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Question 1 of 10
1. Question
Which safeguard provides the strongest protection when dealing with Types of healthcare fraud (e.g., billing for services not rendered, upcoding, phantom billing)? In a high-volume multi-specialty practice, the compliance department is reviewing its internal controls to ensure that the services billed to Medicare and private payers accurately reflect the clinical encounters documented in the electronic health record (EHR).
Correct
Correct: A retrospective audit involving a three-way match is the most robust safeguard because it validates the entire lifecycle of a claim. By comparing the clinical documentation (evidence of service), the encounter form (the intent to bill), and the final claim (the actual bill), the organization can identify upcoding or phantom billing. Adding patient verification provides an external check to ensure services were actually rendered, which is the only definitive way to detect phantom billing where documentation might be falsified.
Incorrect: Professional certifications and ethics training are important for establishing a culture of compliance but do not provide a mechanical or procedural control to detect active fraud. Claim scrubbing software is highly effective at catching technical coding errors and unbundling, but it cannot determine if a service documented in the system was actually performed. High-level revenue trend analysis can flag potential areas for investigation, but it lacks the granular detail required to confirm whether specific claims are fraudulent or simply reflect a change in patient acuity.
Takeaway: The most effective fraud prevention and detection strategy involves reconciling clinical evidence with billing data and performing independent verification of service delivery to ensure claims are truthful and accurate.
Incorrect
Correct: A retrospective audit involving a three-way match is the most robust safeguard because it validates the entire lifecycle of a claim. By comparing the clinical documentation (evidence of service), the encounter form (the intent to bill), and the final claim (the actual bill), the organization can identify upcoding or phantom billing. Adding patient verification provides an external check to ensure services were actually rendered, which is the only definitive way to detect phantom billing where documentation might be falsified.
Incorrect: Professional certifications and ethics training are important for establishing a culture of compliance but do not provide a mechanical or procedural control to detect active fraud. Claim scrubbing software is highly effective at catching technical coding errors and unbundling, but it cannot determine if a service documented in the system was actually performed. High-level revenue trend analysis can flag potential areas for investigation, but it lacks the granular detail required to confirm whether specific claims are fraudulent or simply reflect a change in patient acuity.
Takeaway: The most effective fraud prevention and detection strategy involves reconciling clinical evidence with billing data and performing independent verification of service delivery to ensure claims are truthful and accurate.
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Question 2 of 10
2. Question
How should Medicare Program be implemented in practice when a provider determines that a specific service, normally covered under Medicare Part B, is likely to be denied for a specific patient due to frequency limitations or lack of medical necessity for that specific clinical scenario?
Correct
Correct: Under Medicare Program guidelines, when a provider believes a service that is usually covered may be denied because it is not medically necessary or exceeds frequency limits, they must issue an Advanced Beneficiary Notice of Noncoverage (ABN). This form must be given to the beneficiary before the service is rendered, explaining why Medicare is unlikely to pay, and must be signed by the patient to legally shift financial liability from the provider to the patient.
Incorrect: Appending a GA modifier without having a signed ABN on file is a compliance violation and does not legally allow the provider to collect from the patient. Retroactive waivers are not valid under Medicare rules as the patient must be informed of financial risk before the service occurs. Bypassing the claim submission process for covered services is generally prohibited for participating providers, and verbal notification is insufficient to establish financial liability for a Medicare-covered benefit.
Takeaway: The Advanced Beneficiary Notice (ABN) is the essential regulatory mechanism for protecting a provider’s right to payment when Medicare is expected to deny a service based on medical necessity or frequency.
Incorrect
Correct: Under Medicare Program guidelines, when a provider believes a service that is usually covered may be denied because it is not medically necessary or exceeds frequency limits, they must issue an Advanced Beneficiary Notice of Noncoverage (ABN). This form must be given to the beneficiary before the service is rendered, explaining why Medicare is unlikely to pay, and must be signed by the patient to legally shift financial liability from the provider to the patient.
