CCT - Certified Compliance Technician Enforcement and Penalties Questions and Answers

Question 1

As part of a civil settlement to resolve allegations of healthcare fraud, a hospital system agrees to a set of stringent compliance obligations monitored by the OIG for five years. This arrangement, which allows the hospital to continue participating in federal healthcare programs, is known as a:

Accepted Answer

Corporate Integrity Agreement (CIA)

Answer

A Corporate Integrity Agreement (CIA) is an agreement between a healthcare entity and the Office of Inspector General (OIG) as part of a civil settlement. In exchange for the OIG's agreement not to seek exclusion from federal healthcare programs, the entity agrees to specific obligations to promote compliance and undergo monitoring, typically for five years.

Question 2

An internal audit at a physician practice uncovers that a non-physician practitioner has been submitting claims under the supervising physician's provider number for services performed without the physician present, a practice known as 'incident-to' billing abuse. Besides repaying the funds and potential exclusion, which of the following is the OIG most likely to impose?

Accepted Answer

Civil Monetary Penalties (CMPs)

Answer

The OIG is authorized to impose Civil Monetary Penalties (CMPs) for a wide variety of conduct, including presenting claims that one knows or should know are for services not provided as claimed or are otherwise false or fraudulent. Submitting false 'incident-to' claims fits this description. While other actions could occur depending on the severity, CMPs are a direct and common financial penalty for this type of violation.

Question 3

Which of the following would be grounds for a *permissive* exclusion from federal healthcare programs by the OIG, rather than a mandatory one?

Accepted Answer

A misdemeanor conviction for obstructing a healthcare investigation.

Answer

Permissive exclusions are discretionary. Grounds include misdemeanor convictions related to healthcare fraud or obstruction of an investigation. In contrast, mandatory exclusions are required by law for specific offenses, including felony convictions for Medicare fraud, patient abuse, and felony convictions related to controlled substances.

Question 4

A large-scale, multi-state investigation into a complex criminal healthcare fraud enterprise is underway. While the HHS OIG provides investigative expertise, which government agency is primarily responsible for leading the criminal prosecution and bringing charges against the defendants?

Accepted Answer

Department of Justice (DOJ)

Answer

The Department of Justice (DOJ), through its Criminal Division's Health Care Fraud Unit and various U.S. Attorneys' Offices, is the primary federal agency responsible for prosecuting criminal violations of healthcare laws. While the OIG investigates and can impose civil penalties and exclusions, and the FBI investigates federal crimes, the DOJ leads the ultimate criminal prosecution in court.

Question 5

An internal investigation confirms a manager intentionally falsified documentation to support medically unnecessary services, leading to significant improper payments. The organization's disciplinary guidelines call for termination for willful misconduct. To align with effective compliance enforcement, what is the organization's most critical action regarding the manager?

Accepted Answer

Consistently apply the disciplinary guidelines and terminate the employment.

Answer

A key element of an effective compliance program is enforcing standards through well-publicized disciplinary guidelines. This requires consistent and predictable application of discipline. If the guidelines call for termination for intentional, fraudulent acts, the organization must follow through to maintain the integrity of its compliance program and deter future misconduct.

(CCT) Certified Compliance Technician Practice Test

(CCT) Certified Compliance Technician Practice Test

CCT - Certified Compliance Technician Enforcement and Penalties Questions and Answers