HCCA - CHC QUESTIONS AND ANSWERS
True or False:
The ACA requires that all providers adopt a compliance plan as a condition of
enrollment with Medicare, Medicaid, and Children's Health Insurance Program (CHIP). -
Answer-True
ref. ACA section 6102
According to HHS-OIG - what are three important reasons for proper documentation in
Compliance? (hint: protections) - Answer-1.Protect our programs
2.Protect your patients
3.Protect the Provider
https://oig.hhs.gov/newsroom/podcasts/2011/heat/heat09-trans.asp#:~:text=Proper
%20documentation%2C%20both%20in%20patients,to%20protect%20you%20the
%20provider.
At which level of the Medicare Part A or Part B appeals process is the appeal decision
by the Office of Medicare Hearings and Appeals (OMHA)?
a. first level of appeal
b. second level of appeal
c. third level of appeal
d. fourth level of appeal - Answer-c. . third level of appeal
Frist level - redetermination by Medicare contractor
Second level - reconsideration by Independent contractor
Third appeal - Administrative Law Judge (ALJ) hearing
Fourth appeal - review by Medicare Appeals Council
Fifth appeal - review in Federal District Court
https://www.hhs.gov/about/agencies/omha/the-appeals-process/index.html
What should CCO be able to do? (What skills should this person have?) Choose all that
apply.
a. Leadership skills.
b. Oversee the coding department.
c. Skills to design and implement a compliance program.
d. Be able to anticipate new risk areas.
e. Practical experience with documenting medical necessity. - Answer-a. Leadership
skills,
c. Skills to design and implement a compliance program, and
d. Be able to anticipate new risk areas.
Which of the following is an absolute necessity in order to have a successful
Compliance Program?
a. continuous training and improvements
,b. effective reporting path
c. non-retaliation for whistleblowers
d. reliable and equal discipline - Answer-c. non-retaliation for whistleblowers
A Compliance Program with well written policies and procedures:
a. can be successful if consistently reviewed and maintained
b. cannot be effective due to the sheer volume presented
c. will be effective if read by management
d. will not be successful without the proper oversight - Answer-d. will not be successful
without the proper oversight
A Compliance Officer can achieve a higher level of compliance and ethics engagement
by:
a. ensuring leadership reads the policies
b. increasing management involvement
c. responding to compliance hotline calls
d. monitoring the code of conduct - Answer-b. increasing management involvement
Which of the following requires providers to be permanently excluded from all federal
health care programs if found guilty of a healthcare related fraud a third time:
a. Deficit Reduction Act of 2005
b. False Claims Act
c. Balance Budget Act of 1997
d. Social Security Act section 1128 - Answer-c. Balance Budget Act of 1997
Also known as a BBA "three strikes rule"
Which statement is TRUE regarding compliance programs?
a. Compliance programs are considered more dangerous if they are developed but not
implemented.
b. Compliance programs can detect but not prevent criminal conduct
c. Compliance programs are only required by law for healthcare entities that have more
than $500,000 in annual revenue.
d. Compliance programs are not mandated by law. - Answer-a. Compliance programs
are considered more dangerous if they are developed but not implemented.
Formal statement outlining a plan for a specified subject area. It usually cites state
and/or federal required actions or standards.
a. CAP
b. Procedure document
c. Policy document
d. Legal standards - Answer-c. Policy document
CAP - outlines corrective action plan
Procedure - describes process/steps under a certain criteria
Legal standards - mandatory action or rule
,Life cycle of records management - Answer-Creation
Use
Maintenance
Retention
Disposition
Standards of Conduct (written P&Ps) - Answer-Demonstrate the organization's ethical
attitude and its "enterprise-wide" emphasis on compliance with all applicable laws and
regulations
Code of Conduct: Content Checklist - Answer-• Demonstrate system wide emphasis on
compliance with all applicable laws and regulations
• Written plainly and concisely so all employees can understand the standards
• Includes internal and external regulations
• Mentions organizational policies without completely restating them
• Is consistent with company policies and procedures
• Includes management's responsibility to explain and enforce the code
Ref: SCCE Compliance & Ethics Manual, Chapter 2
https://compliancecosmos.org/essential-elements-effective-ethics-and-compliance-
program
Code of Conduct and Employees - Answer-All employees must receive, read, and
understand the standards.
A supervisor should explain the standards and answer any questions.
Employee should attest in writing that they have received, read, and understood the
standards
Employee compliance with standards must be enforced through appropriate discipline
when necessary
Discipline for non-compliance should be stated in the standards
Code of Conduct Purpose - Answer-• To present specific guidelines for employees to
follow
• To confirm that all employees comprehend what is required of them
• To provide a process for proper decision making
• To confirm that employees put standards into everyday practice
• To elevate corporate performance in basic business relationship
• To confirm that the organization upholds and supports proper compliance conduct
Every organization needs policies and procedures for: - Answer-• Internal assessments
• Record retention (where, how long)
• Self-disclosure
• Medicare sanction checks (LEIE)
• Billing policies
• Credit balance
, • No charge visits
• Incomplete/unsuccessful procedure
• Documentation requirements
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.
