Compliance Programs
The number of elements of an effective compliance program.
7
(8 is acceptable, if you know what the 8th is)
The document that represents the culture of the organization, outlines core values and policies that shape both daily and long-term operations of the health care entity.
What is the Code of Conduct?
The law that prohibits the knowing and willful payment of remuneration to induce or reward patient referrals or the generation of business involving any item or service payable by the Federal health care programs.
What is the federal Anti-Kickback Statute?
The google-like system that houses UHealth policies.
What is PolicyStat?
The e-mail address all inquiries must be immediately forwarded/sent to for logging.
What is compliancehelp@med.miami.edu?
The guiding documents from the government that provides that if an entity has an effective compliance and ethics program and the offense occurred despite the program, that entity is eligible for a reduced penalty.
What are the Federal Sentencing Guidelines?
The designated compliance professional that serves as the focal point for compliance activities.
Who is the Chief Compliance Officer?
The type of statute or law that does not require proof of intent in order to be liable.
What is a strict liability law?
Currently, the two policies that govern clinical faculty in regards to conflicts of interest.
The non-Board level committee that is tasked with oversight to our program.
What is the Executive Compliance Committee?
The law/regulation that allows the Secretary of HHS to mandate a compliance program as condition of their enrollment in Medicare, Medicaid, or the Children's Health Insurance Program (CHIP).
What is the Affordable Care Act (ACA/Obamacare)?
The guiding document that represents the culture of the organization; requirement by Managed Care organizations because of CMS conditions for participation requirements.
What is the Code of Conduct?
Physicians cannot make a referral of a Medicare patient to this type of entity if the physician has a financial relationship with that entity, unless an exception applies.
What is "designated health services" entity?
The decision-maker on whether a clinical faculty member is permitted to enter into a consulting agreement.
Who is the clinical Chair?
The document that must be provided at the beginning of any interview for an investigation.
What is the confidentiality memorandum?
A legally binding agreement between OIG of HHS and a healthcare provider who is settling a federal case for defrauding a federal health-care program such as Medicare or Medicaid.
What is a Corporate Integrity Agreement (CIA)?
An objective, independent review with a formalized methodology.
What is an audit?
If the government intervenes in this type of suit, the relator can receive between 15-25% of the proceeds.
What is a qui tam action?
The department(s) that must approve a gift to a patient that doesn't fit in the nominal value exception to the Civil Monetary Penalties per the Cash and Non-Cash Patient Gift Policy.
Who are General Counsel and UHealth Compliance?
The number of claims reviewed for each UHealth billing provider per year by OBC.
The set of shared attitudes, values, goals, and practices that characterizes an institution or organization.
What is a "culture"?
The amount of time to report (to the appropriate governmental authority) an overpayment from Medicare after determining there is credible evidence of a violation.
What is 60 days?
The amount of time the government can "look back" to determine and recover overpayments.
What is 6 years?
The type of assessment required prior to UHealth Compliance and General Counsel approving a complete waiver of Medicare co-pays, co-insurances, or deductible amounts.
What is a financial needs assessment?
The quality/type of a report or allegation that generally requires notification and direction from General Counsel prior to investigation.
What is a report that alleges illegal activity?