HCCA CHC 2026 STUDY GUIDE QUESTIONS AND
ANSWERS GUARANTEE A+
✔✔Which statement is TRUE regarding compliance programs?
a. Compliance programs are considered more dangerous if they are developed but not
implemented.
b. Compliance programs can detect but not prevent criminal conduct
c. Compliance programs are only required by law for healthcare entities that have more
than $500,000 in annual revenue.
d. Compliance programs are not mandated by law. - ✔✔a. Compliance programs are
considered more dangerous if they are developed but not implemented.
✔✔An individual's understanding of the compliance aspects of their job can BEST be
enhanced by including compliance in:
a. annual evaluations
b. exit interviews
c. HR benefit materials
d. audit committee meetings - ✔✔a. annual evaluations
✔✔Formal statement outlining a plan for a specified subject area. It usually cites state
and/or federal required actions or standards.
a. CAP
b. Procedure document
c. Policy document
d. Legal standards - ✔✔c. Policy document
CAP - outlines corrective action plan
Procedure - describes process/steps under a certain criteria
Legal standards - mandatory action or rule
✔✔Life cycle of records management - ✔✔Creation
Use
Maintenance
Retention
Disposition
✔✔Standards of Conduct (written P&Ps) - ✔✔Demonstrate the organization's ethical
attitude and its "enterprise-wide" emphasis on compliance with all applicable laws and
regulations
✔✔Code of Conduct: Content Checklist - ✔✔• Demonstrate system wide emphasis on
compliance with all applicable laws and regulations
• Written plainly and concisely so all employees can understand the standards
• Includes internal and external regulations
• Mentions organizational policies without completely restating them
,• Is consistent with company policies and procedures
• Includes management's responsibility to explain and enforce the code
Ref: SCCE Compliance & Ethics Manual, Chapter 2
https://compliancecosmos.org/essential-elements-effective-ethics-and-compliance-
program
✔✔Code of Conduct and Employees - ✔✔All employees must receive, read, and
understand the standards.
A supervisor should explain the standards and answer any questions.
Employee should attest in writing that they have received, read, and understood the
standards
Employee compliance with standards must be enforced through appropriate discipline
when necessary
Discipline for non-compliance should be stated in the standards
✔✔Code of Conduct Purpose - ✔✔• To present specific guidelines for employees to
follow
• To confirm that all employees comprehend what is required of them
• To provide a process for proper decision making
• To confirm that employees put standards into everyday practice
• To elevate corporate performance in basic business relationship
• To confirm that the organization upholds and supports proper compliance conduct
✔✔Every organization needs policies and procedures for: - ✔✔• Internal assessments
• Record retention (where, how long)
• Self-disclosure
• Medicare sanction checks (LEIE)
• Billing policies
• Credit balance
• No charge visits
• Incomplete/unsuccessful procedure
• Documentation requirements
✔✔When should Code of Conduct be distributed to new employees? - ✔✔Must be
distributed within 90 days of hire
✔✔RAT-STATS is: (select all that apply)
a. statistical software to select randomized samples
b. government statistical rule software developed in the 1970s
c. free hospital statistical software
d. recommended by OIG, CMS and other agencies to select random samples - ✔✔a. b.
d.
,The software can be used by other entities other than hospitals, so option "c." is not
precisely accurate, but it is free to use and can be downloaded here:
https://oig.hhs.gov/compliance/rat-stats/index.asp
✔✔What is the term called for an organization's commitment to compliance by
management, employees, and contractors. Statement should summarize ethical
behavior and legal principles under which the healthcare organization operates? -
✔✔Code of Conduct
✔✔In the course of an audit, you find that disciplinary actions against certain physicians
and high level executives for non-compliance in the organization have been unfair and
inconsistent with current policies & procedures. What is your first course of action
.a. Work with legal counsel to enforce proper disciplinary actions
b. Get HR involved and recommend the use of progressive discipline policies
c. Immediately terminate these individuals
d. Get local and federal labor department involved for unfair discipline. - ✔✔b. Get HR
involved and recommend the use of progressive discipline policies
OIG recommends setting forth the degrees of disciplinary actions. Progressive discipline
provides a structure and a set of discipline standards for managers/supervisors to follow
to ensure discipline is fair, equitable and consistent.
✔✔Documentation - ✔✔• A&M should be documented
• Findings should be shared with dept managers
• If activity is part of risk priority then compliance committee, senior leadership and
board when necessary
• OIG calls for written evaluation to be presented to CEO, governing body, committee
annually
✔✔Non-retaliation in compliance - what is important to state in this policy: - ✔✔For any
reporting method to be effective, employees must accept that there will be no retaliation
or retribution for coming forward.
The concept of non-retaliation is fundamental to the compliance program, and a clearly
stated policy regarding non-retribution is the first step.
