Part 3 - Fraud, Waste, and Abuse 2025 PDF

Summary

This document is a training module on Medicare fraud, waste, and abuse (FWA) for 2025. It covers the definitions of fraud, waste, and abuse, the laws that prohibit them, and examples of these issues in the Medicare program. It also explains the training requirements and objectives for participants.

Full Transcript

Part 3 | Fraud, Waste and Abuse 2025 1. Part 3: Medicare Fraud, Waste and Abuse 2025 1.1 Medicare Fraud, Waste and Abuse 2025 Notes: Part 3: Medicare Fraud, Waste and Abuse 2025 Published by Articulate® Storyline www.articulate.com 1.2 Course Overview Notes: About this course The goal of thi...

Part 3 | Fraud, Waste and Abuse 2025 1. Part 3: Medicare Fraud, Waste and Abuse 2025 1.1 Medicare Fraud, Waste and Abuse 2025 Notes: Part 3: Medicare Fraud, Waste and Abuse 2025 Published by Articulate® Storyline www.articulate.com 1.2 Course Overview Notes: About this course The goal of this training is to meet CMS’ annual training and testing guidelines. A passing score of 85% on the course’s final exam is required to receive course credit. Published by Articulate® Storyline www.articulate.com 1.3 Introduction Notes: Introduction This training satisfies the Medicare Parts C and D plan sponsor general compliance and fraud, waste and abuse (FWA) annual training requirements in the regulations and sub-regulatory guidance listed on the screen. Published by Articulate® Storyline www.articulate.com 1.4 Why Do I Need Training? Notes: Why Do I Need Training? Every year, billions of dollars are improperly spent because of FWA. It affects everyone — including you. This training will help you detect, correct, and prevent FWA. You are part of the solution. Combating FWA is everyone’s responsibility! As an individual who provides health or administrative services for Medicare enrollees, every action you take potentially affects Medicare enrollees, the Medicare Program, or the Medicare Trust Fund. Published by Articulate® Storyline www.articulate.com 1.5 Training Requirements Notes: Training Requirements Certain training requirements apply to people involved in Medicare Parts C and D. All employees of Medicare Advantage Organizations (MAOs) and Prescription Drug Plans (PDPs) (collectively referred to in this training course as “sponsors”) must receive training for preventing, detecting, and correcting FWA. FWA training must occur within 90 days of initial hire and at least annually thereafter. More information on other Medicare Parts C and D compliance training and answers to common questions is Published by Articulate® Storyline www.articulate.com available on the CMS website. Click the buttons to learn more. 1 Part C (Slide Layer) Published by Articulate® Storyline www.articulate.com 2 Part D (Slide Layer) 1.6 Course Objectives Notes: Published by Articulate® Storyline www.articulate.com Course objectives Please take a few minutes to review the learning objectives for this course. 1.7 Lesson 1: What is FWA? Notes: What is FWA? This lesson describes fraud, waste, and abuse (FWA) and the laws that prohibit it. It should take about 10 minutes to complete. Upon completing the lesson, you should be able to correctly: Recognize FWA in the Medicare program Published by Articulate® Storyline www.articulate.com Identify the major laws and regulations pertaining to FWA Recognize potential consequences and penalties associated with violations 1.8 Fraud Notes: Fraud Fraud is knowingly and willfully executing, or attempting to execute, a scheme or artifice to defraud any health care benefit program, or to obtain, by means of false or fraudulent pretenses, representations, or promises, any of the money or property owned by, or under the custody or control of, any health care benefit program. Published by Articulate® Storyline www.articulate.com The Health Care Fraud Statute makes it a criminal offense to knowingly and willfully execute a scheme to defraud a health care benefit program. Health care fraud is punishable by imprisonment for up to 10 years. It is also subject to criminal fines of up to $250,000. In other words, fraud is intentionally submitting false information to the Government or a Government contractor to get money or a benefit. 