CCT OIG Compliance Guidance 3

Question 1

The OIG's Corporate Integrity Agreements (CIAs) are typically entered into as a condition of:

Accepted Answer

Settling civil or administrative fraud and abuse matters with the OIG

Answer

CIAs are negotiated as part of civil settlements and require organizations to implement specific compliance measures in exchange for not being excluded from federal programs.

Question 2

Under OIG guidance, what is the significance of the 'one purpose test' in Anti-Kickback Statute cases?

Accepted Answer

A transaction is illegal if even one purpose of the remuneration is to induce federal program referrals

Answer

Courts applying the 'one purpose test' hold that the AKS is violated if any one purpose—even if not the primary one—of a payment is to induce referrals.

Question 3

Which OIG Work Plan tool allows compliance officers to monitor what areas the OIG will review in a given fiscal year?

Accepted Answer

The OIG Work Plan, updated throughout the year

Answer

The OIG Work Plan is updated continuously and identifies the specific audits, evaluations, and inspections OIG plans to conduct, helping providers focus internal reviews.

Question 4

OIG guidance states that a compliance program's training should be:

Accepted Answer

Tailored to the specific roles and risk areas of employees receiving it

Answer

Effective training under OIG guidance must be role-specific, addressing the compliance risks most relevant to each employee's function.

Question 5

What does the OIG's exclusion authority allow it to do?

Accepted Answer

Bar individuals and entities from participating in federal healthcare programs

Answer

The OIG can exclude individuals and entities from Medicare, Medicaid, and other federal healthcare programs, making it unlawful for programs to pay claims they submit.

(CCT) Certified Compliance Technician Practice Test

(CCT) Certified Compliance Technician Practice Test

CCT OIG Compliance Guidance 3