Incorrect: Appending a GA modifier without having a signed ABN on file is a compliance violation and does not legally allow the provider to collect from the patient. Retroactive waivers are not valid under Medicare rules as the patient must be informed of financial risk before the service occurs. Bypassing the claim submission process for covered services is generally prohibited for participating providers, and verbal notification is insufficient to establish financial liability for a Medicare-covered benefit.
Takeaway: The Advanced Beneficiary Notice (ABN) is the essential regulatory mechanism for protecting a provider’s right to payment when Medicare is expected to deny a service based on medical necessity or frequency.
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Question 3 of 10
3. Question
Your team is drafting a policy on Authorization for specialist visits and procedures as part of data protection for an investment firm. A key unresolved point is the protocol for employees utilizing the firm’s HMO-based health plan. For a specialist consultation to be deemed medically necessary and eligible for payment, the policy must define the role of the Primary Care Physician (PCP) in the authorization chain. Which action is required by the PCP to ensure the specialist visit is authorized under standard managed care rules?
Correct
Correct: In a Health Maintenance Organization (HMO) model, the Primary Care Physician (PCP) acts as a gatekeeper. For a specialist visit to be covered by the insurance plan, the PCP must provide a formal referral. This mechanism is used to manage healthcare utilization and ensure that specialist services are medically necessary before the insurer accepts financial liability for the claim.
Incorrect: Providing medical records is a clinical and data protection requirement but does not serve as an insurance authorization for payment. Pre-certification is generally reserved for specific high-cost procedures or hospitalizations and must typically be obtained before the service occurs, not 48 hours after. Coordination of Benefits (COB) is the process of determining which insurance plan is primary when a patient is covered by more than one policy, and it does not authorize specific specialist consultations.
Takeaway: In managed care plans like HMOs, a formal referral from a primary care gatekeeper is a mandatory prerequisite for authorized specialist consultations and subsequent claim payment.
Incorrect
Correct: In a Health Maintenance Organization (HMO) model, the Primary Care Physician (PCP) acts as a gatekeeper. For a specialist visit to be covered by the insurance plan, the PCP must provide a formal referral. This mechanism is used to manage healthcare utilization and ensure that specialist services are medically necessary before the insurer accepts financial liability for the claim.
Incorrect: Providing medical records is a clinical and data protection requirement but does not serve as an insurance authorization for payment. Pre-certification is generally reserved for specific high-cost procedures or hospitalizations and must typically be obtained before the service occurs, not 48 hours after. Coordination of Benefits (COB) is the process of determining which insurance plan is primary when a patient is covered by more than one policy, and it does not authorize specific specialist consultations.
Takeaway: In managed care plans like HMOs, a formal referral from a primary care gatekeeper is a mandatory prerequisite for authorized specialist consultations and subsequent claim payment.
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Question 4 of 10
4. Question
How do different methodologies for Premium tax credits and cost-sharing reductions compare in terms of effectiveness? When assisting a consumer during the open enrollment period, a medical insurance specialist must evaluate how federal subsidies impact the total cost of care. If a consumer’s household income falls between 100% and 250% of the federal poverty level, they may be eligible for both Premium Tax Credits (PTC) and Cost-Sharing Reductions (CSR). In determining the most effective plan choice for a consumer who anticipates high medical utilization, which statement accurately reflects the application of these methodologies?
Correct
Correct: Cost-sharing reductions (CSRs) are specifically designed to lower out-of-pocket costs such as deductibles, copayments, and coinsurance by increasing the actuarial value of the plan. However, by regulation, these are only available to individuals who enroll in a Silver-tier plan on the health insurance marketplace. In contrast, Premium Tax Credits (PTCs) are more flexible and can be used to lower the monthly premium of any plan tier (Bronze, Silver, Gold, or Platinum) chosen by the eligible consumer.
Incorrect: One alternative incorrectly suggests that premium tax credits are restricted to Silver plans, when in fact they are plan-agnostic. Another alternative incorrectly states that cost-sharing reductions are available across all metal tiers, which ignores the Silver-plan requirement. The final alternative incorrectly claims that cost-sharing reductions apply to Gold or Platinum plans or that premium tax credits are primarily for catastrophic plans, which misrepresents the eligibility and purpose of both subsidy types.