1.9 Waste and Abuse Notes: Waste and Abuse Published by Articulate® Storyline www.articulate.com Waste includes overusing services, or other practices that, directly or indirectly, result in unnecessary costs to the Medicare program. Waste is generally not considered to be caused by criminally negligent actions but rather by the misuse of resources. Abuse includes actions that may, directly or indirectly, result in unnecessary costs to the Medicare Program, improper payment, payment for services that fail to meet professionally recognized standards of care, or services that are medically unnecessary. Abuse involves payment for items or services when there is not legal entitlement to that payment and the provider has not knowingly and/or intentionally misrepresented facts to obtain payment. Published by Articulate® Storyline www.articulate.com 1.10 Examples of FWA Notes: Examples of FWA Take a few moments to review the examples of FWA listed on the screen. Published by Articulate® Storyline www.articulate.com 1.11 Differences Among Fraud, Waste and Abuse Notes: Differences Among Fraud, Waste and Abuse There are differences among fraud, waste, and abuse. One of the primary differences is intent and knowledge. Fraud requires intent to obtain payment and the knowledge that the actions are wrong. Waste and abuse may involve obtaining an improper payment or creating an unnecessary cost to the Medicare program, but does not require the same intent and knowledge. Published by Articulate® Storyline www.articulate.com 1.12 Understanding FWA Notes: Understanding FWA To detect FWA, you need to know the law. The following statutes and regulations provide high-level information about related FWA laws: Civil False Claims Act, Health Care Fraud Statute, and Criminal Fraud Anti-Kickback Statute Stark Statute (Physician Self-Referral Law) Exclusion from all federal health care programs Health Insurance Portability and Accountability Act (HIPAA) For details about the specific laws, such as safe harbor provisions, consult the applicable statute and regulations. Published by Articulate® Storyline www.articulate.com 1.13 Civil False Claims Act (FCA) Notes: Civil False Claims Act (FCA) The civil provisions of the FCA make a person liable to pay damages to the Government if he or she knowingly: Conspires to violate the FCA Carries out other acts to obtain property from the government by misrepresentation Knowingly conceals or knowingly and improperly avoids or decreases an obligation to pay the Government Makes or uses a false record or statement supporting a false claim Presents a false claim for payment or approval Published by Articulate® Storyline www.articulate.com For more information, refer to 31 United States Code (U.S.C.) Sections 3729-3733. Damages and Penalties Any person who knowingly submits false claims to the Government is liable for three times the Government’s damages caused by the violator plus a penalty. Click the button on your screen to view examples of FCA. Examples (Slide Layer) Published by Articulate® Storyline www.articulate.com 1.14 Civil FCA (continued) Notes: Whistleblowers: A person who exposes information or activity that is deemed illegal, dishonest, or violates professional or clinical standards. Protected: Persons who report false claims or bring legal actions to recover money paid on false claims are protected from retaliation. Rewarded: Persons who bring a successful whistleblower lawsuit receive at least 15 percent, but not more than 30 percent, of the money collected. Published by Articulate® Storyline www.articulate.com 1.15 Health Care Fraud Statute Notes: Health Care Fraud Statute The Health Care Fraud Statute states that “Whoever knowingly and willfully executes, or attempts to execute, a scheme or artifice to defraud any health care benefit program … shall be fined under this title or imprisoned not more than 10 years, or both.” Conviction under the statute does not require proof that the violator had knowledge of the law or specific intent to violate the law. For more information, refer to 18 U.S.C. Section 1346-1347. Published by Articulate® Storyline www.articulate.com Examples (Slide Layer) 1.16 Criminal Health Care Fraud Notes: Published by Articulate® Storyline www.articulate.com Criminal Health Care Fraud Anyone who knowingly and willfully makes or attempts to make a false claim, to defraud any health care benefit program or to obtain, by means of false or fraudulent pretenses is subject to the following penalty: A person would be fined under this title or imprisoned not more than 10 years, or both. If the violation results in serious bodily injury, the person would be fined under this title or imprisoned not more than 20 years, or both. If the violation results in death, the person would be fined under this title, or imprisoned for any term of years or for life, or both. For more information, refer to 18 U.S.C. Section 1347. 