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 is the purpose of a 'non-retaliation attestation' collected from managers during a healthcare compliance investigation?
Answer: To document that managers understand and commit to protecting reporting employees from adverse action
Non-retaliation attestations from managers reinforce the organization's commitment to anti-retaliation policies and create accountability.
Under an OIG Corporate Integrity Agreement (CIA), what obligation does a healthcare organization typically have regarding internal investigations?
Answer: Report certain investigations, findings, and corrective actions to an Independent Review Organization (IRO)
CIAs typically require reporting of significant compliance matters and corrective actions to an IRO that reports to the OIG.
Which best describes the 'reasonable inquiry' standard a compliance officer should apply before closing an investigation?
Answer: Ensuring the inquiry was sufficiently thorough that a competent professional would be satisfied the matter is resolved
The reasonable inquiry standard requires that the investigation was conducted with appropriate diligence and that conclusions are well-supported by evidence.
A compliance officer suspects that destroying certain emails before a government subpoena would help the organization. What is the CORRECT response?
Answer: Issue an immediate litigation hold and preserve all potentially relevant communications
Destroying documents in anticipation of a subpoena constitutes obstruction of justice; an immediate litigation hold is the only lawful response.
What does 'materiality' mean in the context of evaluating potential False Claims Act liability during an investigation?
Answer: Whether the false statement or omission had a natural tendency to influence the government's payment decision
The Supreme Court's Escobar decision established that FCA liability requires the false statement to be material to the government's decision to pay.
An internal investigation concludes with findings that are inconclusive due to insufficient evidence. What is the MOST appropriate action?
Answer: Document the inconclusive findings, preserve all evidence, and monitor for future indicators
Inconclusive investigations should be formally closed with documented findings and evidence preserved, with enhanced monitoring to detect future indicators.
Which element is MOST critical to include in a final compliance investigation report?
Answer: A factual summary, evidence reviewed, findings, conclusions, and recommended corrective actions
A thorough investigation report documents the process, evidence, factual findings, and actionable recommendations to support remediation and defensibility.