CPHRM Regulatory Compliance 4 — Questions and Answers
Question 1: A hospital implements a new compliance hotline. Under the OIG's compliance program guidance, a key feature of an effective hotline is:
- Requiring employees to identify themselves when reporting concerns
- Allowing anonymous reporting without fear of retaliation (Correct answer)
- Routing all calls directly to the Chief Executive Officer
- Limiting reports to billing and coding issues only
Correct answer: Allowing anonymous reporting without fear of retaliation
Effective compliance hotlines should allow anonymous reporting and include non-retaliation policies to encourage employees to report concerns without fear of adverse consequences.
Question 2: Which federal law prohibits healthcare providers from offering, paying, soliciting, or receiving anything of value to induce or reward referrals of federal healthcare program business?
- Stark Law
- False Claims Act
- Anti-Kickback Statute (Correct answer)
- Civil Monetary Penalties Law
Correct answer: Anti-Kickback Statute
The Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)) prohibits knowingly and willfully offering, paying, soliciting, or receiving remuneration to induce or reward referrals of items or services covered by federal healthcare programs.
Question 3: A hospital is conducting a compliance risk assessment. Which tool is MOST useful for prioritizing compliance risks?
- A gap analysis comparing current practices to regulatory requirements
- A heat map that plots likelihood of occurrence against potential impact (Correct answer)
- A review of prior year audit findings only
- A survey of department managers about their biggest operational challenges
Correct answer: A heat map that plots likelihood of occurrence against potential impact
A risk heat map allows compliance teams to visually prioritize risks by plotting both the likelihood of occurrence and the potential impact, enabling focused resource allocation.
Question 4: Under CMS CoPs, the medical staff bylaws must address which of the following related to credentialing?
- The specific clinical privileges granted to each physician
- The process for granting, renewing, and revoking privileges (Correct answer)
- The minimum malpractice insurance limits required
- The maximum number of physicians that can be credentialed
Correct answer: The process for granting, renewing, and revoking privileges
CMS CoPs require medical staff bylaws to include processes for appointment, reappointment, and clinical privileges, including the criteria and procedures for granting, renewing, revising, and revoking privileges.
Question 5: The National Practitioner Data Bank (NPDB) must be queried by hospitals:
- Only at initial medical staff appointment
- At initial appointment and at least every 2 years thereafter (Correct answer)
- Annually for all credentialed practitioners
- Only when a malpractice suit is filed against a practitioner
Correct answer: At initial appointment and at least every 2 years thereafter
Hospitals must query the NPDB when a practitioner applies for medical staff membership or clinical privileges and at least every 2 years for practitioners currently on staff.
Question 6: A hospital compliance officer discovers that a vendor is offering free meals to physicians who refer patients to their durable medical equipment company. This arrangement most likely violates:
- The Stark Law only
- The Anti-Kickback Statute only (Correct answer)
- Both the Stark Law and the Anti-Kickback Statute
- HIPAA's privacy regulations
Correct answer: The Anti-Kickback Statute only
While the Stark Law applies to physician referrals for designated health services to entities with a financial relationship, the Anti-Kickback Statute more broadly applies to any remuneration intended to induce referrals for federal healthcare program items, including DME.
Question 7: Which federal regulation requires hospitals to have an infection control committee and a designated infection control officer?
- OSHA Bloodborne Pathogens Standard
- CMS Conditions of Participation §482.42 (Correct answer)
- CDC Healthcare Infection Control Practices Advisory Committee guidelines
- The Joint Commission Infection Prevention Standards
Correct answer: CMS Conditions of Participation §482.42
CMS CoPs at §482.42 require hospitals to have an active program for the prevention, control, and investigation of infections and communicable diseases, including qualified personnel and oversight.
CPHRM Regulatory Compliance 4
A hospital implements a new compliance hotline.
Under the OIG's compliance program guidance, a key feature of an effective hotline is: