be: (think of the 1st CP element) -
Answer-A set of
... [Show More] internal policies and procedures that you put into place to help your
organization comply with the law.
Before developing a Compliance Program, FIRST, conduct a ___ _______, then,
NEXT, _____ risks to help you define the basis for what the compliance program should
focus on for the next year in its plan. - Answer-risk assessment;
prioritize
There is no established template for documenting compliance risks. Each organization
should develop a Risk Assessment that fits its risk profile. The components that are
commonly used throughout the industry are as follows EXCEPT:
a. Risk Assessment
b. Measuring key risk indicators
c. Identifying key performance indicators
d. Training the leadership of compliance regulation program - Answer-d. Training the
leadership of compliance regulation program
Ref. ABA CRCM (certified regulatory compliance manager)
The compliance program should address plans to verify adherence to applicable laws
and regulations through:
a. ongoing monitoring to evaluate the program, self-monitoring and corrective action
b. self-monitoring
c. Periodic reviews
d. Ongoing monitoring to evaluate the program, self-monitoring and period reviews -
Answer-a. ongoing monitoring to evaluate the program, self-monitoring and corrective
action
Ref. ABA CRCM (certified regulatory compliance manager)
ABC Hospital is under a 5-year CIA with government-imposed requirements for
development of a Compliance Program and use of external auditor for periodic claim
reviews. Which of the following is TRUE:
a. Costs to meeting terms of the CIA are permitted to be included in the cost report like
any other operational cost.
b. Because the hospital agreed to a settlement and was not convicted for alleged
violations, the Compliance Program is considered a voluntary program.
c. The government chooses and pays for the external auditors.
d. None of the above - Answer-d. None of the above.
Explanation:
• CIA-related costs CANNOT be included in the cost report.
• Government-imposed Compliance Program ARE NOT considered a voluntary
program.
• Hospital is required to choose and pay for any auditors (with government review and
right to object)
Most expenses related to developing and implementing a compliance program are
considered the cost of doing business and are tax deductible for the organization.
Which of the following is NOT tax deductible?
a. When the expense costs are more than the national average
b. When the expenses are a result of the imposition of a penalty
c. The annual maintenance of the program
d. The salary of the compliance officer - Answer-b. When the expenses are a result of
the imposition of a penalty.
CIA is a penalty imposed upon the organization and, as with any other governmental
penalty; the expense of the development, implementation, and maintenance of this
program cannot be included as a deductible expense to the organization.
Note: practice question from AAPC CPCO Ch2
Sue works for ABC Family Physicians. The providers at this office ask her to research
the department that helps protect patients from unfair treatment or discrimination. What
department or agency would that be?
a. Equality in Employment Agency
b. Office for Civil Rights
c. Department of Justice
d. Office of Inspector General - Answer-b. Office for Civil Rights (OCR)
DOL oversees employment discrimination;
DOJ enforces federal criminal law and implements criminal law policies;
OIG combats FWA in Medicare, Medicaid and HHS Programs.
Note: practice question from AAPC CPCO Ch1
Payers expect all providers to refund monies that are overpayments. By law, how long
does the provider have to refund overpayments once discovered?
a. A timely manner, the specific number of days is not specified
b. 60 days after receipt of overpayment
c. 60 days after identification of overpayment
d. 90 days after a request by the payer - Answer-c. 60 days after identification of
overpayment
Under Section 6402 of the ACA, a provider must refund Medicare within 60 days of
identifying the overpayment.
Note: practice question from AAPC CPCO Ch2
Information provided from a hotline call involves a senior manager and indicates
potential research misconduct. The caller is concerned about losing her job. Which of
the following should the compliance professional tell the employee:
a. "retaliation is prohibited by policy"
b. "confidentiality will always be maintained"
c. "HIPAA regulations ensure confidentiality"
d. "the ORI must be notified of this hotline call" - Answer-a. "retaliation is prohibited by
policy"
Benefits of Compliance Programs. List a few - Answer-• Safeguards organization legal
responsibility to abide by applicable laws and regulations
• Demonstrate organization's commitment to good corporate conduct
• Provide a more accurate view of employee and contractor behavior relating to fraud
and abuse
• Identify and prevent criminal and unethical conduct
• Improve the quality of patient care
• Create a centralized source of info on healthcare regulations
• Develop a methodology to encourage employees to report potential problem
• Develop procedures that allow the prompt and through investigation of alleged
misconduct
• Initiate immediate and appropriate corrective action
• Reduce organization remedies, such as program exclusion
Ref: OIG CPG for Hospitals
Which statement is TRUE regarding compliance programs?
a. Compliance programs are not mandated by law.
b. Compliance programs are only effective after the baseline audit has been performed
and policies written.
c. Compliance programs are only required by law for healthcare entities that have more
than $500,000 in annual revenue.
d. Compliance programs are considered more dangerous if they are developed but not
implemented. - Answer-d. Compliance programs are considered more dangerous if they
are developed but not implemented.
The only thing worse than not having a Compliance Program is to have a Compliance
Program that is not implemented. (same with P&Ps)
Note: practice question from AAPC CPCO Ch2
True or False:
Experienced compliance health care personnel can do, and want to do, what is called
"double duty" as trainers and line performers - Answer-TRUE
Compliance Committee Purpose - Answer-"to advise the compliance officer and assist
in the implementation of the compliance program"
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