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Question 1 of 10
1. Question
A transaction monitoring alert at a wealth manager has triggered regarding Service line marketing and promotion during market conduct. The alert details show that a practice manager is conducting an internal audit of the marketing department’s 12-month promotional strategy for a new bariatric surgery service line. The audit reveals a ‘Patient Ambassador’ program where existing patients receive a $100 credit toward their own future elective procedures for every new patient they refer who completes a surgical consultation. What is the primary legal risk that the practice manager must document in the audit report?
Correct
Correct: The Civil Monetary Penalties (CMP) Law prohibits offering inducements to Medicare or Medicaid beneficiaries that are likely to influence their selection of a particular provider, and the Anti-Kickback Statute (AKS) prohibits remuneration to induce referrals. A $100 credit for referrals directly targets patient behavior through financial incentives, which is a high-risk area in healthcare marketing and must be flagged during an internal audit.
Incorrect
Correct: The Civil Monetary Penalties (CMP) Law prohibits offering inducements to Medicare or Medicaid beneficiaries that are likely to influence their selection of a particular provider, and the Anti-Kickback Statute (AKS) prohibits remuneration to induce referrals. A $100 credit for referrals directly targets patient behavior through financial incentives, which is a high-risk area in healthcare marketing and must be flagged during an internal audit.
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Question 2 of 10
2. Question
A whistleblower report received by a private bank alleges issues with Burnout prevention and physician well-being programs during business continuity. The allegation claims that a large multi-specialty group practice, recently acquired through a bank-financed private equity deal, has systematically dismantled its physician well-being initiatives to prioritize short-term revenue cycles during a 14-month EHR transition. The report highlights that physician turnover has reached 28%, and ‘pajama time’—uncompensated EHR work at home—has doubled. As the Practice Manager, which of the following strategies is most effective for addressing the root causes of this burnout while ensuring the long-term viability of the practice?
Correct
Correct: The most effective way to combat physician burnout is to address systemic issues rather than individual ones. Research consistently shows that administrative burden, particularly related to EHR documentation and inefficient workflows, is a primary driver of burnout. By forming a clinician-led committee, the practice ensures that those performing the work are the ones redesigning it, leading to more meaningful reductions in ‘pajama time’ and administrative friction.
Incorrect: Mandatory resilience training focuses on the individual’s ability to handle stress rather than fixing the environment causing the stress, which can often lead to further resentment. Increasing productivity-based compensation or RVU targets encourages higher volume, which typically exacerbates burnout and work-life imbalance. Standardizing encounter lengths to a short duration often ignores the complexity of patient needs, potentially increasing stress by forcing physicians to rush through difficult cases or fall behind schedule.
Takeaway: Effective physician well-being programs must focus on systemic workflow optimization and reducing administrative burden through clinician-led initiatives rather than individual resilience training.
Incorrect
Correct: The most effective way to combat physician burnout is to address systemic issues rather than individual ones. Research consistently shows that administrative burden, particularly related to EHR documentation and inefficient workflows, is a primary driver of burnout. By forming a clinician-led committee, the practice ensures that those performing the work are the ones redesigning it, leading to more meaningful reductions in ‘pajama time’ and administrative friction.
Incorrect: Mandatory resilience training focuses on the individual’s ability to handle stress rather than fixing the environment causing the stress, which can often lead to further resentment. Increasing productivity-based compensation or RVU targets encourages higher volume, which typically exacerbates burnout and work-life imbalance. Standardizing encounter lengths to a short duration often ignores the complexity of patient needs, potentially increasing stress by forcing physicians to rush through difficult cases or fall behind schedule.
Takeaway: Effective physician well-being programs must focus on systemic workflow optimization and reducing administrative burden through clinician-led initiatives rather than individual resilience training.
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Question 3 of 10
3. Question
A regulatory inspection at an investment firm focuses on Dashboard development and reporting in the context of whistleblowing. The examiner notes that the firm’s healthcare portfolio, specifically a large multi-specialty physician practice, lacks a structured reporting mechanism for the Board to oversee compliance risks. The Practice Manager is tasked with developing a dashboard to track internal reports of potential billing fraud and ethical violations for the quarterly compliance review. To ensure the dashboard serves as an effective tool for governance and risk mitigation while maintaining legal protections, which of the following should be the primary focus of the reporting structure?
Correct
Correct: In physician practice management and internal audit, a dashboard intended for executive oversight should prioritize high-level risk assessment and the effectiveness of management’s response. Categorizing incidents by severity allows the Board to focus on high-risk areas, while tracking the status of corrective action plans ensures that identified issues are being remediated, which is a key component of an effective compliance program under OIG guidelines.
