PHYSICIAN/HOSPITAL FINANCIAL ARRANGEMENTS POST-TEST. Name: Date: Practice Plan:

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1 PHYSICIAN/HOSPITAL FINANCIAL ARRANGEMENTS POST-TEST Name: Date: Practice Plan: Phone: ************************************************************************ 1. Which of the following legislation was not addressed in today s presentation on financial arrangements between physicians and hospitals? a. Internal Revenue Code c. EMTALA b. Stark laws d. Antikickback Statute 2. True or False: Violation of Stark, a criminal statute, can result in a prison sentence. 3. Under Stark, the definition of referral includes: a. Referrals directed by or controlled by a physician, such as by the physician s employees. b. Services personally performed by a physician. c. Services performed incident to the services of a referring physician. d. A request for a consultation with another physician 4. Under Stark, a financial relationship may be: a. An ownership interest in an entity b. An investment interest in an entity c. A compensation arrangement with an entity d. All of the above. 5. True or False: Under Stark, a compensation arrangement does not include compensation paid to an immediate family member of a physician.

2 6. Which of the following is NOT an example of a compensation arrangement between a physician and a hospital? a. Physician employment agreement. b. Medical director agreement. c. Lease of hospital equipment and supplies. d. A physician office lease at an offsite location not owned by the hospital. 7. Which of the following compensation arrangements may qualify as exceptions under Stark? a. Office space rentals b. Bona fide employment relationships c. Bonus agreements based on volume of referrals made to the hospital. d. a and b only 8. To qualify for an exception under Stark, a lease must be set forth in writing and have a term of at least: a. One month b. Six months c. One year d. Three years 9. True or False: To qualify for an exception under Stark, hospital contracts for personal services with physicians must contain compensation that varies depending on the volume or value of patient referrals. 10. True or False: To qualify for the employment exception under Stark, a hospital may hire a physician to perform services that have not yet been identified, provided that a job description is created within 6 months following the commencement of employment. 11. True or False: One penalty for violation of the Stark Law is payment of civil money penalties of up to $15,000 for each service a person knew or should have known was provided in violation of the Stark Law.

3 12. Potential sanctions and penalties for violations of the Stark Law include: a. Physician exclusion from federal payor programs b. Imprisonment c. Denial of payment for DHS provided in violation of the Stark Law d. Both a and c above 13. Under the Antikickback Statute, prohibited conduct includes which of the following: a. Remuneration intended to induce referral of patients b. Remuneration intended to induce the purchasing, leasing, ordering or arranging for any good facility, service or item paid for by Medicaid or State health care programs c. Both a and b above d. Neither a nor b above 14. True or False: There are a total of eighteen safe harbors under the Antikickback Statute. 15. True or False: In the OIG s mind, compliance with a Stark law exception is a defense under the Antikickback Statute. 16. For a lease to qualify as an exception under the Antikickback Statute, all of the following are true except: a. The rental amount must be fair market value b. The term cannot be less than two years c. The lease must in writing and signed by both parties d. The lease specifies the premises and equipment covered by the lease 17. True or False: Fair market value cannot be adjusted to reflect the additional value the lessee places on proximity or convenience to the lessor, if the lessor is a source of referrals to the lessee.

4 18. Under the Antikickback Statute, a written lease signed by both parties must have a term of at least to qualify as an exception. a. Two years b. Six months c. One year d. 90 days 19. To qualify as an exception under the Antikickback Statute, a contract between a hospital and physician as an independent contractor for personal services must meet which of the following conditions? a. The agreement must specify the services to be provided by the physician, and services performed under the agreement must not be illegal. b. The agreement, if intended to provide for services on a periodic or part time basis, must specify exactly the schedule of service intervals, their precise length and exact charge for such intervals. c. The agreement must in writing, signed by the parties and cannot be for less than one year. d. All of the above 20. True or False: Under the Antikickback Statute safe harbor for employees, in contrast to an independent contractor, the provider can pay the employee without a written agreement and without committing to a term of not less than one year. 21. Fair market value includes contract dollars AND: a. billing and collections b. equipment/supplies/personnel c. other perks and freebies d. all of the above 22. True or False: Sec 501(c)(3) of the Internal Revenue Code provides that only a small part of the net earnings of a tax-exempt entity may inure to the benefit of a private individual (a concept commonly referred to as private inurement. )

5 23. True or False: Examples of private inurement are payments of profits to board members of a charitable organization or the purchase of assets from a third party for an amount in excess of the FMV of such assets. 24. Failure to adhere to the prohibition on private inurement could: a. result in large fines to the hospital b. result in jail time for the offending party c. jeopardize the tax exempt status of the hospital d. all of the above 25. Along with fair market value the most important thing to remember is/are which of the following? a. Use no hospital resources without a contract. b. Provide no services without a contract. c. Accept no payment (cash or in kind) without a contract. d. All of the above. ************************************************************************ To receive credit for completing this self-study course, in lieu of attending the mandatory live training program, please print and complete the post-test that accompanied this presentation. You must answer at least 20 out of 25 questions correctly (80%). Please be sure to include ALL contact information above. After you have completed the test, send it to: Sue Marasi, Compliance Administrator UB Associates, Inc Main Street, 211 Harriman Buffalo, NY Fax: (716)

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