Podcast
Questions and Answers
Which of the following is a core compliance requirement?
Which of the following is a core compliance requirement?
- Limit reporting of suspected violations
- Ignore non-compliance issues
- Prioritize personal interests over organizational policies
- Conduct yourself in an ethical and legal manner (correct)
Reporting suspected compliance violations is the responsibility of specific individuals only.
Reporting suspected compliance violations is the responsibility of specific individuals only.
False (B)
What should you do if you suspect a violation of compliance standards?
What should you do if you suspect a violation of compliance standards?
Report the suspected violation.
Which of the following is NOT a reporting method for employees of a Sponsor to report potential non-compliance?
Which of the following is NOT a reporting method for employees of a Sponsor to report potential non-compliance?
The organization's Standards of Conduct should reflect its individual organization’s ________ and business operations.
The organization's Standards of Conduct should reflect its individual organization’s ________ and business operations.
Internal audits are informal reviews of compliance with set standards.
Internal audits are informal reviews of compliance with set standards.
Match the following compliance terms with their descriptions:
Match the following compliance terms with their descriptions:
What is a primary action taken immediately after non-compliance is detected?
What is a primary action taken immediately after non-compliance is detected?
Employees of First-Tier, Downstream, or Related Entities should report potential non-compliance to their ______ or Compliance Help Line.
Employees of First-Tier, Downstream, or Related Entities should report potential non-compliance to their ______ or Compliance Help Line.
What is a consequence of non-compliance?
What is a consequence of non-compliance?
Ethical standards should be followed only if convenient.
Ethical standards should be followed only if convenient.
Match the following compliance actions with their descriptions:
Match the following compliance actions with their descriptions:
Who should tailor the Standards of Conduct to their organization?
Who should tailor the Standards of Conduct to their organization?
What is a core requirement for an effective compliance program?
What is a core requirement for an effective compliance program?
Beneficiaries must report non-compliance only through the Medicare Compliance Officer.
Beneficiaries must report non-compliance only through the Medicare Compliance Officer.
What must organizations do to correct instances of identified non-compliance?
What must organizations do to correct instances of identified non-compliance?
Which of the following is NOT a core requirement of an effective compliance program?
Which of the following is NOT a core requirement of an effective compliance program?
All sponsors must allow for anonymous reporting of potential fraud, waste, and abuse (FWA).
All sponsors must allow for anonymous reporting of potential fraud, waste, and abuse (FWA).
What are the seven core compliance program requirements?
What are the seven core compliance program requirements?
An effective compliance program should articulate the organization’s commitment to __________ conduct.
An effective compliance program should articulate the organization’s commitment to __________ conduct.
What should be done promptly after identifying FWA?
What should be done promptly after identifying FWA?
An organization can retaliate against an employee who reports compliance violations.
An organization can retaliate against an employee who reports compliance violations.
Name one key indicator of potential fraud, waste, and abuse (FWA).
Name one key indicator of potential fraud, waste, and abuse (FWA).
Match the following compliance program aspects with their descriptions:
Match the following compliance program aspects with their descriptions:
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Study Notes
Reporting Potential Non-Compliance
- Employees of a Sponsor can report by calling the Medicare Compliance Officer, through their organization's website, or via the Compliance Hotline.
- First-Tier, Downstream, or Related Entity (FDR) employees should speak to a manager, call the Ethics/Compliance Help Line, or report directly to the sponsor.
- Beneficiaries may report non-compliance by calling the sponsor’s Compliance Hotline, making reports on the sponsor’s website, or contacting 1-800-Medicare.
Response to Detected Non-Compliance
- Immediate investigation and prompt correction are required once non-compliance is detected.
- Internal monitoring should ensure prevention of recurrence, ongoing compliance with CMS requirements, and the effectiveness of internal controls to protect enrollees.
Internal Monitoring and Audits
- Internal monitoring involves regular reviews to confirm compliance and implement corrective actions as needed.
- Internal audits are formal evaluations of compliance against established standards like laws, regulations, and organizational policies.
Compliance Program Training Summary
- Compliance programs must meet seven core requirements and promote a culture of compliance.
- Adhering to ethical behavior and organizational Standards of Conduct is essential.
- Awareness of common non-compliance issues and reporting methods is crucial.
- Understanding the consequences of non-compliance and participating in corrective actions are required.
Procedures for Prompt Response to Compliance Issues
- Sponsors must implement effective measures for swift response and corrective action upon identifying non-compliance.
Ethical Conduct in the Medicare Program
- Ethical behavior in the Medicare Program includes acting fairly and honestly, adhering to high standards, complying with laws and CMS requirements, and reporting suspected violations.
Understanding Expectations
- Standards of Conduct outline compliance expectations and principles specific to each organization and should be readily available to all employees.
- Reporting non-compliance is a shared responsibility, and organizations should clarify how to report such incidents.
Definition of Non-Compliance
- Non-compliance refers to actions that violate laws, federal healthcare program requirements, or organizational policies.
Impact of Non-Compliance
- Non-compliance poses risks to the organization, emphasizing the need for prevention, detection, and correction programs.
- A mechanism for reporting potential fraud, waste, and abuse (FWA) must exist, ensuring anonymity and protection against retaliation for reporters.
Effective Compliance Programs
- CMS mandates sponsors to maintain effective compliance programs that demonstrate commitment to ethical conduct, provide guidance for compliance queries, and facilitate identification and reporting of violations.
- An effective compliance program is critical in preventing, detecting, and correcting issues related to non-compliance and FWA.
- It should be fully implemented, tailored to the organization’s needs, adequately resourced, and promote clear communication channels for reporting non-compliance.
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