Incorrect: Disclosing the names of staff involved in reports (option_b) can lead to breaches of confidentiality and potential whistleblower retaliation, creating significant legal and ethical risks. Providing raw, unedited transcripts (option_c) fails to provide the necessary analysis for strategic decision-making and may expose sensitive or irrelevant data that has not been vetted. Benchmarking healthcare reporting against non-healthcare industries (option_d) is ineffective because the regulatory environment for medical billing and clinical practice is unique and not comparable to other sectors like manufacturing or retail.
Takeaway: Effective compliance dashboards for physician practices must focus on risk categorization and remediation status to support strategic oversight without compromising confidentiality or operational efficiency.
Incorrect
Correct: In physician practice management and internal audit, a dashboard intended for executive oversight should prioritize high-level risk assessment and the effectiveness of management’s response. Categorizing incidents by severity allows the Board to focus on high-risk areas, while tracking the status of corrective action plans ensures that identified issues are being remediated, which is a key component of an effective compliance program under OIG guidelines.
Incorrect: Disclosing the names of staff involved in reports (option_b) can lead to breaches of confidentiality and potential whistleblower retaliation, creating significant legal and ethical risks. Providing raw, unedited transcripts (option_c) fails to provide the necessary analysis for strategic decision-making and may expose sensitive or irrelevant data that has not been vetted. Benchmarking healthcare reporting against non-healthcare industries (option_d) is ineffective because the regulatory environment for medical billing and clinical practice is unique and not comparable to other sectors like manufacturing or retail.
Takeaway: Effective compliance dashboards for physician practices must focus on risk categorization and remediation status to support strategic oversight without compromising confidentiality or operational efficiency.
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Question 4 of 10
4. Question
Which statement most accurately reflects Patient financial responsibility and collections for Certified Physician Practice Manager (CPPM) in practice? A multi-specialty group is experiencing a significant increase in its days in accounts receivable (AR) and a decrease in the net collection rate. The practice manager is tasked with restructuring the front-end revenue cycle processes to address these issues while maintaining high patient satisfaction scores.
Correct
Correct: Collecting patient responsibility at the point of service is the most effective method for reducing accounts receivable and improving cash flow. A well-defined financial policy, combined with staff training on how to communicate these requirements, ensures that expectations are set early and professionally, which is a core competency for a CPPM managing the revenue cycle.
Incorrect: Deferring financial discussions until after the encounter often leads to patients leaving without paying, significantly increasing the cost of collection. Waiving copayments or deductibles without a documented, consistently applied financial hardship policy can violate payer contracts and federal regulations like the Anti-Kickback Statute. Transferring accounts to collections at only thirty days is prematurely aggressive, likely to damage patient satisfaction, and ignores the standard internal billing cycle of 90 to 120 days.
Takeaway: Proactive point-of-service collection supported by clear financial policies and staff training is essential for maintaining a healthy medical practice revenue cycle.
Incorrect
Correct: Collecting patient responsibility at the point of service is the most effective method for reducing accounts receivable and improving cash flow. A well-defined financial policy, combined with staff training on how to communicate these requirements, ensures that expectations are set early and professionally, which is a core competency for a CPPM managing the revenue cycle.
Incorrect: Deferring financial discussions until after the encounter often leads to patients leaving without paying, significantly increasing the cost of collection. Waiving copayments or deductibles without a documented, consistently applied financial hardship policy can violate payer contracts and federal regulations like the Anti-Kickback Statute. Transferring accounts to collections at only thirty days is prematurely aggressive, likely to damage patient satisfaction, and ignores the standard internal billing cycle of 90 to 120 days.
Takeaway: Proactive point-of-service collection supported by clear financial policies and staff training is essential for maintaining a healthy medical practice revenue cycle.
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Question 5 of 10
5. Question
The monitoring system at a payment services provider has flagged an anomaly related to Due diligence processes during sanctions screening. Investigation reveals that a physician group currently being evaluated for a strategic merger has failed to perform monthly checks against the Office of Inspector General (OIG) List of Excluded Individuals/Entities (LEIE) for its contracted laboratory services over the past 24 months. As the Practice Manager overseeing the due diligence process, which action is most critical to address the potential successor liability?
Correct
Correct: In the context of healthcare due diligence, failing to screen for excluded entities (OIG LEIE) creates significant risk under the Civil Monetary Penalties Law. If a practice receives federal funds for services ordered or provided by an excluded entity, those claims are considered overpayments. A retrospective audit is essential to quantify the financial exposure and determine if a voluntary disclosure to the OIG is necessary to mitigate penalties before the acquisition or merger is finalized.