Takeaway: Cost-sharing reductions are plan-specific (Silver only) and target out-of-pocket expenses, whereas premium tax credits are plan-agnostic and target monthly premium costs.
Incorrect
Correct: Cost-sharing reductions (CSRs) are specifically designed to lower out-of-pocket costs such as deductibles, copayments, and coinsurance by increasing the actuarial value of the plan. However, by regulation, these are only available to individuals who enroll in a Silver-tier plan on the health insurance marketplace. In contrast, Premium Tax Credits (PTCs) are more flexible and can be used to lower the monthly premium of any plan tier (Bronze, Silver, Gold, or Platinum) chosen by the eligible consumer.
Incorrect: One alternative incorrectly suggests that premium tax credits are restricted to Silver plans, when in fact they are plan-agnostic. Another alternative incorrectly states that cost-sharing reductions are available across all metal tiers, which ignores the Silver-plan requirement. The final alternative incorrectly claims that cost-sharing reductions apply to Gold or Platinum plans or that premium tax credits are primarily for catastrophic plans, which misrepresents the eligibility and purpose of both subsidy types.
Takeaway: Cost-sharing reductions are plan-specific (Silver only) and target out-of-pocket expenses, whereas premium tax credits are plan-agnostic and target monthly premium costs.
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Question 5 of 10
5. Question
As the product governance lead at an insurer, you are reviewing Medicaid benefits and coverage during outsourcing when an internal audit finding arrives on your desk. It reveals that a third-party administrator (TPA) has been processing claims for a state-contracted Medicaid Managed Care Organization (MCO) for the past six months using a unified utilization management framework. The audit identifies that several claims for Early and Periodic Screening, Diagnostic, and Treatment (EPSDT) services for beneficiaries under age 21 were denied because the services exceeded the plan’s standard adult benefit limits for physical therapy and durable medical equipment. Which action is most appropriate to ensure compliance with federal Medicaid requirements regarding EPSDT benefits?
Correct
Correct: EPSDT is a mandatory federal Medicaid benefit for children under 21 that is significantly broader than adult Medicaid benefits. Under federal law, states and contracted MCOs must provide any service that is medically necessary to correct or ameliorate a physical or mental condition, provided the service is listed in Section 1905(a) of the Social Security Act. This requirement applies even if the service is not covered under the state’s Medicaid plan for adults or if it exceeds the frequency or duration limits established for the adult population.
Incorrect: Applying adult limits to children is a violation of federal Medicaid law because EPSDT mandates coverage based on medical necessity rather than arbitrary plan caps. Seeking a waiver to align these benefits is generally not permissible because EPSDT is a core, non-waivable protection for minors. Implementing a dollar-based threshold for review does not solve the compliance failure, as all medically necessary services must be covered regardless of cost or standard plan limitations.
Takeaway: EPSDT mandates that Medicaid-eligible children receive any medically necessary service defined by federal law, regardless of whether those services or limits are included in the state’s standard adult benefit package.
Incorrect
Correct: EPSDT is a mandatory federal Medicaid benefit for children under 21 that is significantly broader than adult Medicaid benefits. Under federal law, states and contracted MCOs must provide any service that is medically necessary to correct or ameliorate a physical or mental condition, provided the service is listed in Section 1905(a) of the Social Security Act. This requirement applies even if the service is not covered under the state’s Medicaid plan for adults or if it exceeds the frequency or duration limits established for the adult population.
Incorrect: Applying adult limits to children is a violation of federal Medicaid law because EPSDT mandates coverage based on medical necessity rather than arbitrary plan caps. Seeking a waiver to align these benefits is generally not permissible because EPSDT is a core, non-waivable protection for minors. Implementing a dollar-based threshold for review does not solve the compliance failure, as all medically necessary services must be covered regardless of cost or standard plan limitations.
Takeaway: EPSDT mandates that Medicaid-eligible children receive any medically necessary service defined by federal law, regardless of whether those services or limits are included in the state’s standard adult benefit package.