1.17 Anti-Kickback Statute Published by Articulate® Storyline www.articulate.com Notes: Anti-Kickback Statute The Anti-Kickback Statute prohibits knowingly and willfully soliciting, receiving, offering, or paying remuneration (including any kickback, bribe, or rebate) for referrals for services that are paid, in whole or in part, under a Federal health care program (including the Medicare program). For more information, refer to 42 U.S.C. Section 1320a- 7b(b). Click the button on your screen to view more examples. Examples (Slide Layer) Published by Articulate® Storyline www.articulate.com 1.18 Stark Statute (Physician Self-Referral Law) Notes: Stark Statute (Physician Self-Referral Law) The Stark Statute prohibits a physician from making referrals for certain designated health services to an entity when the physician (or a member of his or her family) has: An ownership/investment interest; or A compensation arrangement (exceptions apply). For more information, refer to 42 U.S.C. Section 1395nn. Published by Articulate® Storyline www.articulate.com Examples (Slide Layer) 1.19 Civil Monetary Penalties (CMP) Law Notes: Published by Articulate® Storyline www.articulate.com Civil Monetary Penalties (CMP) Law The Office of Inspector General (OIG) may impose civil penalties for a number of reasons, including: Arranging for services or items from an excluded individual or entity Providing services or items while excluded Failing to grant OIG timely access to records Knowing of and failing to report and return an overpayment Making false claims Paying to influence referrals For more information, refer to 42 U.S.C. 1320a-7a and the Act, Section 1128A(a). Click the button to view examples of CMP. Published by Articulate® Storyline www.articulate.com Examples (Slide Layer) 1.20 Exclusion Notes: Published by Articulate® Storyline www.articulate.com Exclusion No Federal health care program payment may be made for any item or service furnished, ordered, or prescribed by an individual or entity excluded by the OIG. The OIG has authority to exclude individuals and entities from federally funded health care programs and maintains the List of Excluded Individuals and Entities (LEIE). The U.S. General Services Administration (GSA) administers the Excluded Parties List System (EPLS), which contains debarment actions taken by various Federal agencies, including the OIG. You may access the EPLS on the System for Award Management website. Click the button to view examples of Exclusion. Examples (Slide Layer) Published by Articulate® Storyline www.articulate.com 1.21 Health Insurance Portability and Accountability Act (HIPAA) Notes: Health Insurance Portability and Accountability Act (HIPAA) HIPAA created greater access to health care insurance, strengthened the protection of the privacy of health care data, and promoted standardization and efficiency in the health care industry. HIPAA safeguards help prevent unauthorized access to protected health care information. As an individual with access to protected health care information, you must comply with HIPAA. Published by Articulate® Storyline www.articulate.com For more information, visit HIPAA webpage. Click the button to view examples of HIPAA. Examples (Slide Layer) Published by Articulate® Storyline www.articulate.com 1.22 Lesson 1: Summary Notes: Lesson 1: Summary There are differences among fraud, waste and abuse (FWA). One of the primary differences is intent and knowledge. Fraud requires that the person have intent to obtain payment and the knowledge his or her actions are wrong. Waste and abuse may involve obtaining an improper payment but do not require the same intent and knowledge. Laws and regulations exist that prohibit FWA. Penalties for violating these laws may include: Civil monetary penalties Civil prosecution Published by Articulate® Storyline www.articulate.com Criminal conviction, fines, or both Exclusion from all federal health care programs participation Imprisonment Loss of professional license 1.23 Lesson 2: Your Role in the Fight Against FWA Notes: Lesson 2: Your Role in the Fight Against FWA This lesson describes fraud, waste, and abuse (FWA) and the laws that prohibit it. It should take about 10 minutes to complete. Upon completing the lesson, you should be Published by Articulate® Storyline www.articulate.com able to correctly: Recognize FWA in the Medicare program Identify the major laws and regulations pertaining to FWA Recognize potential consequences and penalties associated with violations 1.24 Where do I fit in? Notes: Where do I fit in? Click the arrows below to review the details on your screen to learn more. Published by Articulate® Storyline www.articulate.com 2 (Slide Layer) 3 (Slide Layer) Published by Articulate® Storyline www.articulate.com 1.25 What Are Your Responsibilites? Notes: What Are Your Responsibilities? You play a vital part in preventing, detecting, and reporting potential FWA, as well as Medicare noncompliance. Published by Articulate® Storyline www.articulate.com 1.26 How Do You Prevent FWA? Notes: How Do You Prevent FWA? Look for suspicious activity Conduct yourself in an ethical manner Ensure accurate and timely data and billing Ensure you coordinate with other payers Know FWA policies and procedures, standards of conduct, laws, regulations, and CMS’ guidance Verify all received information. Published by Articulate® Storyline www.articulate.com 1.27 Stay Informed About Policies and Procedures Notes: Stay Informed About Policies and Procedures Know your entity’s policies and procedures. Every sponsor and First-Tier, Downstream, and Related Entity (FDR) must have policies and procedures that address FWA. These procedures should help you detect, prevent, report, and correct FWA. Code of Conduct should describe the sponsor’s expectations that: All employees conduct themselves in an ethical manner Appropriate mechanisms are in place for anyone to report noncompliance and potential FWA Published by Articulate® Storyline www.articulate.com Reported issues will be addressed and corrected Code of Conduct policies communicate to employees and FDRs compliance is everyone’s responsibility, from the top of the organization to the bottom. 1.28 Report FWA Notes: Report FWA Everyone must report suspected instances of FWA. Your sponsor’s Code of Conduct should clearly state this obligation. Sponsors may not retaliate against you for making a good faith effort in reporting. Report any potential FWA concerns you have to your Published by Articulate® Storyline www.articulate.com compliance department or your sponsor’s compliance department. Your sponsor’s compliance department will investigate and make the proper determination. Often, sponsors have a Special Investigations Unit (SIU) dedicated to investigating FWA. They may also maintain an FWA Hotline. 1.29 Reporting FWA Outside Your Organization Notes: Reporting FWA Outside Your Organization If warranted, sponsors and FDRs must report potentially fraudulent conduct to government authorities, such as the Office of Inspector General (OIG), the Department of Justice (DOJ), or CMS. Published by Articulate® Storyline www.articulate.com Individuals or entities who wish to voluntarily disclose self- discovered potential fraud to OIG may do so under the Self-Disclosure Protocol (SDP). Self-disclosure gives providers the opportunity to avoid the costs and disruptions associated with a government- directed investigation and civil or administrative litigation. Details to Include When Reporting FWA When reporting suspected FWA, include: Contact information for the information source, suspects, and witnesses Alleged FWA details Alleged medicare rules violated The suspect’s history of compliance, education, training, and communication with your organization or other entities Click on the button to learn where to report FWA. Published by Articulate® Storyline www.articulate.com Where to Report FWA (Slide Layer) 1.30 Correction Notes: Published by Articulate® Storyline www.articulate.com Correction Once fraud, waste, or abuse has been detected, promptly correct it. Correcting the problem saves the Government money and ensures compliance with CMS requirements. Develop a plan to correct the issue. Ask your organization’s compliance officer about the development process for the corrective action plan. The actual plan is going to vary, depending on the specific circumstances. In general: Design the corrective action to correct the underlying problem that results in FWA program violations and to prevent future non-compliance. Tailor the corrective action to address the particular FWA, problem, or deficiency identified. Include timeframes for specific actions. Document corrective actions addressing noncompliance or FWA committed by a sponsor’s employee or FDR’s employee, and include consequences for failure to satisfactorily complete the corrective action. Monitor corrective actions continuously to ensure effectiveness. Click the button to view examples of corrective action. Published by Articulate® Storyline www.articulate.com Corrective Action Examples (Slide Layer) 1.31 Indicators of Potential FWA Notes: Published by Articulate® Storyline www.articulate.com Indicators of Potential FWA Now that you know about your role in preventing, reporting, and correcting FWA, let’s review some key indicators to help you recognize the signs of someone committing FWA. The following pages present potential FWA issues. Each page provides questions to ask yourself about different areas, depending on your role as an employee of a sponsor, pharmacy, or other entity involved in the delivery of Medicare Parts C and D benefits to enrollees. 1.32 Key Indicators Published by Articulate® Storyline www.articulate.com Notes: Key Indicators Click on each button below to learn more. 1 Beneficiary Issues (Slide Layer) Published by Articulate® Storyline www.articulate.com 2 Provider Issues (Slide Layer) 3 Pharmacy Issues (Slide Layer) Published by Articulate® Storyline www.articulate.com 4 Wholesaler Issues (Slide Layer) 5 Manufacturer Issues (Slide Layer) Published by Articulate® Storyline www.articulate.com 6 Sponsor Issues (Slide Layer) 1.33 Lesson 2: Summary Notes: Published by Articulate® Storyline www.articulate.com Lesson 2: Summary As a person who provides health or administrative services to a Medicare Parts C or D enrollee, you play a vital role in preventing fraud, waste, and abuse (FWA). Conduct yourself ethically, stay informed of your organization’s policies and procedures, and keep an eye out for key indicators of potential FWA. Report potential FWA. Every sponsor must have a mechanism for reporting potential FWA. Each sponsor must be able to accept anonymous reports and cannot retaliate against you for reporting. Promptly correct identified FWA with an effective corrective action plan. 1.34 General Compliance Training 2025 Published by Articulate® Storyline www.articulate.com Notes: Medicare Parts C and D General Compliance Training 2025 1.35 Introduction Notes: Introduction and Learning Objectives This lesson outlines effective compliance programs. It should take about 15 minutes to complete. After completing this lesson, you should correctly: Recognize how a compliance program operates Recognize how compliance program violations should be reported Published by Articulate® Storyline www.articulate.com 1.36 Compliance Program Requirements Notes: Compliance Program Requirements The Centers for Medicare & Medicaid Services (CMS) requires sponsors to implement and maintain an effective compliance program for its Medicare Parts C and D plans. An effective compliance program must: Articulate and demonstrate an organization’s commitment to legal and ethical conduct Provide guidance on how to handle compliance questions and concerns Provide guidance on how to identify and report compliance violations Published by Articulate® Storyline www.articulate.com 1.37 What is an Effective Compliance Program? Notes: What is an Effective Compliance Program? An effective compliance program fosters a culture of compliance within an organization and, at a minimum: Prevents, detects, and corrects non-compliance Is fully implemented and is tailored to an organization’s unique operations and circumstances Has adequate resources Promotes the organization’s Standards of Conduct Establishes clear lines of communication for reporting non- compliance An effective compliance program is essential to prevent, Published by Articulate® Storyline www.articulate.com detect, and correct Medicare non-compliance as well as fraud, waste, and abuse (FWA). It must, at a minimum, include the seven core compliance program requirements. 1.38 Seven Core Compliance Program Requirements Notes: Seven Core Compliance Program Requirements CMS requires that an effective compliance program to include seven core requirements: 1.Written Policies, Procedures, and Standards of Conduct: These articulate the sponsor’s commitment to comply with all applicable Federal and State standards and describe compliance expectations according to the Standards of Conduct. Published by Articulate® Storyline www.articulate.com 2.Compliance Officer, Compliance Committee, and High- Level Oversight: The sponsor must designate a compliance officer and a compliance committee that will be accountable and responsible for the activities and status of the compliance program, including issues identified, investigated, and resolved by the compliance program. The sponsor’s senior management and governing body must be engaged and exercise reasonable oversight of the sponsor’s compliance program. 3. Effective Training and Education: This covers the elements of the compliance plan as well as prevention, detection, and reporting of FWA. Tailor this training and education to the different employees and their responsibilities and job functions. Published by Articulate® Storyline www.articulate.com 1.39 Seven Core Compliance Program Requirements (continued) Notes: Seven Core Compliance Program Requirements continued 4.Effective Lines of Communication: Make effective lines of communication accessible to all, ensure confidentiality, and provide methods for anonymous and good-faith compliance issues reporting at sponsor and first-tier, downstream, or related entity (FDR) levels. 5.Well-Publicized Disciplinary Standards: Sponsor must enforce standards through well-publicized disciplinary guidelines. 6.Effective System for Routine Monitoring, Auditing, and Identifying Compliance Risks: Conduct routine monitoring and auditing of sponsor’s and FDR’s Published by Articulate® Storyline www.articulate.com operations to evaluate compliance with CMS requirements as well as the overall effectiveness of the compliance program. NOTE: Sponsors must ensure that FDR’s performing delegated administrative or health care service functions concerning the Sponsor’s Medicare Parts C and D program comply with Medicare Program requirements. 1.40 Seven Core Compliance Program Requirements (continued) Notes: Seven Core Compliance Program Requirements continued 7. Procedures and System for Prompt Response to Compliance Issues: The sponsor must use effective Published by Articulate® Storyline www.articulate.com measures to respond promptly to non-compliance and undertake appropriate corrective action. 1.41 Ethics: Do the Right Thing! Notes: Ethics: Do the Right Thing! As part of the Medicare Program, you must conduct yourself in an ethical and legal manner. It’s about doing the right thing! Act fairly and honestly Adhere to high ethical standards in all you do Comply with all applicable laws, regulations, and CMS requirements Report suspected violations Published by Articulate® Storyline www.articulate.com 1.42 How Do You Know What Is Expected of You? Notes: How Do you Know What Is Expected of You? Now that you’ve read the general ethical guidelines on the previous page, how do you know what is expected of you in a specific situation? Standards of Conduct (or Code of Conduct) state the organization’s compliance expectations and their operational principles and values. Organizational Standards of Conduct vary. The organization should tailor the Standards of Conduct content to their individual organization’s culture and business operations. Ask management where to locate your organization’s Published by Articulate® Storyline www.articulate.com Standards of Conduct. Reporting Standards of Conduct violations and suspected non-compliance is everyone’s responsibility. An organization’s Standards of Conduct and Policies and Procedures should identify this obligation and tell you how to report suspected non-compliance. 1.43 What Is Non-Compliance? Notes: What is Non-Compliance? Non-compliance is conduct that does not conform to the Published by Articulate® Storyline www.articulate.com law, Federal health care program requirements, or an organization’s ethical and business policies. CMS has identified the following Medicare Parts C and D high risk areas listed on your screen. Click on the button to learn more about the consequences of non-compliance. Consequences of Non-Compliance (Slide Layer) Published by Articulate® Storyline www.articulate.com 1.44 Non-Compliance Affects Everybody Notes: Non-Compliance Affects Everybody Without programs to prevent, detect, and correct non- compliance, we all risk the items listed on your screen. Published by Articulate® Storyline www.articulate.com 1.45 How to Report Potential Non-Compliance Notes: How to Report Potential Non-Compliance Employees of a Sponsor Call the Medicare Compliance Officer Make a report through your organization’s website Call the Compliance Hotline First-Tier, Downstream, or Related Entity (FDR) Employees Talk to a Manager or Supervisor Call your Ethics/Compliance Help Line Report to the sponsor Published by Articulate® Storyline www.articulate.com Beneficiaries Call the sponsor’s Compliance Hotline or Customer Service Make a report through the sponsor’s website Call 1-800-Medicare 1.46 What Happens After Non-Compliance Is Detected? Notes: What Happens After Non-Compliance Is Detected? Non-compliance must be investigated immediately and corrected promptly. Internal monitoring should continue to ensure: No recurrence of the same non-compliance Published by Articulate® Storyline www.articulate.com Ongoing CMS requirements compliance Efficient and effective internal controls Protected enrollees 1.47 What Are Internal Monitoring and Audits? Notes: What Are Internal Monitoring and Audits? Internal monitoring activities include regular reviews to confirm ongoing compliance and taking effective corrective actions. Internal auditing is a formal review of compliance with a particular set of standards (for example, policies and procedures, laws, and regulations) used as base measures. Published by Articulate® Storyline www.articulate.com 1.48 Compliance Program Training: Summary Notes: Compliance Program Training: Summary Organizations must create and maintain compliance programs that, at a minimum, meet the seven core requirements. An effective compliance program fosters a culture of compliance. To help ensure compliance, behave ethically and follow your organization’s Standards of Conduct. Watch for common instances of non-compliance, and report suspected non-compliance. Know the consequences of non-compliance, and help correct any non-compliance with a corrective action plan Published by Articulate® Storyline www.articulate.com that includes ongoing monitoring and auditing. 1.49 Post-Assessment Notes: Post-Assessment This assessment asks you 10 questions about Medicare Parts C and D compliance programs. It should take about 5 minutes to complete. Please choose the answer for each question by clicking on the button next to your answer. You may change your answer to a question until you click on the “SUBMIT ANSWER” button, at which time your answer is submitted. After you submit your answer, the “NEXT” button will Published by Articulate® Storyline www.articulate.com appear, along with feedback on your answer. Click on the “NEXT” button to continue to the next question. You can only move forward in the Post-Assessment and you can answer each question only once. Click the “NEXT” button to continue to the first Post- Assessment question. 1.50 Question 1 of 10 (Multiple Choice, 10 points, 1 attempt permitted) Correct Choice True Published by Articulate® Storyline www.articulate.com X False Feedback when correct: That is correct. This is False. Feedback when incorrect: That is incorrect. The correct answer is False. Notes: Correct (Slide Layer) Published by Articulate® Storyline www.articulate.com Incorrect (Slide Layer) 1.51 Question 2 of 10 (Multiple Choice, 10 points, 1 attempt permitted) Published by Articulate® Storyline www.articulate.com Correct Choice Telephone hotlines Report on the sponsor’s website In-person reporting to the compliance department/supervisor X All of the above Feedback when correct: The answer is D. All of the above are applicable. Feedback when incorrect: The correct answer is D. All of the above are applicable. Notes: Published by Articulate® Storyline www.articulate.com Correct (Slide Layer) Incorrect (Slide Layer) Published by Articulate® Storyline www.articulate.com 1.52 Question 3 of 10 (Multiple Choice, 10 points, 1 attempt permitted) Correct Choice Allows the sponsor to discipline employees who violate the Code of Conduct Prohibits management and supervisor from harassing employees for misconduct X Protects employees who, in good faith, report suspected non-compliance Prevents fights between employees Feedback when correct: The answer is C. It protects employees who, in good faith, report suspected non-compliance. Feedback when incorrect: The correct answer is C. It protects employees who, in good faith, report suspected non- compliance. Published by Articulate® Storyline www.articulate.com Notes: Correct (Slide Layer) Published by Articulate® Storyline www.articulate.com Incorrect (Slide Layer) 1.53 Question 4 of 10 (Multiple Choice, 10 points, 1 attempt permitted) Published by Articulate® Storyline www.articulate.com Correct Choice X True False Feedback