Incorrect: While terminating the contract and implementing software are good prospective steps, they do not address the historical financial liability that the acquiring practice may inherit. A written attestation of ‘no intent’ does not provide legal protection against the strict liability nature of receiving funds for services involving excluded parties. Requesting a flag clearance based on clinical necessity is irrelevant because the exclusion status of a provider or entity legally prohibits federal reimbursement regardless of the quality of care provided.
Takeaway: Due diligence in physician practice management must prioritize the identification and quantification of historical compliance liabilities, particularly regarding OIG exclusions, to prevent the inheritance of significant federal penalties.
Incorrect
Correct: In the context of healthcare due diligence, failing to screen for excluded entities (OIG LEIE) creates significant risk under the Civil Monetary Penalties Law. If a practice receives federal funds for services ordered or provided by an excluded entity, those claims are considered overpayments. A retrospective audit is essential to quantify the financial exposure and determine if a voluntary disclosure to the OIG is necessary to mitigate penalties before the acquisition or merger is finalized.
Incorrect: While terminating the contract and implementing software are good prospective steps, they do not address the historical financial liability that the acquiring practice may inherit. A written attestation of ‘no intent’ does not provide legal protection against the strict liability nature of receiving funds for services involving excluded parties. Requesting a flag clearance based on clinical necessity is irrelevant because the exclusion status of a provider or entity legally prohibits federal reimbursement regardless of the quality of care provided.
Takeaway: Due diligence in physician practice management must prioritize the identification and quantification of historical compliance liabilities, particularly regarding OIG exclusions, to prevent the inheritance of significant federal penalties.
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Question 6 of 10
6. Question
In your capacity as product governance lead at a fintech lender, you are handling Physician productivity and compensation models during periodic review. A colleague forwards you a policy exception request showing that a group of senior physicians in an affiliated medical practice are requesting a modification to their wRVU-based compensation plan. The request highlights that their current productivity metrics do not account for the significant time spent on clinical oversight of advanced practice providers (APPs) and administrative leadership. To ensure the model remains compliant with Fair Market Value (FMV) standards while incentivizing both volume and quality, which strategy should be recommended?
Correct
Correct: A hybrid model involving a base salary, wRVU-based incentives, and administrative stipends is the most effective way to balance productivity with non-clinical responsibilities. This approach ensures that physicians are compensated for the value of their leadership and supervision (which are not captured by personally performed wRVUs) while maintaining a clear link between clinical effort and pay. Using market-based stipends for administrative work helps maintain compliance with Fair Market Value (FMV) and the Stark Law, as it avoids inflating clinical conversion factors for non-clinical work.
Incorrect: A pure collections-minus-expenses model can lead to high income volatility and fails to specifically address the need to compensate for non-revenue generating administrative time. Increasing the wRVU conversion factor above the 90th percentile without a clear clinical justification creates significant regulatory risk regarding Fair Market Value and could be viewed as an inducement for referrals. Paying physicians a direct percentage of the gross billings of supervised mid-level providers is legally risky under the Anti-Kickback Statute and Stark Law, as it may be interpreted as compensation based on the volume or value of referrals.
Takeaway: Effective physician compensation must utilize a multi-faceted approach that separately accounts for clinical productivity, administrative leadership, and supervision to ensure both operational equity and regulatory compliance.
Incorrect
Correct: A hybrid model involving a base salary, wRVU-based incentives, and administrative stipends is the most effective way to balance productivity with non-clinical responsibilities. This approach ensures that physicians are compensated for the value of their leadership and supervision (which are not captured by personally performed wRVUs) while maintaining a clear link between clinical effort and pay. Using market-based stipends for administrative work helps maintain compliance with Fair Market Value (FMV) and the Stark Law, as it avoids inflating clinical conversion factors for non-clinical work.
Incorrect: A pure collections-minus-expenses model can lead to high income volatility and fails to specifically address the need to compensate for non-revenue generating administrative time. Increasing the wRVU conversion factor above the 90th percentile without a clear clinical justification creates significant regulatory risk regarding Fair Market Value and could be viewed as an inducement for referrals. Paying physicians a direct percentage of the gross billings of supervised mid-level providers is legally risky under the Anti-Kickback Statute and Stark Law, as it may be interpreted as compensation based on the volume or value of referrals.
Takeaway: Effective physician compensation must utilize a multi-faceted approach that separately accounts for clinical productivity, administrative leadership, and supervision to ensure both operational equity and regulatory compliance.
