CTC Regulatory Compliance & Standards 3 — Questions and Answers
Question 1: A patient receives telepsychiatry in State A from a psychiatrist licensed only in State B. Which interstate compact allows this to be legally compliant?
- IMLC (Interstate Medical Licensure Compact)
- NPDB Multi-State Privilege
- PSYCH Compact (Correct answer)
- NLC Nursing Licensure Compact
Correct answer: PSYCH Compact
The Psychology Interjurisdictional Compact (PSYCH Compact) allows licensed psychologists to practice telepsychology across member states without obtaining full licensure in each state.
Question 2: Under Section 1834(m) of the Social Security Act, which setting is classified as a permissible Medicare telehealth originating site?
- Patient's private residence (pre-COVID)
- Skilled nursing facility (Correct answer)
- Retail pharmacy
- Urgent care center
Correct answer: Skilled nursing facility
Skilled nursing facilities (SNFs) are explicitly listed in Section 1834(m) as permissible Medicare telehealth originating sites before any COVID-era expansions.
Question 3: Which federal agency enforces anti-kickback statute violations related to telehealth arrangements between vendors and providers?
- FTC (Federal Trade Commission)
- OIG (Office of Inspector General) (Correct answer)
- CMS (Centers for Medicare & Medicaid Services)
- FDA (Food and Drug Administration)
Correct answer: OIG (Office of Inspector General)
The HHS Office of Inspector General (OIG) enforces the Anti-Kickback Statute (AKS) and investigates improper financial arrangements between telehealth vendors and healthcare providers.
Question 4: A telehealth organization wants to use de-identified patient data for research. Which HIPAA method requires removing 18 specific identifiers to achieve safe harbor de-identification?
- Limited Data Set method
- Expert Determination method
- Safe Harbor method (Correct answer)
- Minimum Necessary method
Correct answer: Safe Harbor method
HIPAA's Safe Harbor method requires removal of all 18 specific identifiers (name, dates, geographic data, etc.) and no actual knowledge of re-identification risk.
Question 5: Which CMS billing modifier must be appended to telehealth claims to indicate the service was delivered via synchronous audio-visual technology?
- Modifier 95 (Correct answer)
- Modifier GT
- Modifier GQ
- Modifier 93
Correct answer: Modifier 95
Modifier 95 is used for real-time interactive audio and video telehealth services rendered to a patient at a distant site, replacing the older GT modifier for most Medicare claims.
Question 6: Which regulation mandates that telehealth platforms serving federal employees or federally funded programs must meet Section 508 accessibility standards?
- ADA Title III
- Rehabilitation Act Section 504
- Rehabilitation Act Section 508 (Correct answer)
- 21st Century Cures Act
Correct answer: Rehabilitation Act Section 508
Section 508 of the Rehabilitation Act requires that electronic and information technology used by federal agencies and federally funded programs be accessible to people with disabilities.
Question 7: A CTC discovers that a telehealth vendor experienced a breach affecting 600 patients. Within how many days must HHS be notified under HIPAA Breach Notification Rule?
- 30 days
- 45 days
- 60 days (Correct answer)
- 60 days for media, 60 days for HHS
Correct answer: 60 days
Under the HIPAA Breach Notification Rule, covered entities must notify HHS within 60 days of discovery of a breach affecting 500 or more individuals in a state or jurisdiction.
CTC Regulatory Compliance & Standards 3
A patient receives telepsychiatry in State A from a psychiatrist licensed only in State B.
Which interstate compact allows this to be legally compliant?