CHC Compliance Program Administration 5 — Questions and Answers
Question 1: Which federal agency maintains the List of Excluded Individuals and Entities (LEIE) that healthcare organizations must screen against?
- 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 maintains the LEIE, and healthcare organizations must screen employees, contractors, and vendors against it to avoid employing or contracting with excluded parties.
Question 2: What is the recommended approach when a compliance investigation reveals that a violation was systemic rather than an isolated incident?
- Address only the individual employees involved and close the investigation
- Implement systemic corrective actions, update policies, and provide targeted retraining (Correct answer)
- Immediately self-disclose to all relevant government agencies
- Terminate the entire department involved
Correct answer: Implement systemic corrective actions, update policies, and provide targeted retraining
Systemic violations require systemic corrective actions including policy updates, process changes, and targeted training to prevent recurrence across the organization.
Question 3: A compliance officer is asked to report to the board of directors on the compliance program. Which type of information is MOST important to include?
- Detailed descriptions of all individual employee discipline cases
- Key metrics, significant risks identified, investigations completed, and program effectiveness measures (Correct answer)
- A full list of all compliance policies in effect
- The compliance officer's personal recommendations for salary increases
Correct answer: Key metrics, significant risks identified, investigations completed, and program effectiveness measures
Board reports should focus on program performance metrics, significant risks, investigation outcomes, and overall effectiveness to enable informed governance oversight.
Question 4: What distinguishes a 'compliance program' from a 'paper program'?
- A paper program uses printed rather than electronic policies
- A compliance program is actively implemented and enforced, while a paper program exists only on paper with no real implementation (Correct answer)
- A compliance program is required by law; a paper program is voluntary
- A paper program is more detailed and comprehensive
Correct answer: A compliance program is actively implemented and enforced, while a paper program exists only on paper with no real implementation
A 'paper program' refers to a compliance program that has the required documents but lacks genuine implementation, enforcement, and cultural integration.
Question 5: Under the Affordable Care Act, which type of provider is mandated to have a compliance program as a condition of enrollment in Medicare and Medicaid?
- Only large hospital systems with more than 500 beds
- Nursing facilities (skilled nursing facilities and nursing facilities) (Correct answer)
- Any provider that accepts private insurance
- Only providers under a Corporate Integrity Agreement
Correct answer: Nursing facilities (skilled nursing facilities and nursing facilities)
The ACA mandated that nursing facilities have a compliance and ethics program as a condition of participation in Medicare and Medicaid.
Question 6: Which of the following BEST describes the concept of 'proportionality' in applying disciplinary actions under a compliance program?
- All violations should result in immediate termination to deter misconduct
- Discipline should be commensurate with the severity of the violation and applied consistently (Correct answer)
- Discipline should only apply to senior-level employees
- Disciplinary actions should be kept secret to avoid embarrassment
Correct answer: Discipline should be commensurate with the severity of the violation and applied consistently
Proportionality ensures that disciplinary sanctions fit the severity of the violation and are applied consistently to maintain fairness and deter future misconduct.
Question 7: When a compliance officer conducts a root cause analysis following a compliance incident, what is the PRIMARY goal?
- To assign personal blame to the employee who committed the violation
- To identify the underlying systemic factors that allowed the violation to occur (Correct answer)
- To calculate the financial penalty owed to regulators
- To determine whether to self-disclose the incident
Correct answer: To identify the underlying systemic factors that allowed the violation to occur
Root cause analysis focuses on identifying systemic breakdowns in processes, training, or controls—not individual blame—so that effective corrective actions can be designed.
CHC Compliance Program Administration 5
Which federal agency maintains the List of Excluded Individuals and Entities (LEIE) that healthcare organizations must screen against?