• anonymous reporting and,
• no retaliation or retribution for bringing forth problems/concerns
✔✔Place to start with Enforcement is: - ✔✔Standards of conduct and P&Ps
✔✔For Enforcement and Disciplinary Actions, Policies should include: - ✔✔1. non-
compliant consequences
2. employees duty to report non-compliance
3. list parties responsible for appropriate action
4. outline of disciplinary actions or procedures
5. promise that discipline will be fair and consistent
, ✔✔New Employee Policy - three checks OIG recommends to do/perform: - ✔✔OIG
recommends: perform background checks, reference checks, and exclusion list checks
✔✔Which two main documents become tools to build compliance program? - ✔✔Code
of Conduct and P&Ps
✔✔You are the new Compliance Officer, hired after ABC Hospital reorganized and
decided that the General Counsel should no longer also serve in that role. Upon review
of the Code of Conduct (CoC), you find that it is written using lots of legal jargon. What
action do you take:
a. Keep CoC as it is.
b. Pull a sample off the internet and insert hospital name to save time as it was most
likely written by experts.
c. Rewrite the CoC in plain and concise language tailored to the hospital so employees
can use a general guidance.
d. Rewrite the CoC with detailed restating hospital's P&Ps, and all laws and regulations
possible so that employees can't say they were not aware of requirements. - ✔✔c.
Rewrite the CoC in plain and concise language tailored to the hospital so employees
can use a general guidance.
Explanation:
• CoC should be clear and concise language easy to understand, and should be tailored
to specific issues of the organization
✔✔What is the term called for an organization's commitment to compliance by the
board, management, and employees? It summarizes ethical behavior and legal
principles the healthcare organization operates.
A) Code of Conduct
B) Federal Sentencing Guidelines
C) Internal Controls - ✔✔A) Code of Conduct
✔✔The U.S. Federal Sentencing Commission was organized in _____, published its
initial set of guidelines manual in _____ (known today as the US Sentencing
Guidelines), and included chapter eight of the Federal Sentencing Guidelines for
Organizations in _____.
a. 1980, 1987, 1999
b. 1985, 1987, 1991
c. 1980, 1985, 1987
d. 1985, 1990, 2001 - ✔✔b. 1985, 1987, 1991
The US Sentencing Guidelines (USSG) can be found here:
https://www.ussc.gov/guidelines.
Chapter 8 - Sentencing of organizations, includes Parts A-F (Part B 2.b.1 outlines the
Compliance and Ethics Program)
ANSWERS GUARANTEE A+
✔✔Which statement is TRUE regarding compliance programs?
a. Compliance programs are considered more dangerous if they are developed but not
implemented.
b. Compliance programs can detect but not prevent criminal conduct
c. Compliance programs are only required by law for healthcare entities that have more
than $500,000 in annual revenue.
d. Compliance programs are not mandated by law. - ✔✔a. Compliance programs are
considered more dangerous if they are developed but not implemented.
✔✔An individual's understanding of the compliance aspects of their job can BEST be
enhanced by including compliance in:
a. annual evaluations
b. exit interviews
c. HR benefit materials
d. audit committee meetings - ✔✔a. annual evaluations
✔✔Formal statement outlining a plan for a specified subject area. It usually cites state
and/or federal required actions or standards.
a. CAP
b. Procedure document
c. Policy document
d. Legal standards - ✔✔c. Policy document
CAP - outlines corrective action plan
Procedure - describes process/steps under a certain criteria
Legal standards - mandatory action or rule
✔✔Life cycle of records management - ✔✔Creation
Use
Maintenance
Retention
Disposition
✔✔Standards of Conduct (written P&Ps) - ✔✔Demonstrate the organization's ethical
attitude and its "enterprise-wide" emphasis on compliance with all applicable laws and
regulations
✔✔Code of Conduct: Content Checklist - ✔✔• Demonstrate system wide emphasis on
compliance with all applicable laws and regulations
• Written plainly and concisely so all employees can understand the standards
• Includes internal and external regulations
• Mentions organizational policies without completely restating them
,• Is consistent with company policies and procedures
• Includes management's responsibility to explain and enforce the code
Ref: SCCE Compliance & Ethics Manual, Chapter 2
https://compliancecosmos.org/essential-elements-effective-ethics-and-compliance-
program
✔✔Code of Conduct and Employees - ✔✔All employees must receive, read, and
understand the standards.
A supervisor should explain the standards and answer any questions.
