CHC Remedial Measures and Discipline 5

Question 1

When an organization decides to exclude an individual from participation in its operations following a compliance violation, it must first check the:

Accepted Answer

OIG List of Excluded Individuals and Entities (LEIE) and SAM.gov

Answer

State tax records for outstanding liens

Answer

Employee's social media profiles

Answer

Medicare Advantage plan enrollment database

Question 2

A 'root cause analysis' conducted as part of a corrective action plan should PRIMARILY answer which question?

Accepted Answer

Why did the violation occur and what systemic conditions enabled it?

Answer

Who is personally liable for the violation?

Answer

How much revenue was lost due to the violation?

Answer

Which competitor organization has the same problem?

Question 3

An employee alleges that they were wrongfully terminated in retaliation for reporting a compliance concern. Under the False Claims Act's anti-retaliation provisions, the employee may:

Accepted Answer

Seek reinstatement, double back pay, and attorneys' fees

Answer

Only seek reinstatement but not back pay

Answer

Only file a complaint with the state labor board

Answer

Seek unlimited punitive damages without proof of harm

Question 4

During a compliance audit, it is discovered that a department head had prior knowledge of ongoing billing fraud but failed to act. The MOST appropriate discipline for the department head is:

Accepted Answer

Discipline commensurate with their supervisory responsibility for failing to act, potentially including termination

Answer

A verbal reminder of compliance obligations with no formal record

Answer

Transfer to a different department where billing is not performed

Answer

No action, because they did not personally submit false claims

Question 5

A corrective action plan is MOST effective when it includes which of the following mechanisms?

Accepted Answer

Defined milestones, accountability assignments, and ongoing monitoring to verify implementation

Answer

A one-time review with no follow-up monitoring

Answer

Delegation of all corrective actions to the accused employee

Answer

A commitment to disclose future violations only if material in amount

Question 6

Which of the following BEST describes 'progressive discipline' as used in healthcare compliance programs?

Accepted Answer

Applying escalating sanctions starting with counseling and increasing to termination for repeated or serious violations

Answer

Immediately terminating employees at the first sign of misconduct

Answer

Reducing discipline severity each time a violation occurs to encourage reporting

Answer

Applying identical sanctions regardless of violation severity or employee history

Question 7

After completing a self-disclosure to the OIG Self-Disclosure Protocol, the organization should expect the OIG to:

Accepted Answer

Acknowledge receipt, conduct its own review, and negotiate a settlement that may include a multiplier on the overpayment

Answer

Immediately exclude the organization from Medicare and Medicaid

Answer

Automatically waive all penalties without further review

Answer

Refer the matter to the DOJ for criminal prosecution in all cases