OIG Compliance Guidance Flashcards
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Read the first 7 OIG Compliance Guidance flashcards as text
What is the primary purpose of the OIG's Compliance Program Guidance (CPG) documents?
Answer: To provide voluntary frameworks helping organizations develop effective compliance programs
OIG CPGs are voluntary guidance documents that help organizations design and implement effective compliance programs, not legally binding regulations.
Which OIG document outlines the 'seven elements' considered fundamental to an effective compliance program?
Answer: The Federal Sentencing Guidelines Chapter 8
The Federal Sentencing Guidelines Chapter 8 first articulated the seven core elements that the OIG adopted as the foundation for effective compliance programs.
An OIG Advisory Opinion is issued in response to:
Answer: Specific requests from requesting parties about the OIG's view on a particular arrangement
Advisory Opinions are issued only to the requesting party and apply solely to that party's described arrangement, not to the general public.
Under OIG guidance, which of the following best describes a 'kickback' arrangement in the healthcare context?
Answer: Any remuneration offered to induce or reward referrals of federal healthcare program business
The Anti-Kickback Statute prohibits any remuneration—cash or in-kind—intentionally given to induce or reward referrals of items or services covered by federal healthcare programs.
The OIG's 'Special Fraud Alerts' are best described as:
Answer: Public notices identifying specific arrangements the OIG views as particularly problematic
Special Fraud Alerts are public communications that warn providers about specific practices the OIG considers fraudulent or abusive under federal law.
Which safe harbor under the Anti-Kickback Statute protects properly structured investment interests?
Answer: The investment interests safe harbor
The investment interests safe harbor protects returns on equity investments when certain criteria—such as investment terms not being based on referral volume—are met.
When an OIG Compliance Program Guidance recommends that providers conduct 'risk assessments,' what is the intended outcome?
Answer: To identify areas of greatest compliance vulnerability specific to the organization
Risk assessments help organizations identify and prioritize their specific areas of regulatory and compliance vulnerability so resources can be focused accordingly.