True or False:
The ACA requires that all providers adopt a compliance plan as a condition of
enrollment with Medicare, Medicaid, and Children's Health Insurance Program (CHIP). -
Answer-True
ref. ACA section 6102
According to HHS-OIG - what are three important reasons for proper documentation in
Compliance? (hint: protections) - Answer-1.Protect our programs
2.Protect your patients
3.Protect the Provider
https://oig.hhs.gov/newsroom/podcasts/2011/heat/heat09-trans.asp#:~:text=Proper
%20documentation%2C%20both%20in%20patients,to%20protect%20you%20the
%20provider.
At which level of the Medicare Part A or Part B appeals process is the appeal decision
by the Office of Medicare Hearings and Appeals (OMHA)?
a. first level of appeal
b. second level of appeal
c. third level of appeal
d. fourth level of appeal - Answer-c. . third level of appeal
Frist level - redetermination by Medicare contractor
Second level - reconsideration by Independent contractor
Third appeal - Administrative Law Judge (ALJ) hearing
Fourth appeal - review by Medicare Appeals Council
Fifth appeal - review in Federal District Court
https://www.hhs.gov/about/agencies/omha/the-appeals-process/index.html
What should CCO be able to do? (What skills should this person have?) Choose all that
apply.
a. Leadership skills.
b. Oversee the coding department.
c. Skills to design and implement a compliance program.
d. Be able to anticipate new risk areas.
e. Practical experience with documenting medical necessity. - Answer-a. Leadership
skills,
c. Skills to design and implement a compliance program, and
d. Be able to anticipate new risk areas.
Which of the following is an absolute necessity in order to have a successful
Compliance Program?
a. continuous training and improvements
,b. effective reporting path
c. non-retaliation for whistleblowers
d. reliable and equal discipline - Answer-c. non-retaliation for whistleblowers
A Compliance Program with well written policies and procedures:
a. can be successful if consistently reviewed and maintained
b. cannot be effective due to the sheer volume presented
c. will be effective if read by management
d. will not be successful without the proper oversight - Answer-d. will not be successful
without the proper oversight
A Compliance Officer can achieve a higher level of compliance and ethics engagement
by:
a. ensuring leadership reads the policies
b. increasing management involvement
c. responding to compliance hotline calls
d. monitoring the code of conduct - Answer-b. increasing management involvement
Which of the following requires providers to be permanently excluded from all federal
health care programs if found guilty of a healthcare related fraud a third time:
a. Deficit Reduction Act of 2005
b. False Claims Act
c. Balance Budget Act of 1997
d. Social Security Act section 1128 - Answer-c. Balance Budget Act of 1997
Also known as a BBA "three strikes rule"
Which statement is TRUE regarding compliance programs?
a. Compliance programs are considered more dangerous if they are developed but not
implemented.
b. Compliance programs can detect but not prevent criminal conduct
c. Compliance programs are only required by law for healthcare entities that have more
than $500,000 in annual revenue.
d. Compliance programs are not mandated by law. - Answer-a. Compliance programs
are considered more dangerous if they are developed but not implemented.
Formal statement outlining a plan for a specified subject area. It usually cites state
and/or federal required actions or standards.
a. CAP
b. Procedure document
c. Policy document
d. Legal standards - Answer-c. Policy document
CAP - outlines corrective action plan
Procedure - describes process/steps under a certain criteria
Legal standards - mandatory action or rule
,Life cycle of records management - Answer-Creation
Use
Maintenance
Retention
Disposition
Standards of Conduct (written P&Ps) - Answer-Demonstrate the organization's ethical
attitude and its "enterprise-wide" emphasis on compliance with all applicable laws and
regulations
Code of Conduct: Content Checklist - Answer-• Demonstrate system wide emphasis on
compliance with all applicable laws and regulations
• Written plainly and concisely so all employees can understand the standards
• Includes internal and external regulations
• Mentions organizational policies without completely restating them
• Is consistent with company policies and procedures
• Includes management's responsibility to explain and enforce the code
Ref: SCCE Compliance & Ethics Manual, Chapter 2
https://compliancecosmos.org/essential-elements-effective-ethics-and-compliance-
program
Code of Conduct and Employees - Answer-All employees must receive, read, and
understand the standards.
A supervisor should explain the standards and answer any questions.
Employee should attest in writing that they have received, read, and understood the
standards
Employee compliance with standards must be enforced through appropriate discipline
when necessary
Discipline for non-compliance should be stated in the standards
Code of Conduct Purpose - Answer-• To present specific guidelines for employees to
follow
• To confirm that all employees comprehend what is required of them
• To provide a process for proper decision making
• To confirm that employees put standards into everyday practice
• To elevate corporate performance in basic business relationship
• To confirm that the organization upholds and supports proper compliance conduct
Every organization needs policies and procedures for: - Answer-• Internal assessments
• Record retention (where, how long)
• Self-disclosure
• Medicare sanction checks (LEIE)
• Billing policies
• Credit balance
, • No charge visits
• Incomplete/unsuccessful procedure
• Documentation requirements
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.
