2026 HCCA – CHC ACTUAL EXAM COMPLETE 500+
QUESTION AND ANSWER ALREADY GRADED A
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)
Expectations have evolved since 1991 when the US Sentencing Guidelines (USSG) were first drafted
highlighting the importance of an effective compliance program (and as a condition of probation) to
help detect criminal conduct (USSG chapter 8B2.1). DOJ has now set higher expectations for
organizations to not only have a designated compliance officer but a well designed compliance
program that is adequately resourced with independent authority function to work in practice. Which
of the following guidelines outlines those expectations:
a. HHS OIG - CPG (Compliance Program Guidance)
b. DOJ ECCP (Evaluation of Corporate Compliance Programs)
c. Monaco Memo
d. HHS OIG - CIA (Corporate Integrity Agreement)
b. DOJ ECCP (Evaluation of Corporate Compliance Programs)
The ECCP and other related guidance can be downloaded here:
https://www.justice.gov/criminal/criminal-fraud/policy-materials
The most updated DOJ ECCP (Evaluation of Corporate Compliance Programs) provides additional
guidance to prosecutors. Which of the following are included in the ECCP revisions (Sep 2024)?
a. expects company's compliance program to include safeguards to better monitor and manage
potential compliance risk regarding new technologies (e.g., A.I.)
b. expects company's to integrate these new technology related risks into broader enterprise risk
management (ERM) strategies
c. expands on post-acquisition compliance integration and use of data for compliance purposes
d. all of the above
,d. all of the above
An IRB received a self-report of investigator non-compliance describing a repeated failure to ensure
that all participants met inclusion criteria before receiving an investigational drug. The PI also
submitted a Corrective Action Plan that stated staff will be more careful to document that inclusion
and exclusion criteria are met, but IRB is unsatisfied with this plan. Which of the following is the
MOST appropriate:
a. suspend all the PI's clinical trials until the audits are completed
b. stop enrollment in all of the PI's clinical trials until they are audited
c. require the PI to undergo additional training in the GCP/ICH guidelines
d. consult SOP to determine the available options before taking action
b. stop enrollment in all of the PI's clinical trials until they are audited
A PI is accused of accepting kickbacks from a sponsor. The allegation is that the study budget included
an item for funds to cover office visits required by the study, but all the office visits have been billed
to insurance as "standard of care." A research compliance professional should FIRST notify the:
a. IRB to request initiation of an investigation
b. sponsor to inform that funds may have been inappropriately diverted
c. BOD to request that study-related billing be suspended
d. legal office to determine if an investigation should be conducted under privilege
d. legal office to determine if an investigation should be conducted under privilege
A private physician signed a clinical trial agreement with a drug company to receive funds from trial
sponsors for research services that must be conducted at a hospital. The physician contacted the
hospital and requested $25 per subject referred to the hospital. On which of the following should the
physician be educated:
a. HIPAA
b. Stark Law
c. Sarbanes-Oxley Act
d. Medicare Modernization Act
b. Stark Law
,Which of the following resources are MOST relevant for developing and updating a research
compliance work plan?
1. FDA warning letters
2. OIG inspection reports
3. OHRP determination letters
4. OSHA inspection reports
a. 1, 2, and 3
b. 1, 2, and 4
c. 1, 3, and 4
d. 2, 3, and 4
a. 1, 2, and 3
An investigation and necessary disciplinary action should be taken if a limited data set is released for:
a. research
b. marketing
c. public health
d. healthcare operations
b. marketing
Which of the following is responsible for clinical trial billing compliance and enforcement:
a. FDA
b. OIG
c. ORI
d. OCR
b. OIG
What should CCO be able to do? (What skills should this person have?) Choose all that apply.
a. Leadership skills.
b. Oversee the coding department.
c. Skills to design and implement a compliance program.
d. Be able to anticipate new risk areas.
e. Practical experience with documenting medical necessity.
a. Leadership skills,
c. Skills to design and implement a compliance program, and
d. Be able to anticipate new risk areas.
Which of the following is an absolute necessity in order to have a successful Compliance Program?
a. continuous training and improvements
b. effective reporting path
c. non-retaliation for whistleblowers
d. reliable and equal discipline
, c. non-retaliation for whistleblowers
A Compliance Program with well written policies and procedures:
a. can be successful if consistently reviewed and maintained
b. cannot be effective due to the sheer volume presented
c. will be effective if read by management
d. will not be successful without the proper oversight
d. will not be successful without the proper oversight
Regardless of having the best written policies in place that are reviewed/maintained consistently, and
read and disseminated accordingly, will fail if there is no proper oversight to ensure they are actually
being followed and understood.
A Compliance Officer can achieve a higher level of compliance and ethics engagement by:
a. ensuring leadership reads the policies
b. increasing management involvement
c. responding to compliance hotline calls
d. monitoring the code of conduct
b. increasing management involvement.
Compliance is everyone's responsibility, but management involvement is crucial. They have a direct
contact with employees, they know and understand their staff's needs and concerns, and have the most
influence over employee's actions and attitudes. Employees most likely use their direct manager(s) to
raise concerns and the reason they are so critical for an organization to foster a culture of compliance.
