CHC Remedial Measures and Discipline 4

Question 1

A compliance officer is reviewing a case where a nurse submitted false time records. The investigation is complete and discipline is warranted. Which sequence reflects BEST practice?

Accepted Answer

Investigate thoroughly, document findings, consult HR and legal, then impose proportional discipline

Answer

Discipline first, then investigate to confirm findings

Answer

Issue termination immediately upon allegation to protect the organization

Answer

Refer all cases to law enforcement before taking internal action

Question 2

Which of the following is an example of a SYSTEMIC remedial measure rather than an individual disciplinary measure?

Accepted Answer

Revising the billing policy and retraining the entire coding department

Answer

Terminating the employee who submitted false claims

Answer

Issuing a written warning to a supervisor

Answer

Placing an individual employee on a performance improvement plan

Question 3

An IRO (Independent Review Organization) engaged under a CIA is PRIMARILY responsible for:

Accepted Answer

Conducting independent reviews of claims and operations to verify compliance program effectiveness

Answer

Filing criminal charges against employees who violate the CIA

Answer

Replacing the organization's internal audit department entirely

Answer

Negotiating settlement terms on behalf of the OIG

Question 4

A compliance investigation finds that a vendor, not an employee, caused the billing error. The MOST appropriate remedial step is to:

Accepted Answer

Review and strengthen vendor contracts, oversight procedures, and potentially terminate the vendor relationship

Answer

Ignore the finding because only employees can be disciplined

Answer

Transfer liability to the vendor through a retroactive indemnification clause

Answer

File a False Claims Act whistleblower suit against the vendor

Question 5

Under the OIG's compliance program guidance, effective discipline programs must be applied to:

Accepted Answer

All levels of the organization, including senior management and executives

Answer

Only frontline staff and coders

Answer

Physicians only, because they generate billing

Answer

Temporary contractors who are not W-2 employees

Question 6

Which of the following actions would MOST likely be considered an aggravating factor when determining the severity of discipline for a compliance violation?

Accepted Answer

The employee concealed evidence and continued the conduct after warnings

Answer

The employee self-reported the violation before it was discovered

Answer

The employee cooperated fully with the investigation

Answer

The employee had no prior disciplinary history

Question 7

A compliance officer wants to ensure that disciplinary policies align with the Stark Law and Anti-Kickback Statute requirements. This means discipline policies should address:

Accepted Answer

Referral arrangements, financial relationships with referral sources, and remuneration to or from physicians

Answer

Only HIPAA privacy violations

Answer

Exclusively billing and coding errors

Answer

Only violations reported through the external hotline