Q: Related to Corporate Integrity Agreements with the government, what is an IRO and what
are the details of how it works? Choose 2 answers.
a. Independent Reorganization Operation.
b. They do the auditing required by a CIA.
c. The OIG hires them.
d. They need to be fair and unbiased and can’t have a financial relationship with the hospital.
Answer:
b. They do the auditing required by a CIA.
d. They need to be fair and unbiased and can’t have a financial relationship with the hospital.
Explanation: IROs need to meet criteria and follow the AICPA and SEC guidance (unbiased
judgement, honest neutrality, and demonstrate independence among other requirements)
Q: A person comes to your pharmacy to drop off a prescription for a beneficiary who is a
“regular” customer. The prescription is for a controlled substance with a quantity of 160. This
beneficiary normally receives a quantity of 60, not 160. You review the prescription and have
concerns about possible forgery. What is your next step?
A. Fill the prescription for 160
B. Fill the prescription for 60
C. Call the prescriber to verify quantity
D. Call the sponsor’s compliance department
E. Call law enforcement
Answer:
C. Call the prescriber to verify quantity
Call the prescriber to verify. If the subscriber verifies that the quantity should be 60 and not 160
your next step should be to immediately call the sponsor’s compliance hotline. The sponsor will
provide next steps.
Q: Your job is to submit risk diagnosis to CMS for purposes of payment. As part of this job you
are to verify, through a certain process, that the data is accurate. Your immediate supervisor tells
you to ignore the sponsor’s process and to adjust\/add risk diagnosis codes for certain individuals.
What do you do?
A. Do what is asked of your immediate supervisor
B. Report the incident to the compliance department (via compliance hotline or other
mechanism)
C. Discuss concerns with immediate supervisor
D. Contact law enforcement
Answer:
B. Report the incident to the compliance department (via compliance hotline or other
mechanism)
The compliance department is responsible for investigating and taking appropriate action. Your
sponsor\/supervisor may NOT intimidate or take retaliatory action against you for good faith
reporting concerning a potential compliance, fraud, waste, or abuse issue.
Q: The compliance professional is at the step of the risk assessment process that is primarily
based around risk tolerance information and inherent risk assessment information. What step is
MOST closely associated with this information?
a. Assess inherent likelihood of determined risks.
b. Determine risk tolerance.
c. Assess residual impact of the risks.
d. Evaluate the portfolio of risk and determine what the risk responses will be.
Answer:
d. Evaluate the portfolio of risk and determine what the risk responses will be
Q: An Organization identifies a potential issue when reviewing personal services and
management contracts. Which of the following should the compliance professional consider in
analyzing the issue?
a. Deficit Reduction Act (DRA)
b. Conditions of Participation (CoP)
c. IRS tax-exempt guidelines
d. Anti-Kickback (AKS) Safe Harbors
Answer:
d. Anti-Kickback (AKS) Safe Harbors
Q: You are the new Compliance Officer, hired after ABC Hospital reorganized and decided that
the General Counsel should no longer also serve in that role. Upon review of the Code of
Conduct (CoC), you find that it is written using lots of legal jargon. What action do you take:
a. Keep CoC as it is.
b. Pull a sample off the internet and insert hospital name to save time as it was most likely
written by experts.
c. Rewrite the CoC in plain and concise language tailored to the hospital so employees can use a
general guidance.
d. Rewrite the CoC with detailed restating hospital’s P&Ps, and all laws and regulations possible
so that employees can’t say they were not aware of requirements.
Answer:
c. Rewrite the CoC in plain and concise language tailored to the hospital so employees can use a
general guidance.
Explanation:
CoC should be clear and concise language easy to understand, and should be tailored to specific
issues of the organization
Q: A compliance professional is reviewing the policies and procedures for exclusion
verifications. The policy does not state frequency of exclusion verifications. How frequent
should exclusion verifications be performed?
a. Annually
b. Bi-annually
c. Monthly
d. Semi-annually
Answer:
c. monthly (as recommended by OIG to avoid risk)
Q: A hotline caller states the coding department was instructed to code based on LCD
requirements regardless of medical record information. Which of the following should be the
compliance professional’s FIRST action?
a. direct the coding supervisor to follow the applicable policy
b. incorporate the coding issue into next year’s risk assessment
c. design a review to find facts and circumstances related to the compliant
d. engage outside counsel to protect the underlying facts from discovery
Answer:
c. design a review to find facts and circumstances related to the compliant
Q: During Attorney-Client Privilege considerations in a corporate compliance investigation,
which of the following does not sound appropriate:
a. CO should determine who should conduct investigation
b. When initially contacting counsel, clarify the purpose is to see counsel and define
investigative strategy as appropriate (who investigation results be reported to, internal reviews to
be conducted, individuals to be interviewed, documents that should be subject to privilege, etc.)
c. Conduct internal investigation with in-house counsel and avoid engaging with outside counsel
and other consultants to ensure confidentiality
Answer:
c. Conduct internal investigation with in-house counsel and avoid engaging with outside counsel
and other consultants to ensure confidentiality
Note: The best way to ensure that communications exchanged during an internal investigation
are protected by the attorney-client privilege is to use outside counsel as necessary, or other
consultants that specialize in these matters
Q: Your organization needs to conduct an audit of its billing practices. Which of the following
sampling issues is NOT correct?
a. The time frame of the samples should reflect the scope of the audit
b. A small sample should not be used because it is not statistically meaningful
c. A large sample is not necessary because there is little variability in the sample population
d. The validity of a sampling plan is contingent on having a reasonable sound compliance plan in
place
Answer:
b. A small sample should not be used because it is not statistically meaningful
Q: A compliance professional identified an issue with medical necessity. The compliance
professional should collaborate with the:
a. case manager
b. billing clerk
c. documentation specialist<\/p>\n","protected":false},"excerpt":{"rendered":"
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