CCT OIG Compliance Guidance 4

Question 1

The OIG's 'permissive exclusion' authority differs from mandatory exclusion in that:

Accepted Answer

The OIG has discretion whether to exclude based on the specific facts

Answer

Permissive exclusions allow the OIG to weigh circumstances and decide whether exclusion is appropriate, unlike mandatory exclusions triggered automatically by conviction.

Question 2

According to OIG compliance guidance for hospitals, which department most commonly generates high-risk billing areas?

Accepted Answer

Emergency departments and outpatient services

Answer

OIG hospital CPGs consistently flag emergency departments and outpatient services as high-risk because of complex coding, observation vs. inpatient decisions, and high claim volumes.

Question 3

What is the primary distinction between the False Claims Act and the Anti-Kickback Statute in OIG enforcement?

Accepted Answer

The FCA targets false or fraudulent claims to government programs; the AKS targets corrupt payment arrangements

Answer

The FCA imposes liability for submitting false or fraudulent claims to federal programs, while the AKS prohibits corrupt remuneration arrangements intended to generate referrals.

Question 4

OIG guidance recommends that compliance programs conduct regular internal monitoring and auditing primarily to:

Accepted Answer

Detect and correct compliance problems before they escalate or are discovered externally

Answer

Ongoing monitoring and auditing allow organizations to identify and self-correct issues proactively, reducing exposure and demonstrating a commitment to compliance.

Question 5

Which OIG safe harbor protects discounts offered by vendors to purchasers of healthcare goods or services?

Accepted Answer

The discount safe harbor

Answer

The discount safe harbor protects price reductions given by sellers to buyers if the discount is properly disclosed and appropriately reflected in the buyer's cost reports.

(CCT) Certified Compliance Technician Practice Test

(CCT) Certified Compliance Technician Practice Test

CCT OIG Compliance Guidance 4