Compliance Interview

Activity:  As a new manager in the finance department responsible for the Revenue Cycle function, you

are interested in learning the level of readiness, education, and training of the department staff as

it relates to compliance. In order to obtain an accurate picture, a meeting with the Corporate

Compliance Officer was requested.  With the meeting set for Monday morning (plan on 45 minutes), there

are a number of items that will need to be considered as you reflect on the experiences learned at your

previous position.  Prior to giving notice and submitting your letter of resignation, the Office of the

Inspector General (OIG) was completing their audit of the Corporate Compliance Plan and reviewing the

organizations practices as they relate to the with the Responsible Corporate Officer Doctrine (RCO) .

It was rumored that the company was going to be subjected to a Corporate Integrity Agreement (CIA)

because of weak policies, lack of training programs, unclear communication of compliance initiatives,

and failure to implement the Corporate Compliance Program that was approved by the board prior to the

resignation of the organization’s Chief Executive Officer.
Question:  Develop an interview agenda (about 10 questions, with appropriate citations in APA format)

and be certain to consider not only your prior experience as you make a list of your questions but also

a careful ear and eye for hints of the type of compliance issues present with your new employer such as

their focus on the proposed Treasury regulations section 501r, on charitable Hospital Organizations,

FDA Red Flag Rules, Accounting control over Recovery Audit Adjustments, Privacy and HIPAA, Consumer

Collection Laws.  Also, develop for each question the Compliance Officer’s response and appropriate

reference citations in APA format.  In addition to the standard approach to agenda development (list of

topics, estimate of time for each item to be discussed, and any written material that you would like to

have the Compliance Officer review prior to the meeting) be aware of the meeting time and the politics

of the office.

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