when correct: That is correct. This answer is True. Feedback when incorrect: That is incorrect. The correct answer is True. Notes: Correct (Slide Layer) Published by Articulate® Storyline www.articulate.com Incorrect (Slide Layer) 1.54 Question 5 of 10 (Multiple Choice, 10 points, 1 attempt permitted) Published by Articulate® Storyline www.articulate.com Correct Choice True X False Feedback when correct: That is correct. The correct answer is False. Feedback when incorrect: That is incorrect. The correct answer is False. Notes: Correct (Slide Layer) Published by Articulate® Storyline www.articulate.com Incorrect (Slide Layer) 1.55 Question 6 of 10 (Multiple Choice, 10 points, 1 attempt permitted) Published by Articulate® Storyline www.articulate.com Correct Choice True X False Feedback when correct: That is correct. The correct answer is False. Feedback when incorrect: That is incorrect. The correct answer is False. Notes: Correct (Slide Layer) Published by Articulate® Storyline www.articulate.com Incorrect (Slide Layer) 1.56 Question 7 of 10 (Multiple Choice, 10 points, 1 attempt permitted) Published by Articulate® Storyline www.articulate.com Correct Choice True X False Feedback when correct: That is correct. The correct answer is False. Feedback when incorrect: That is incorrect. The correct answer is False. Notes: Correct (Slide Layer) Published by Articulate® Storyline www.articulate.com Incorrect (Slide Layer) 1.57 Question 8 of 10 (Multiple Choice, 10 points, 1 attempt permitted) Published by Articulate® Storyline www.articulate.com Correct Choice True X False Feedback when correct: That is correct. The correct answer is False. Feedback when incorrect: That is incorrect. The correct answer is False. Notes: Incorrect (Slide Layer) Published by Articulate® Storyline www.articulate.com Correct (Slide Layer) 1.58 Question 9 of 10 (Multiple Choice, 10 points, 1 attempt permitted) Published by Articulate® Storyline www.articulate.com Correct Choice X Protects enrollees, avoids recurrence of the same non-compliance, and promotes efficiency Ensure bonuses for all employees Both A. and B. Feedback when correct: The correct answer is A. Protects enrollees, avoids recurrence of the same non-compliance, and promotes efficiency. Feedback when incorrect: That is incorrect. The correct answer is A. Protects enrollees, avoids recurrence of the same non- compliance, and promotes efficiency Notes: Published by Articulate® Storyline www.articulate.com Correct (Slide Layer) Incorrect (Slide Layer) Published by Articulate® Storyline www.articulate.com 1.59 Question 10 of 10 (Multiple Choice, 10 points, 1 attempt permitted) Correct Choice Disciplinary action Termination of employment Exclusion from participation in all Federal health care programs X All of the above Feedback when correct: The correct answer is D: All of the above. Feedback when incorrect: That is incorrect. The correct answer is D: All of the above. Published by Articulate® Storyline www.articulate.com Notes: Correct (Slide Layer) Published by Articulate® Storyline www.articulate.com Incorrect (Slide Layer) 1.60 Post-Assessment Results (Results Slide, 0 points, 1 attempt permitted) Published by Articulate® Storyline www.articulate.com Results for 1.50 Question 1 of 10 1.51 Question 2 of 10 1.52 Question 3 of 10 1.53 Question 4 of 10 1.54 Question 5 of 10 1.55 Question 6 of 10 1.56 Question 7 of 10 1.57 Question 8 of 10 1.58 Question 9 of 10 1.59 Question 10 of 10 Result slide properties Passing 70% Score Published by Articulate® Storyline www.articulate.com Success (Slide Layer) Failure (Slide Layer) Published by Articulate® Storyline www.articulate.com 1.61 Thank you Notes: Thank You You’ve completed Part 3. Please exit this course and proceed to the final exam. Published by Articulate® Storyline www.articulate.com 2. Lightbox 2.1 How to Navigate Notes: How to navigate Please take a moment to learn how to navigate this course, including using the course menu, resources and other features. Click each button to learn how to navigate this course. Published by Articulate® Storyline www.articulate.com 1 Menu (Slide Layer) 2 Menu and Gloss (Slide Layer) Published by Articulate® Storyline www.articulate.com 3 Accessing Resources (Slide Layer) 4 Prev and Next Buttons (Slide Layer) Published by Articulate® Storyline www.articulate.com 2.2 Disclaimer Notes: Published by Articulate® Storyline www.articulate.com

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