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Question 7 of 10
7. Question
During your tenure as product governance lead at a broker-dealer, a matter arises concerning Physician Practice Human Resources and Workforce Development Programs during complaints handling. The a whistleblower report suggests that a recently integrated multi-specialty medical group is bypassing standardized onboarding protocols to meet aggressive patient volume targets. Specifically, the report indicates that medical assistants are performing specialized diagnostic tests without documented competency assessments, leading to increased error rates in patient records and potential safety risks. To address these workforce development concerns and mitigate operational risk, what is the most appropriate management strategy?
Correct
Correct: In physician practice management, ensuring that staff are competent to perform their assigned duties is a fundamental HR and risk management requirement. A formal competency-based assessment framework provides documented evidence that an employee has the necessary skills and knowledge to perform specific tasks safely and accurately. This approach aligns with regulatory standards and quality improvement methodologies by creating a verifiable control point before clinical duties are delegated.
Incorrect: Peer-review systems are useful for professional development but lack the formal validation and supervisory oversight required for high-risk clinical tasks. Revising the employee handbook to focus on disciplinary actions is a reactive measure that addresses the symptoms of errors rather than the root cause, which is a lack of training and assessment. Transitioning to a productivity-based compensation model would likely exacerbate the problem by prioritizing speed over quality and safety, further incentivizing the bypassing of protocols.
Takeaway: Effective workforce development in healthcare requires a structured, documented competency assessment process to ensure patient safety and regulatory compliance.
Incorrect
Correct: In physician practice management, ensuring that staff are competent to perform their assigned duties is a fundamental HR and risk management requirement. A formal competency-based assessment framework provides documented evidence that an employee has the necessary skills and knowledge to perform specific tasks safely and accurately. This approach aligns with regulatory standards and quality improvement methodologies by creating a verifiable control point before clinical duties are delegated.
Incorrect: Peer-review systems are useful for professional development but lack the formal validation and supervisory oversight required for high-risk clinical tasks. Revising the employee handbook to focus on disciplinary actions is a reactive measure that addresses the symptoms of errors rather than the root cause, which is a lack of training and assessment. Transitioning to a productivity-based compensation model would likely exacerbate the problem by prioritizing speed over quality and safety, further incentivizing the bypassing of protocols.
Takeaway: Effective workforce development in healthcare requires a structured, documented competency assessment process to ensure patient safety and regulatory compliance.
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Question 8 of 10
8. Question
Which consideration is most important when selecting an approach to Physician impairment and substance abuse policies? In a large multi-specialty group practice, the management team is reviewing the protocol for handling clinical staff who may be struggling with chemical dependency. The board of directors is concerned about the intersection of employment law, state medical board mandates, and the ethical duty to protect patients from harm while maintaining the practice’s operational integrity.
Correct
Correct: State medical boards and laws typically mandate the reporting of impaired physicians to ensure patient safety. Physician Health Programs (PHPs) are specialized resources that provide a pathway for physicians to receive treatment and monitoring, often allowing for a confidential return to practice if the physician complies with the program. This approach balances the legal obligation to report with the ethical and professional goal of rehabilitation.
Incorrect: Public disclosure prior to a formal finding or board action can lead to defamation lawsuits and is not a standard requirement for managing impairment. Internal-only remediation plans often violate state mandatory reporting laws and lack the specialized expertise needed to monitor substance abuse effectively. Immediate termination without due process or investigation can expose the practice to wrongful termination litigation and ignores the rehabilitative options provided by state-sanctioned programs.
Takeaway: Effective physician impairment policies must integrate mandatory state reporting requirements with structured rehabilitation pathways like PHPs to protect patients while supporting professional recovery and due process.
Incorrect
Correct: State medical boards and laws typically mandate the reporting of impaired physicians to ensure patient safety. Physician Health Programs (PHPs) are specialized resources that provide a pathway for physicians to receive treatment and monitoring, often allowing for a confidential return to practice if the physician complies with the program. This approach balances the legal obligation to report with the ethical and professional goal of rehabilitation.
Incorrect: Public disclosure prior to a formal finding or board action can lead to defamation lawsuits and is not a standard requirement for managing impairment. Internal-only remediation plans often violate state mandatory reporting laws and lack the specialized expertise needed to monitor substance abuse effectively. Immediate termination without due process or investigation can expose the practice to wrongful termination litigation and ignores the rehabilitative options provided by state-sanctioned programs.
Takeaway: Effective physician impairment policies must integrate mandatory state reporting requirements with structured rehabilitation pathways like PHPs to protect patients while supporting professional recovery and due process.
