CCT OIG Compliance Guidance 2

Question 1

What is the primary purpose of the OIG's Compliance Program Guidance (CPG) documents?

Accepted Answer

To provide voluntary frameworks helping organizations develop effective compliance programs

Answer

To establish legally binding regulations for healthcare organizations

Answer

To replace the need for internal audits within healthcare entities

Answer

To set mandatory penalty schedules for HIPAA violations

Question 2

Which OIG document outlines the 'seven elements' considered fundamental to an effective compliance program?

Accepted Answer

The Federal Sentencing Guidelines Chapter 8

Answer

The OIG Work Plan

Answer

The HHS Inspector General Act

Answer

The Compliance Program Effectiveness Tool

Question 3

An OIG Advisory Opinion is issued in response to:

Accepted Answer

Specific requests from requesting parties about the OIG's view on a particular arrangement

Answer

Congressional inquiries about proposed healthcare legislation

Answer

Requests from the public regarding general compliance questions

Answer

State Medicaid agencies seeking guidance on billing disputes

Question 4

Under OIG guidance, which of the following best describes a 'kickback' arrangement in the healthcare context?

Accepted Answer

Any remuneration offered to induce or reward referrals of federal healthcare program business

Answer

A penalty assessed by CMS for late claim submissions

Answer

A rebate issued by a pharmaceutical manufacturer to a wholesaler

Answer

A shared savings arrangement between unaffiliated hospitals

Question 5

The OIG's 'Special Fraud Alerts' are best described as:

Accepted Answer

Public notices identifying specific arrangements the OIG views as particularly problematic

Answer

Formal enforcement actions notifying providers of imminent prosecution

Answer

Mandatory corrective action plans issued to non-compliant organizations

Answer

Annual reports summarizing all healthcare fraud convictions

Question 6

Which safe harbor under the Anti-Kickback Statute protects properly structured investment interests?

Accepted Answer

The investment interests safe harbor

Answer

The personal services safe harbor

Answer

The managed care safe harbor

Answer

The referral services safe harbor

Question 7

When an OIG Compliance Program Guidance recommends that providers conduct 'risk assessments,' what is the intended outcome?

Accepted Answer

To identify areas of greatest compliance vulnerability specific to the organization

Answer

To calculate the financial reserves needed for potential False Claims Act settlements

Answer

To satisfy mandatory reporting requirements under the Stark Law

Answer

To document patient safety incidents for accreditation purposes