Which of the following actions could lead to a civil monetary penalty?

Billing for services not performed could indeed lead to a civil monetary penalty because it constitutes fraudulent billing, which violates the accepted standards of medical billing and coding. Such conduct not only undermines the integrity of medical practices and healthcare providers but also represents a misuse of public funds when insurers, including Medicare and Medicaid, are billed for services that were never rendered.

Fraudulently charging for nonexistent services is taken very seriously by government regulators, and penalties can include substantial fines, exclusion from federal healthcare programs, and potential legal action against the provider. The other options, such as completing annual compliance training, providing free consultations, and engaging with patients about treatment options, are legitimate and ethical practices that do not involve deceptive billing or coding, and therefore would not incur civil monetary penalties.