Which of the following requires providers to be permanently excluded from all federal health care
programs if found guilty of a healthcare related fraud a third time:
a. Deficit Reduction Act of 2005
b. False Claims Act
c. Balance Budget Act of 1997
d. Social Security Act section 1128d
c. Balance Budget Act of 1997
Also known as a BBA "three strikes rule"
What section of the ACA prevents discrimination against individuals with limited English proficiency
(LEP), and also prohibits discrimination in healthcare programs and activities that receive federal
funding, based on race, color, national origin, sex, age, or disability.
a. ACA section 6102
b. ACA section 1557
c. ACA section 6002
QUESTION AND ANSWER ALREADY GRADED A
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)
Expectations have evolved since 1991 when the US Sentencing Guidelines (USSG) were first drafted
highlighting the importance of an effective compliance program (and as a condition of probation) to
help detect criminal conduct (USSG chapter 8B2.1). DOJ has now set higher expectations for
organizations to not only have a designated compliance officer but a well designed compliance
program that is adequately resourced with independent authority function to work in practice. Which
of the following guidelines outlines those expectations:
a. HHS OIG - CPG (Compliance Program Guidance)
b. DOJ ECCP (Evaluation of Corporate Compliance Programs)
c. Monaco Memo
d. HHS OIG - CIA (Corporate Integrity Agreement)
b. DOJ ECCP (Evaluation of Corporate Compliance Programs)
The ECCP and other related guidance can be downloaded here:
https://www.justice.gov/criminal/criminal-fraud/policy-materials
The most updated DOJ ECCP (Evaluation of Corporate Compliance Programs) provides additional
guidance to prosecutors. Which of the following are included in the ECCP revisions (Sep 2024)?
a. expects company's compliance program to include safeguards to better monitor and manage
potential compliance risk regarding new technologies (e.g., A.I.)
b. expects company's to integrate these new technology related risks into broader enterprise risk
management (ERM) strategies
c. expands on post-acquisition compliance integration and use of data for compliance purposes
d. all of the above
,d. all of the above
An IRB received a self-report of investigator non-compliance describing a repeated failure to ensure
that all participants met inclusion criteria before receiving an investigational drug. The PI also
submitted a Corrective Action Plan that stated staff will be more careful to document that inclusion
and exclusion criteria are met, but IRB is unsatisfied with this plan. Which of the following is the
MOST appropriate:
a. suspend all the PI's clinical trials until the audits are completed
b. stop enrollment in all of the PI's clinical trials until they are audited
c. require the PI to undergo additional training in the GCP/ICH guidelines
d. consult SOP to determine the available options before taking action
b. stop enrollment in all of the PI's clinical trials until they are audited
A PI is accused of accepting kickbacks from a sponsor. The allegation is that the study budget included
an item for funds to cover office visits required by the study, but all the office visits have been billed
to insurance as "standard of care." A research compliance professional should FIRST notify the:
a. IRB to request initiation of an investigation
b. sponsor to inform that funds may have been inappropriately diverted
c. BOD to request that study-related billing be suspended
d. legal office to determine if an investigation should be conducted under privilege
d. legal office to determine if an investigation should be conducted under privilege
A private physician signed a clinical trial agreement with a drug company to receive funds from trial
sponsors for research services that must be conducted at a hospital. The physician contacted the
hospital and requested $25 per subject referred to the hospital. On which of the following should the
physician be educated:
a. HIPAA
b. Stark Law
c. Sarbanes-Oxley Act
d. Medicare Modernization Act
b. Stark Law
,Which of the following resources are MOST relevant for developing and updating a research
compliance work plan?
1. FDA warning letters
2. OIG inspection reports
3. OHRP determination letters
4. OSHA inspection reports
a. 1, 2, and 3
b. 1, 2, and 4
c. 1, 3, and 4
d. 2, 3, and 4
a. 1, 2, and 3
An investigation and necessary disciplinary action should be taken if a limited data set is released for:
a. research
b. marketing
c. public health
d. healthcare operations
b. marketing
Which of the following is responsible for clinical trial billing compliance and enforcement:
a. FDA
b. OIG
c. ORI
d. OCR
b. OIG
What should CCO be able to do? (What skills should this person have?) Choose all that apply.
a. Leadership skills.
b. Oversee the coding department.
c. Skills to design and implement a compliance program.
d. Be able to anticipate new risk areas.
e. Practical experience with documenting medical necessity.
a. Leadership skills,
c. Skills to design and implement a compliance program, and
d. Be able to anticipate new risk areas.
Which of the following is an absolute necessity in order to have a successful Compliance Program?
a. continuous training and improvements
b. effective reporting path
c. non-retaliation for whistleblowers
d. reliable and equal discipline
, c. non-retaliation for whistleblowers
A Compliance Program with well written policies and procedures:
a. can be successful if consistently reviewed and maintained
b. cannot be effective due to the sheer volume presented
c. will be effective if read by management
d. will not be successful without the proper oversight
d. will not be successful without the proper oversight
Regardless of having the best written policies in place that are reviewed/maintained consistently, and
read and disseminated accordingly, will fail if there is no proper oversight to ensure they are actually
being followed and understood.
A Compliance Officer can achieve a higher level of compliance and ethics engagement by:
a. ensuring leadership reads the policies
b. increasing management involvement
c. responding to compliance hotline calls
d. monitoring the code of conduct
b. increasing management involvement.
Compliance is everyone's responsibility, but management involvement is crucial. They have a direct
contact with employees, they know and understand their staff's needs and concerns, and have the most
influence over employee's actions and attitudes. Employees most likely use their direct manager(s) to
raise concerns and the reason they are so critical for an organization to foster a culture of compliance.
Which of the following requires providers to be permanently excluded from all federal health care
programs if found guilty of a healthcare related fraud a third time:
a. Deficit Reduction Act of 2005
b. False Claims Act
c. Balance Budget Act of 1997
d. Social Security Act section 1128d
c. Balance Budget Act of 1997
Also known as a BBA "three strikes rule"
What section of the ACA prevents discrimination against individuals with limited English proficiency
(LEP), and also prohibits discrimination in healthcare programs and activities that receive federal
funding, based on race, color, national origin, sex, age, or disability.
a. ACA section 6102
b. ACA section 1557
c. ACA section 6002
