HAC Healthcare Accounting Regulatory Compliance & Auditing 2 — Questions and Answers
Question 1: Under the False Claims Act, what is the minimum per-claim civil monetary penalty for knowingly submitting a false claim to Medicare or Medicaid?
- $2,181
- $5,000
- $11,803 (Correct answer)
- $25,000
Correct answer: $11,803
As of recent adjustments, the False Claims Act civil penalty range is approximately $13,946 to $27,894 per claim (inflation-adjusted), with the lower bound near $11,803 in earlier adjustment periods.
Question 2: Which OIG exclusion authority permanently excludes individuals convicted of patient abuse or neglect from participating in federal healthcare programs?
- Permissive exclusion under 42 U.S.C. § 1320a-7(b)
- Mandatory exclusion under 42 U.S.C. § 1320a-7(a) (Correct answer)
- Civil monetary penalty authority under 42 U.S.C. § 1320a-7a
- Stark Law exclusion under 42 U.S.C. § 1395nn
Correct answer: Mandatory exclusion under 42 U.S.C. § 1320a-7(a)
Mandatory exclusion under 42 U.S.C. § 1320a-7(a) requires OIG to exclude individuals convicted of patient abuse, neglect, or mistreatment with a minimum 5-year exclusion.
Question 3: A hospital's internal audit reveals that a physician is ordering diagnostic tests from a lab in which the physician holds a 20% ownership stake. Which law is most directly implicated?
- Anti-Kickback Statute
- Stark Law (Physician Self-Referral Law) (Correct answer)
- False Claims Act
- HIPAA Privacy Rule
Correct answer: Stark Law (Physician Self-Referral Law)
The Stark Law prohibits physicians from referring Medicare/Medicaid patients for designated health services to entities in which the physician or immediate family member has a financial relationship.
Question 4: In a Medicare RAC (Recovery Audit Contractor) audit, what is the standard look-back period for complex reviews?
- 1 year
- 2 years
- 3 years (Correct answer)
- 5 years
Correct answer: 3 years
RAC auditors may review claims up to 3 years from the date the claim was paid, aligning with CMS's standard look-back period for complex medical record reviews.
Question 5: Which financial statement audit standard do not-for-profit hospitals most commonly follow when preparing GAAP-compliant audited financial statements?
- PCAOB Auditing Standards
- AICPA Statements on Auditing Standards (SAS) (Correct answer)
- Government Auditing Standards (Yellow Book)
- International Standards on Auditing (ISA)
Correct answer: AICPA Statements on Auditing Standards (SAS)
Not-for-profit hospitals typically follow AICPA SAS (Generally Accepted Auditing Standards) for their annual audited financial statements prepared under US GAAP.
Question 6: Under the Uniform Guidance (2 CFR Part 200), what expenditure threshold triggers a Single Audit requirement for a healthcare entity receiving federal awards?
- $500,000
- $750,000 (Correct answer)
- $1,000,000
- $2,000,000
Correct answer: $750,000
Entities that expend $750,000 or more in federal awards in a fiscal year must undergo a Single Audit (or program-specific audit) under 2 CFR Part 200.
Question 7: Which component of an effective healthcare compliance program, as outlined by the OIG, involves performing periodic risk assessments and internal monitoring?
- Written standards and procedures
- Auditing and monitoring (Correct answer)
- Enforcement and discipline
- Open lines of communication
Correct answer: Auditing and monitoring
The OIG's seven elements of an effective compliance program include auditing and monitoring, which encompasses periodic risk assessments, internal audits, and ongoing monitoring activities.
HAC Healthcare Accounting Regulatory Compliance & Auditing 2
Under the False Claims Act, what is the minimum per-claim civil monetary penalty for knowingly submitting a false claim to Medicare or Medicaid?