14. Describe at least six responses an organization could take upon discovering that one of its employees has committed acts of healthcare fraud.

4. You are the CO of a 230-bed teaching hospital. You have just read a newspaper article reporting that a physician on the hospital’s medical staff has been charged with violations of the False Claims Act in his private practice. The charges include upcoding and billing for unnecessary services.

Do you believe that there is any way that the hospital could be implicated in the physician’s misdeeds?
What is your first reaction to receiving this information?
If it appears that the charges are legitimate and some disciplinary action is necessary, what are your options?
When you suggest suspending the physician from the medical staff for 6 months, the Chief Medical Officer reminds you that the physician refers a large number of patients to the hospital. Does this make a difference to you?

4. If you were on the board of a healthcare organization, how much information would you want to receive about its compliance activities? How often would you want to hear about violation events? Would you want to hear about all of them, or just the most serious?

7. You are the Compliance Officer of a medical diagnostic laboratory. One of your employees arrives at work in the morning and tells you that he was approached on the street in front of your facility by a person claiming to represent a Medicare RAC. He asked the employee questions about the lab’s billing practices. The employee excused himself and wants to know how to handle these situations.

What is a RAC?
What advice will you give to the employee?

1. As Compliance Officer for a healthcare organization, in what circumstances would you choose NOT to disclose suspicious billing activity?

7. As a manager of employees, explain precisely how you would take into account their participation in compliance training in evaluating their job performance. Do you care whether they understood the training material or is it sufficient that they attended the training sessions?

5. Use five words to describe the monitoring process. Use another five words to describe an audit.