CRCR - Certified Revenue Cycle Representative Program Healthcare Compliance and Regulations Questions and Answers — Questions and Answers
Question 1: An individual arrives at a hospital's Emergency Department with symptoms of a stroke but expresses concern about their ability to pay for treatment. According to the Emergency Medical Treatment and Active Labor Act (EMTALA), what is the hospital's primary obligation?
- To obtain a deposit or payment information before any services are rendered.
- To perform a financial screening to determine eligibility for charity care.
- To provide a medical screening examination to determine if an emergency medical condition exists. (Correct answer)
- To immediately transfer the patient to a public hospital that accepts uninsured patients.
Correct answer: To provide a medical screening examination to determine if an emergency medical condition exists.
The Emergency Medical Treatment and Active Labor Act (EMTALA) requires Medicare-participating hospitals with emergency departments to provide a medical screening examination to any individual who comes to the emergency department and requests examination or treatment for a medical condition, regardless of their ability to pay. Treatment cannot be delayed to inquire about payment or insurance. Only after the screening and necessary stabilizing treatment can financial discussions occur.
Question 2: A physician owns a significant financial stake in a local, independent MRI facility. The physician consistently refers their Medicare patients to this specific facility for imaging services. This practice is most likely to be scrutinized under which of the following regulations?
- The Health Insurance Portability and Accountability Act (HIPAA)
- The False Claims Act (FCA)
- The Emergency Medical Treatment and Active Labor Act (EMTALA)
- The Physician Self-Referral Law (Stark Law) (Correct answer)
Correct answer: The Physician Self-Referral Law (Stark Law)
The Stark Law prohibits physicians from referring Medicare or Medicaid patients for 'designated health services' (which includes radiology services) to an entity with which the physician or an immediate family member has a financial relationship, unless a specific exception applies. The scenario describes a potential violation because the physician has a financial interest in the facility to which they are referring patients.
Question 3: Which of the following billing activities represents a potential violation of the False Claims Act?
- Submitting a claim with an accidental typographical error in the patient's address.
- Knowingly using a billing code for a more complex and expensive service than what was actually performed and documented. (Correct answer)
- Appealing a payer's denial for a service that the provider believes was medically necessary.
- Offering a prompt-pay discount to a patient for paying their balance in full at the time of service.
Correct answer: Knowingly using a billing code for a more complex and expensive service than what was actually performed and documented.
Knowingly billing for a more expensive service than what was provided is known as 'upcoding' and is a classic example of a False Claims Act violation. The False Claims Act imposes liability on any person who knowingly submits a false or fraudulent claim to a federal healthcare program. The other options describe a clerical error, a standard billing practice, and an acceptable collection method, none of which involve intentional deception for improper payment.
Question 4: A revenue cycle representative needs to leave a voicemail for a patient regarding an overdue bill. To comply with HIPAA's Minimum Necessary Standard, which of the following messages is most appropriate?
- "Hello, this is a message for Jane Doe. This is Pat from Central Clinic calling about your overdue balance of $150 for your visit on January 5th. Please call us back at 555-1234."
- "Hello, this is Pat from Central Clinic calling for Jane Doe. We need to discuss an important matter regarding your account. Please call us back at 555-1234." (Correct answer)
- "Hello, this is Pat calling from Dr. Smith's office for Jane Doe. Your insurance has denied the claim for your recent lab work, and we need you to call us at 555-1234."
- "Hello, this message is for Jane Doe. This is Pat from the billing office calling about your recent cardiology appointment. Please return our call at 555-1234."
Correct answer: "Hello, this is Pat from Central Clinic calling for Jane Doe. We need to discuss an important matter regarding your account. Please call us back at 555-1234."
HIPAA's Minimum Necessary Standard requires that disclosures of Protected Health Information (PHI) be limited to the minimum amount necessary to accomplish the intended purpose. Leaving specific financial details (the balance), clinical services (lab work, cardiology appointment), or insurance status on a voicemail that could be overheard by others is a violation. A simple callback request with the caller's name and organization is the most compliant option as it discloses the least amount of PHI.
Question 5: A hospital's marketing department launches a new campaign with the slogan, "All patient copays and deductibles waived for the month of June!" This practice of routinely waiving patient cost-sharing amounts to attract patients could be a violation of which federal law?
- The Health Information Technology for Economic and Clinical Health (HITECH) Act
- The Affordable Care Act (ACA)
- The Anti-Kickback Statute (AKS) (Correct answer)
- The Emergency Medical Treatment and Active Labor Act (EMTALA)
Correct answer: The Anti-Kickback Statute (AKS)
The Anti-Kickback Statute (AKS) makes it illegal to knowingly and willfully offer or pay any remuneration (including waiving copayments and deductibles) to induce referrals for items or services payable by federal healthcare programs. Routinely waiving cost-sharing can be seen as an improper inducement to attract patients, as it constitutes offering something of value.
Question 6: A Medicare beneficiary is scheduled for a cosmetic procedure that is never covered by Medicare. To ensure the patient understands they will be financially responsible for the entire cost, what is the MOST appropriate action for the provider to take before the service?
- Have the patient review and sign a mandatory Advance Beneficiary Notice of Noncoverage (ABN).
- Inform the patient verbally that the service is not covered and they will be billed.
- Issue a voluntary Advance Beneficiary Notice of Noncoverage (ABN) as a courtesy. (Correct answer)
- Submit the claim to Medicare first and bill the patient only after receiving the denial.
Correct answer: Issue a voluntary Advance Beneficiary Notice of Noncoverage (ABN) as a courtesy.
For services that are statutorily excluded from Medicare coverage (i.e., 'never covered'), a mandatory ABN is not required. However, it is a best practice and recommended by CMS to issue a voluntary ABN as a courtesy to the patient. This ensures the patient is fully informed of their financial responsibility in writing before the service is provided. A mandatory ABN is required when a service is typically covered but may not be considered medically necessary for a specific patient's situation.
CRCR - Certified Revenue Cycle Representative Program Healthcare Compliance and Regulations Questions and Answers
An individual arrives at a hospital's Emergency Department with symptoms of a stroke but expresses concern about their ability to pay for treatment.
According to the Emergency Medical Treatment and Active Labor Act (EMTALA), what is the hospital's primary obligation?