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Question 6 of 10
6. Question
You have recently joined a private bank as internal auditor. Your first major assignment involves Provider responsibilities in documentation during internal audit remediation, and a regulator information request indicates that several high-value claims from the bank’s healthcare subsidiary lacked sufficient evidence of medical necessity. During your review of the remediation plan, you must identify the core standard that providers must meet to satisfy both clinical and reimbursement requirements. Which of the following best describes the provider’s primary responsibility in this context?
Correct
Correct: The provider is fundamentally responsible for the clinical integrity of the medical record. This includes providing a detailed clinical rationale and objective findings that justify the level of service (CPT codes) and the medical necessity of the encounter. Furthermore, the record must be authenticated (signed) by the rendering provider to be legally and professionally valid for reimbursement.
Incorrect: Delegating clinical narrative drafting to coders is inappropriate because coders cannot document clinical observations they did not personally perform. Finalizing documentation after insurance adjudication is a violation of contemporaneous documentation standards and may be considered fraudulent. Prioritizing administrative fields on a claim form over the actual clinical progress notes fails to address the core requirement of proving medical necessity, which is the basis for the audit remediation.
Takeaway: Providers are ultimately responsible for the clinical integrity and authentication of documentation to prove medical necessity for all billed services.
Incorrect
Correct: The provider is fundamentally responsible for the clinical integrity of the medical record. This includes providing a detailed clinical rationale and objective findings that justify the level of service (CPT codes) and the medical necessity of the encounter. Furthermore, the record must be authenticated (signed) by the rendering provider to be legally and professionally valid for reimbursement.
Incorrect: Delegating clinical narrative drafting to coders is inappropriate because coders cannot document clinical observations they did not personally perform. Finalizing documentation after insurance adjudication is a violation of contemporaneous documentation standards and may be considered fraudulent. Prioritizing administrative fields on a claim form over the actual clinical progress notes fails to address the core requirement of proving medical necessity, which is the basis for the audit remediation.
Takeaway: Providers are ultimately responsible for the clinical integrity and authentication of documentation to prove medical necessity for all billed services.
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Question 7 of 10
7. Question
A regulatory inspection at a broker-dealer focuses on Medicaid Program in the context of model risk. The examiner notes that the internal audit department identified a recurring failure in the coordination of benefits for dual-eligible beneficiaries. During a review of 200 sample claims from the previous fiscal year, it was found that the billing department frequently submitted claims for durable medical equipment directly to Medicaid without first seeking reimbursement from Medicare, under the assumption that the items were non-covered. Which of the following represents the most appropriate audit recommendation to ensure compliance with federal Medicaid regulations?
Correct
Correct: Medicaid is legally established as the payer of last resort under federal law. For individuals who are dual-eligible (enrolled in both Medicare and Medicaid), Medicare is the primary payer for covered services. Providers are required to bill Medicare first and receive an adjudication, such as a Remittance Advice (RA) showing payment or a formal denial, before Medicaid can be billed. This ensures that Medicaid only pays for costs that no other party is responsible for, maintaining the integrity of the program’s funding.
Incorrect: Using modifiers to bypass Medicare without an actual denial is a violation of coordination of benefits rules and constitutes non-compliant billing. Exhaustion of Part A benefits does not automatically make Medicaid the primary payer for all services, as Part B or other supplemental insurance may still be the primary resource for outpatient services or equipment. A pay-and-chase model where Medicaid is billed first is generally prohibited for providers; the burden is on the provider to identify and bill the correct primary payer before seeking Medicaid funds, except in very specific circumstances like prenatal care or pediatric preventive services.
Takeaway: Medicaid is the payer of last resort and requires all other insurance resources, including Medicare, to be exhausted and adjudicated before a claim is submitted to Medicaid.
Incorrect
Correct: Medicaid is legally established as the payer of last resort under federal law. For individuals who are dual-eligible (enrolled in both Medicare and Medicaid), Medicare is the primary payer for covered services. Providers are required to bill Medicare first and receive an adjudication, such as a Remittance Advice (RA) showing payment or a formal denial, before Medicaid can be billed. This ensures that Medicaid only pays for costs that no other party is responsible for, maintaining the integrity of the program’s funding.
Incorrect: Using modifiers to bypass Medicare without an actual denial is a violation of coordination of benefits rules and constitutes non-compliant billing. Exhaustion of Part A benefits does not automatically make Medicaid the primary payer for all services, as Part B or other supplemental insurance may still be the primary resource for outpatient services or equipment. A pay-and-chase model where Medicaid is billed first is generally prohibited for providers; the burden is on the provider to identify and bill the correct primary payer before seeking Medicaid funds, except in very specific circumstances like prenatal care or pediatric preventive services.
Takeaway: Medicaid is the payer of last resort and requires all other insurance resources, including Medicare, to be exhausted and adjudicated before a claim is submitted to Medicaid.
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Question 8 of 10
8. Question
Excerpt from an incident report: In work related to Medicare Part B (Medical Insurance) as part of record-keeping at a private bank, it was noted that an internal review of health-related reimbursement accounts identified a recurring issue regarding outpatient diagnostic services. A beneficiary received several medically necessary laboratory tests from a non-participating provider who did not accept assignment. The audit team is evaluating the potential financial liability for the beneficiary to ensure the bank’s supplemental insurance product is correctly calculating secondary payments. Which of the following best describes the financial impact on the beneficiary when a provider does not accept assignment for a Medicare Part B covered service?
Correct
Correct: When a provider is non-participating and does not accept assignment, they have not agreed to accept the Medicare-approved amount as payment in full. Under Medicare Part B rules, these providers can charge more than the Medicare-approved amount, but they are subject to a ‘limiting charge.’ This limiting charge is capped at 15 percent over the Medicare-approved amount. The beneficiary is responsible for the difference between the Medicare payment and the limiting charge, in addition to their standard coinsurance.
Incorrect: The suggestion that the beneficiary is only responsible for the 20 percent coinsurance is incorrect because that only applies when a provider accepts assignment. The claim that coverage is voided is incorrect because Medicare still covers services from non-participating providers, provided the service is medically necessary and the provider has not formally opted out of the Medicare system entirely. The idea that a provider must discount the bill by 15 percent is a misunderstanding of the limiting charge; the limiting charge is a ceiling on what can be billed, not a mandatory discount from the provider’s standard rates.
Takeaway: Beneficiaries using non-participating providers who do not accept assignment may be subject to a limiting charge of 15 percent above the Medicare-approved amount for covered services.
Incorrect
Correct: When a provider is non-participating and does not accept assignment, they have not agreed to accept the Medicare-approved amount as payment in full. Under Medicare Part B rules, these providers can charge more than the Medicare-approved amount, but they are subject to a ‘limiting charge.’ This limiting charge is capped at 15 percent over the Medicare-approved amount. The beneficiary is responsible for the difference between the Medicare payment and the limiting charge, in addition to their standard coinsurance.
Incorrect: The suggestion that the beneficiary is only responsible for the 20 percent coinsurance is incorrect because that only applies when a provider accepts assignment. The claim that coverage is voided is incorrect because Medicare still covers services from non-participating providers, provided the service is medically necessary and the provider has not formally opted out of the Medicare system entirely. The idea that a provider must discount the bill by 15 percent is a misunderstanding of the limiting charge; the limiting charge is a ceiling on what can be billed, not a mandatory discount from the provider’s standard rates.
Takeaway: Beneficiaries using non-participating providers who do not accept assignment may be subject to a limiting charge of 15 percent above the Medicare-approved amount for covered services.
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Question 9 of 10
9. Question
A regulatory guidance update affects how a private bank must handle Managed care utilization management processes in the context of transaction monitoring. The new requirement implies that clinical necessity must be validated through rigorous prospective review to prevent the misappropriation of healthcare funds. When a provider submits a request for a high-cost diagnostic imaging procedure, the utilization management team must verify that the patient has met specific clinical milestones. If the documentation provided is insufficient to prove medical necessity according to the plan’s evidence-based guidelines, what is the most appropriate next step for the utilization management coordinator?
Correct
Correct: In managed care utilization management, the prospective review process (prior authorization) requires that medical necessity be established before a service is performed. If the initial submission lacks sufficient clinical detail, the coordinator should ‘pend’ the request. This status allows the provider a specific timeframe to submit the necessary clinical evidence, such as conservative treatment history or diagnostic results, to justify the procedure under the plan’s medical necessity criteria.
Incorrect: Denying the request as a non-covered service is incorrect because medical necessity is a clinical evaluation, whereas ‘non-covered’ refers to services explicitly excluded by the insurance contract regardless of necessity. Approving the request as a courtesy or waiver undermines the entire purpose of utilization management, which is to ensure appropriate and cost-effective care. Subrogation is a legal process used to recover costs from a third party after a claim is paid and is unrelated to the clinical determination of medical necessity.
Takeaway: Prospective utilization management relies on the ‘pend’ process to obtain missing clinical documentation required to verify medical necessity before an authorization decision is finalized.
Incorrect
Correct: In managed care utilization management, the prospective review process (prior authorization) requires that medical necessity be established before a service is performed. If the initial submission lacks sufficient clinical detail, the coordinator should ‘pend’ the request. This status allows the provider a specific timeframe to submit the necessary clinical evidence, such as conservative treatment history or diagnostic results, to justify the procedure under the plan’s medical necessity criteria.
Incorrect: Denying the request as a non-covered service is incorrect because medical necessity is a clinical evaluation, whereas ‘non-covered’ refers to services explicitly excluded by the insurance contract regardless of necessity. Approving the request as a courtesy or waiver undermines the entire purpose of utilization management, which is to ensure appropriate and cost-effective care. Subrogation is a legal process used to recover costs from a third party after a claim is paid and is unrelated to the clinical determination of medical necessity.
Takeaway: Prospective utilization management relies on the ‘pend’ process to obtain missing clinical documentation required to verify medical necessity before an authorization decision is finalized.
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Question 10 of 10
10. Question
A client relationship manager at a fund administrator seeks guidance on Documentation required for appeals as part of periodic review. They explain that a high-dollar claim for a spinal fusion (CPT 22840) was denied by the third-party administrator due to a lack of medical necessity. The provider has initiated a formal appeal process and submitted a packet of information. To ensure a comprehensive review that aligns with industry standards for overturning a clinical denial, which combination of documentation is most essential for the review committee to analyze?
Correct
Correct: To successfully appeal a denial based on medical necessity, the documentation must provide objective clinical evidence that the procedure was appropriate for the patient’s condition. A letter of medical necessity provides the surgeon’s clinical rationale, while operative reports and imaging (like MRIs or X-rays) provide objective proof of the pathology. Crucially, documentation of failed conservative treatments (such as physical therapy or medication) is often a specific requirement in payer policies for surgical interventions.
Incorrect: The other options fail to address the clinical core of a medical necessity denial. Providing the CMS-1500 form and deductible information focuses on administrative and financial processing rather than clinical justification. Financial responsibility statements and provider credentials do not prove the patient needed the specific surgery. Internal coding manuals and benefit summaries explain how a claim is processed or what is covered generally, but they do not provide the patient-specific clinical data required to overturn a medical necessity determination.
Takeaway: Successful medical necessity appeals require clinical evidence, including provider justification and objective diagnostic records, that directly addresses the payer’s specific clinical criteria for the service.
Incorrect
Correct: To successfully appeal a denial based on medical necessity, the documentation must provide objective clinical evidence that the procedure was appropriate for the patient’s condition. A letter of medical necessity provides the surgeon’s clinical rationale, while operative reports and imaging (like MRIs or X-rays) provide objective proof of the pathology. Crucially, documentation of failed conservative treatments (such as physical therapy or medication) is often a specific requirement in payer policies for surgical interventions.
Incorrect: The other options fail to address the clinical core of a medical necessity denial. Providing the CMS-1500 form and deductible information focuses on administrative and financial processing rather than clinical justification. Financial responsibility statements and provider credentials do not prove the patient needed the specific surgery. Internal coding manuals and benefit summaries explain how a claim is processed or what is covered generally, but they do not provide the patient-specific clinical data required to overturn a medical necessity determination.
Takeaway: Successful medical necessity appeals require clinical evidence, including provider justification and objective diagnostic records, that directly addresses the payer’s specific clinical criteria for the service.