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Question 9 of 10
9. Question
A new business initiative at an insurer requires guidance on Internal control audits as part of record-keeping. The proposal raises questions about how a large physician group ensures the accuracy of its encounter data following the implementation of a new automated coding tool within the Electronic Health Record (EHR). The Practice Manager is tasked with performing an internal audit 60 days after go-live to ensure that the automated codes match the clinical documentation provided by the providers. Which of the following audit activities provides the most reliable evidence that the internal controls for revenue integrity are functioning as intended?
Correct
Correct: A dual-coding audit, also known as shadow coding, is a substantive test of the internal control system. By having a human expert independently verify the clinical documentation against the system-generated codes, the Practice Manager can directly measure the accuracy and reliability of the automated record-keeping process. This ensures that the practice is neither losing revenue through under-coding nor facing compliance risks through up-coding.
Incorrect: Reviewing audit logs is a critical security control to prevent unauthorized access, but it does not validate the accuracy of the data being recorded. Analyzing days in accounts receivable (DAR) is a high-level financial performance metric that can be influenced by many external factors, such as payer processing times, and does not provide evidence of individual record accuracy. Staff interviews provide qualitative data on workflow and satisfaction but do not constitute a formal audit of the integrity of the financial records or the effectiveness of the automated coding logic.
Takeaway: To validate the effectiveness of automated record-keeping controls, internal audits must include a direct comparison between the source documentation and the system’s output.
Incorrect
Correct: A dual-coding audit, also known as shadow coding, is a substantive test of the internal control system. By having a human expert independently verify the clinical documentation against the system-generated codes, the Practice Manager can directly measure the accuracy and reliability of the automated record-keeping process. This ensures that the practice is neither losing revenue through under-coding nor facing compliance risks through up-coding.
Incorrect: Reviewing audit logs is a critical security control to prevent unauthorized access, but it does not validate the accuracy of the data being recorded. Analyzing days in accounts receivable (DAR) is a high-level financial performance metric that can be influenced by many external factors, such as payer processing times, and does not provide evidence of individual record accuracy. Staff interviews provide qualitative data on workflow and satisfaction but do not constitute a formal audit of the integrity of the financial records or the effectiveness of the automated coding logic.
Takeaway: To validate the effectiveness of automated record-keeping controls, internal audits must include a direct comparison between the source documentation and the system’s output.
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Question 10 of 10
10. Question
Following a thematic review of Physician productivity and compensation models as part of conflicts of interest, a fintech lender received feedback indicating that several physicians in a large multi-specialty group were consistently generating work Relative Value Units (wRVUs) in the 99th percentile of national benchmarks. The lender, evaluating the practice for a capital expansion loan, expressed concern that the current compensation structure, which pays a flat dollar amount per wRVU without a cap, might incentivize over-utilization of services. As the Practice Manager, which action should be prioritized to mitigate the risk of regulatory non-compliance and ensure the practice remains within Fair Market Value (FMV) guidelines?
Correct
Correct: In a productivity-based compensation model, the primary risk is that the incentive to generate wRVUs may lead to over-utilization or billing for services that are not medically necessary. Implementing a robust internal auditing and monitoring program is the most effective way to ensure that high productivity is legitimate and supported by clinical documentation. This protects the practice from False Claims Act and Stark Law violations by demonstrating that compensation is paid for actual, necessary work performed at Fair Market Value.
Incorrect: Capping compensation at a specific percentile may limit financial payout but does not address the underlying risk of medically unnecessary services being billed to payers. Requiring administrative approval for specific procedures is impractical in a clinical setting and may interfere with the physician-patient relationship or delay care. While adjusting the base salary component changes the financial structure, it does not provide the necessary oversight or validation of the work already being performed and billed.
Takeaway: Effective risk management in physician compensation requires balancing productivity incentives with objective clinical auditing to ensure that high-volume billing is supported by medical necessity and documentation.
Incorrect
Correct: In a productivity-based compensation model, the primary risk is that the incentive to generate wRVUs may lead to over-utilization or billing for services that are not medically necessary. Implementing a robust internal auditing and monitoring program is the most effective way to ensure that high productivity is legitimate and supported by clinical documentation. This protects the practice from False Claims Act and Stark Law violations by demonstrating that compensation is paid for actual, necessary work performed at Fair Market Value.
Incorrect: Capping compensation at a specific percentile may limit financial payout but does not address the underlying risk of medically unnecessary services being billed to payers. Requiring administrative approval for specific procedures is impractical in a clinical setting and may interfere with the physician-patient relationship or delay care. While adjusting the base salary component changes the financial structure, it does not provide the necessary oversight or validation of the work already being performed and billed.
Takeaway: Effective risk management in physician compensation requires balancing productivity incentives with objective clinical auditing to ensure that high-volume billing is supported by medical necessity and documentation.