CHC Regulatory Compliance and Government Oversight Questions and Answers 1 — Questions and Answers
Question 1: Which federal agency publishes the OIG Work Plan that healthcare compliance officers use to prioritize audit areas each year?
- Centers for Medicare & Medicaid Services (CMS)
- Office of Inspector General (OIG) (Correct answer)
- Department of Justice (DOJ)
- Office for Civil Rights (OCR)
Correct answer: Office of Inspector General (OIG)
The OIG publishes its annual Work Plan to identify areas of focus for audits and investigations in Medicare and Medicaid programs.
Question 2: What is the primary purpose of the OIG's List of Excluded Individuals and Entities (LEIE)?
- To identify providers with malpractice judgments
- To list healthcare entities with HIPAA violations
- To identify parties excluded from participating in federal healthcare programs (Correct answer)
- To track providers under active DOJ investigation
Correct answer: To identify parties excluded from participating in federal healthcare programs
The LEIE identifies individuals and entities excluded from participation in Medicare, Medicaid, and other federal healthcare programs due to fraud, abuse, or other disqualifying conduct.
Question 3: A Corporate Integrity Agreement (CIA) is typically entered into between a healthcare entity and which agency?
- CMS
- OIG (Correct answer)
- DOJ
- Joint Commission
Correct answer: OIG
CIAs are negotiated between the OIG and healthcare providers as a condition of settling False Claims Act cases, requiring ongoing compliance obligations.
Question 4: Under the Stark Law (42 U.S.C. § 1395nn), which of the following best describes a 'designated health service'?
- Any service billed to a commercial insurer
- Specific services including clinical laboratory and physical therapy that trigger the self-referral prohibition (Correct answer)
- Any service provided in a hospital setting
- Services provided exclusively by physicians
Correct answer: Specific services including clinical laboratory and physical therapy that trigger the self-referral prohibition
Stark Law designates specific health services such as clinical laboratory, physical therapy, radiology, and others where physician self-referral to entities with a financial relationship is prohibited.
Question 5: Which statute imposes criminal and civil penalties for knowingly submitting false claims to federal healthcare programs?
- Anti-Kickback Statute
- False Claims Act (Correct answer)
- Stark Law
- HIPAA Privacy Rule
Correct answer: False Claims Act
The False Claims Act (31 U.S.C. §§ 3729–3733) imposes liability on persons who knowingly present false or fraudulent claims for payment to the federal government.
Question 6: What does 'safe harbor' mean in the context of the Anti-Kickback Statute?
- A clause protecting patients from billing disputes
- Specific arrangements that are protected from prosecution under the AKS (Correct answer)
- A HIPAA exemption for small providers
- An OIG-approved compliance program framework
Correct answer: Specific arrangements that are protected from prosecution under the AKS
Safe harbors under the AKS are regulatory exceptions that protect certain business arrangements from prosecution if they meet specific criteria.
CHC Regulatory Compliance and Government Oversight Questions and Answers 1
Which federal agency publishes the OIG Work Plan that healthcare compliance officers use to prioritize audit areas each year?