CPHRM Regulatory Compliance 3 — Questions and Answers
Question 1: The OIG's Corporate Integrity Agreement (CIA) is typically entered into when:
- A hospital voluntarily reports a compliance issue
- A provider settles a False Claims Act case with the government (Correct answer)
- CMS identifies a billing discrepancy during a routine audit
- The Joint Commission places a hospital on Accreditation Watch
Correct answer: A provider settles a False Claims Act case with the government
CIAs are negotiated between the OIG and providers or entities as part of civil settlement agreements, typically requiring enhanced compliance oversight for 3-5 years.
Question 2: HIPAA's Minimum Necessary Standard requires covered entities to:
- Encrypt all protected health information at rest
- Limit PHI use and disclosure to the minimum needed for the intended purpose (Correct answer)
- Obtain written authorization for all disclosures of PHI
- Conduct annual audits of all workforce access to PHI
Correct answer: Limit PHI use and disclosure to the minimum needed for the intended purpose
The Minimum Necessary Standard requires covered entities to make reasonable efforts to limit PHI use, disclosure, and requests to the minimum necessary to accomplish the intended purpose.
Question 3: Under the Americans with Disabilities Act (ADA), a hospital's obligation to provide reasonable accommodations applies to:
- Patients only, not employees
- Employees only, not patients
- Both employees and patients with disabilities (Correct answer)
- Visitors to the facility but not employees
Correct answer: Both employees and patients with disabilities
The ADA applies to hospitals as both employers (Title I) and places of public accommodation (Title III), requiring reasonable accommodations for both employees and patients with disabilities.
Question 4: Which document outlines CMS's requirements that hospitals must meet to participate in the Medicare and Medicaid programs?
- Conditions of Participation (CoPs) (Correct answer)
- National Coverage Determinations (NCDs)
- Local Coverage Determinations (LCDs)
- Medicare Benefit Policy Manual
Correct answer: Conditions of Participation (CoPs)
The Conditions of Participation (CoPs) establish the health and safety standards that hospitals must meet to receive Medicare and Medicaid reimbursement.
Question 5: A risk manager is reviewing compliance with the Patient Self-Determination Act (PSDA). The PSDA requires hospitals to:
- Appoint a patient advocate for every admitted patient
- Inform patients of their right to make advance directives upon admission (Correct answer)
- Ensure all patients have completed a living will before elective procedures
- Obtain informed consent for all procedures regardless of urgency
Correct answer: Inform patients of their right to make advance directives upon admission
The PSDA requires Medicare and Medicaid participating providers to inform adult patients of their rights under state law to make advance directives and to document whether they have one.
Question 6: The primary purpose of the OIG Work Plan is to:
- Establish mandatory compliance benchmarks for all hospitals
- Signal areas the OIG intends to audit and investigate in the coming year (Correct answer)
- Provide guidance on acceptable billing practices for new procedures
- Set exclusion thresholds for providers with compliance violations
Correct answer: Signal areas the OIG intends to audit and investigate in the coming year
The OIG Work Plan identifies and describes the audits, inspections, and evaluations the OIG plans to conduct in the upcoming fiscal year, signaling risk areas for providers.
Question 7: Under EMTALA, a hospital's obligation to provide an appropriate medical screening examination applies to:
- Only patients with Medicare or Medicaid insurance
- Any individual who comes to the emergency department requesting examination or treatment (Correct answer)
- Only patients who are transported by ambulance
- Patients who present with life-threatening conditions only
Correct answer: Any individual who comes to the emergency department requesting examination or treatment
EMTALA applies to any individual who comes to a hospital emergency department and requests examination or treatment for a medical condition, regardless of ability to pay or insurance status.
CPHRM Regulatory Compliance 3
The OIG's Corporate Integrity Agreement (CIA) is typically entered into when: