Internal Investigations Flashcards
7 cards from real CHC practice questions. Tap to flip, then mark Knew It or Still Learning — missed cards come back until you master them.
Read the first 7 Internal Investigations flashcards as text
What ethical obligation does a compliance officer have when an internal investigation implicates senior leadership?
Answer: Proceed with the investigation objectively and report findings to the board or audit committee
When leadership is implicated, the compliance officer must maintain independence and escalate findings to the board or audit committee to ensure objectivity.
During an internal investigation, an employee asks if they can have a personal attorney present during their interview. What is the appropriate response?
Answer: Permit it, as employees retain the right to counsel, though counsel represents the employee, not the company
Employees have the right to retain personal counsel during internal interviews; this counsel represents the employee, not the organization.
A compliance officer discovers that a vendor has been paying for physician meals that exceed allowable thresholds under the Anti-Kickback Statute safe harbor. What is the NEXT step?
Answer: Quantify the total value, consult legal counsel, and assess whether voluntary disclosure is warranted
Potential AKS violations require legal analysis of exposure, the nature of any remuneration, and a deliberate decision about voluntary disclosure.
Which document BEST establishes the authority and methodology for a healthcare compliance investigation?
Answer: A formal investigation charter or mandate signed by appropriate leadership
A formal investigation charter defines scope, authority, methodology, and reporting structure, providing the legal and operational foundation for the inquiry.
What is 'parallel proceedings' in the context of a healthcare compliance investigation?
Answer: When civil and criminal government investigations proceed at the same time regarding the same conduct
Parallel proceedings occur when the DOJ or HHS pursues both civil (FCA) and criminal charges simultaneously, creating heightened legal exposure.
When preserving electronically stored information (ESI) for a compliance investigation, what is a 'litigation hold'?
Answer: A formal directive suspending routine document destruction to preserve potentially relevant records
A litigation hold is an internal directive that suspends normal document retention policies to preserve evidence that may be relevant to anticipated or pending litigation.
A compliance audit identifies that a coder has been consistently adding diagnosis codes not documented by the physician. This practice is BEST classified as:
Answer: Upcoding fraud with potential False Claims Act liability
Adding unsupported diagnosis codes inflates reimbursement claims, constituting upcoding that may create FCA liability for both the coder and the organization.