Compliance Program Administration Flashcards

Which federal agency maintains the List of Excluded Individuals and Entities (LEIE) that healthcare organizations must screen against?

Answer: Office of Inspector General (OIG)

The OIG maintains the LEIE, and healthcare organizations must screen employees, contractors, and vendors against it to avoid employing or contracting with excluded parties.

What is the recommended approach when a compliance investigation reveals that a violation was systemic rather than an isolated incident?

Answer: Implement systemic corrective actions, update policies, and provide targeted retraining

Systemic violations require systemic corrective actions including policy updates, process changes, and targeted training to prevent recurrence across the organization.

A compliance officer is asked to report to the board of directors on the compliance program. Which type of information is MOST important to include?

Answer: Key metrics, significant risks identified, investigations completed, and program effectiveness measures

Board reports should focus on program performance metrics, significant risks, investigation outcomes, and overall effectiveness to enable informed governance oversight.

What distinguishes a 'compliance program' from a 'paper program'?

Answer: A compliance program is actively implemented and enforced, while a paper program exists only on paper with no real implementation

A 'paper program' refers to a compliance program that has the required documents but lacks genuine implementation, enforcement, and cultural integration.

Under the Affordable Care Act, which type of provider is mandated to have a compliance program as a condition of enrollment in Medicare and Medicaid?

Answer: Nursing facilities (skilled nursing facilities and nursing facilities)

The ACA mandated that nursing facilities have a compliance and ethics program as a condition of participation in Medicare and Medicaid.

Which of the following BEST describes the concept of 'proportionality' in applying disciplinary actions under a compliance program?

Answer: Discipline should be commensurate with the severity of the violation and applied consistently

Proportionality ensures that disciplinary sanctions fit the severity of the violation and are applied consistently to maintain fairness and deter future misconduct.

When a compliance officer conducts a root cause analysis following a compliance incident, what is the PRIMARY goal?

Answer: To identify the underlying systemic factors that allowed the violation to occur

Root cause analysis focuses on identifying systemic breakdowns in processes, training, or controls—not individual blame—so that effective corrective actions can be designed.