Employee should attest in writing that they have received, read, and understood the
standards
Employee compliance with standards must be enforced through appropriate discipline
when necessary
Discipline for non-compliance should be stated in the standards
✔✔Code of Conduct Purpose - ✔✔• To present specific guidelines for employees to
follow
• To confirm that all employees comprehend what is required of them
• To provide a process for proper decision making
• To confirm that employees put standards into everyday practice
• To elevate corporate performance in basic business relationship
• To confirm that the organization upholds and supports proper compliance conduct
✔✔Every organization needs policies and procedures for: - ✔✔• Internal assessments
• Record retention (where, how long)
• Self-disclosure
• Medicare sanction checks (LEIE)
• Billing policies
• Credit balance
• No charge visits
• Incomplete/unsuccessful procedure
• Documentation requirements
✔✔When should Code of Conduct be distributed to new employees? - ✔✔Must be
distributed within 90 days of hire
✔✔RAT-STATS is: (select all that apply)
a. statistical software to select randomized samples
b. government statistical rule software developed in the 1970s
c. free hospital statistical software
d. recommended by OIG, CMS and other agencies to select random samples - ✔✔a. b.
d.
,The software can be used by other entities other than hospitals, so option "c." is not
precisely accurate, but it is free to use and can be downloaded here:
https://oig.hhs.gov/compliance/rat-stats/index.asp
✔✔What is the term called for an organization's commitment to compliance by
management, employees, and contractors. Statement should summarize ethical
behavior and legal principles under which the healthcare organization operates? -
✔✔Code of Conduct
✔✔In the course of an audit, you find that disciplinary actions against certain physicians
and high level executives for non-compliance in the organization have been unfair and
inconsistent with current policies & procedures. What is your first course of action
.a. Work with legal counsel to enforce proper disciplinary actions
b. Get HR involved and recommend the use of progressive discipline policies
c. Immediately terminate these individuals
d. Get local and federal labor department involved for unfair discipline. - ✔✔b. Get HR
involved and recommend the use of progressive discipline policies
OIG recommends setting forth the degrees of disciplinary actions. Progressive discipline
provides a structure and a set of discipline standards for managers/supervisors to follow
to ensure discipline is fair, equitable and consistent.
✔✔Documentation - ✔✔• A&M should be documented
• Findings should be shared with dept managers
• If activity is part of risk priority then compliance committee, senior leadership and
board when necessary
• OIG calls for written evaluation to be presented to CEO, governing body, committee
annually
✔✔Non-retaliation in compliance - what is important to state in this policy: - ✔✔For any
reporting method to be effective, employees must accept that there will be no retaliation
or retribution for coming forward.
The concept of non-retaliation is fundamental to the compliance program, and a clearly
stated policy regarding non-retribution is the first step.
• anonymous reporting and,
• no retaliation or retribution for bringing forth problems/concerns
✔✔Place to start with Enforcement is: - ✔✔Standards of conduct and P&Ps
✔✔For Enforcement and Disciplinary Actions, Policies should include: - ✔✔1. non-
compliant consequences
2. employees duty to report non-compliance
3. list parties responsible for appropriate action
4. outline of disciplinary actions or procedures
5. promise that discipline will be fair and consistent
, ✔✔New Employee Policy - three checks OIG recommends to do/perform: - ✔✔OIG
recommends: perform background checks, reference checks, and exclusion list checks
✔✔Which two main documents become tools to build compliance program? - ✔✔Code
of Conduct and P&Ps
✔✔You are the new Compliance Officer, hired after ABC Hospital reorganized and
decided that the General Counsel should no longer also serve in that role. Upon review
of the Code of Conduct (CoC), you find that it is written using lots of legal jargon. What
action do you take:
a. Keep CoC as it is.
b. Pull a sample off the internet and insert hospital name to save time as it was most
likely written by experts.
c. Rewrite the CoC in plain and concise language tailored to the hospital so employees
can use a general guidance.
d. Rewrite the CoC with detailed restating hospital's P&Ps, and all laws and regulations
possible so that employees can't say they were not aware of requirements. - ✔✔c.
Rewrite the CoC in plain and concise language tailored to the hospital so employees
can use a general guidance.
Explanation:
• CoC should be clear and concise language easy to understand, and should be tailored
to specific issues of the organization
✔✔What is the term called for an organization's commitment to compliance by the
board, management, and employees? It summarizes ethical behavior and legal
principles the healthcare organization operates.
A) Code of Conduct
B) Federal Sentencing Guidelines
C) Internal Controls - ✔✔A) Code of Conduct
✔✔The U.S. Federal Sentencing Commission was organized in _____, published its
initial set of guidelines manual in _____ (known today as the US Sentencing
Guidelines), and included chapter eight of the Federal Sentencing Guidelines for
Organizations in _____.
a. 1980, 1987, 1999
b. 1985, 1987, 1991
c. 1980, 1985, 1987
d. 1985, 1990, 2001 - ✔✔b. 1985, 1987, 1991
The US Sentencing Guidelines (USSG) can be found here:
https://www.ussc.gov/guidelines.
Chapter 8 - Sentencing of organizations, includes Parts A-F (Part B 2.b.1 outlines the
Compliance and Ethics Program)
