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CPMA Exam Chapter 5: Self-Disclosure Audits Study Guide

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CPMA Exam Chapter 5: Self-Disclosure Audits Study Guide The OIG Self-Disclosure Protocol (SDP) provides the - Answer-ability to self-disclose potential instances of fraud involving federal healthcare programs for which liability arises under the OIG's civil money penalty authorities The SDP (S...

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  • October 15, 2024
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CPMA Exam Chapter 5: Self-Disclosure
Audits Study Guide

The OIG Self-Disclosure Protocol (SDP) provides the - Answer✔✔-ability to self-disclose

potential instances of fraud involving federal healthcare programs for which liability arises

under the OIG's civil money penalty authorities


The SDP (Self-Disclosure Protocol) is not for reporting of - Answer✔✔-potential or actual Stark

(self-referral) violations;




It is not a means to obtain an advisory opinion to determine if the suspect conduct is unlawful.


For potential or actual STARK law violations, the HHS provides - Answer✔✔-a separate

disclosure process called the Self-Referral Disclosure Protocol (SDRP)


Where errors result in mere overpayments for which there was not evidence of fraudulent

conduct, an entity must - Answer✔✔-voluntarily identify, disclose, and refund overpayments as

detailed above so as to avoid False Claims Act (FCA) liability under the "reverse false claims

provision" of the FCA.


Although an auditor is unlikely to be responsible for managing such disclosures, an auditor may

need to be involved in - Answer✔✔-identifying the scope of the error (the sampling frame).



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If decision is made to either perform a 100% audit, or to audit a sample, the auditor will -

Answer✔✔-perform the actual analysis of the suspect claims to identify the existence of any

legally definable error.




In such a case, the auditor must be very clear in detailing the rational for any error or change in

code,




as well as to detail the financial impact associated with the auditor's conclusions (usually, on a

service-specific basis).


In addition to identifying the appropriate binding standards, where a change in code is the

result, the auditor may be asked to identify the appropriate - Answer✔✔-fee schedule

allowance in effect at the time, so that the specific financial impact associated with any

detected error can be identified and refunded.


In some cases, no auditing may be required - Answer✔✔-because the dollar value of an

overpayment can be identified through simple data analysis




AN EXAMPLE: A circumstance might be overpayment associated with non-conformance with

the incident-to rule




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