CHC UPDATED COMPREHENSIVE TEST QUESTIONS AND
SOLUTIONS RATED A+
✔✔Policy (definition) - ✔✔1. statement of an approach to an issue
2. guidance on governing principle
3. rules that govern the organization
✔✔Procedure - ✔✔1. defines implementation of the policy
2. outlines steps to be taken
✔✔Components of Policy - ✔✔1. easy to understand
2. title
3. policy number
4. program area
5. purpose statement
6. definitions
7. responsible party
8. effective date
9. review date
10. related policies and procedures
11. applicability to whom
12. effect of non-compliance
✔✔Compliance Work Plan - ✔✔1. develop an annual road map
2. work with management (*)
3. communicate your plan
4. don't hesitate to make changes
5. include areas of concern and corrective action plans (*)
✔✔What is Infrastructure? - ✔✔basic framework of the organization (*)
organizational chart; strong foundation
buy in and commitment makes the program strong and effective
✔✔Compliance Program's Infrastructure (members) - ✔✔1. Board of Directors
2. Oversight Committee
3. Management
4. Physicians
5. Compliance Officer
6. Staff
✔✔What Impacts Infrastructure? (*) - ✔✔1. size
2. financial resources (compliance budget, people, training) - must match size
3. scope of program (what are you responsible for?)
for most - compliance is voluntary
,no one size fits all program
✔✔Physicians At Teaching Hospitals (PATH) - ✔✔1. 1990's
2. started putting compliance programs in place for Medicare billing
✔✔The Compliance Function - ✔✔prevention, detection, and resolution of actions
✔✔The Legal Function - ✔✔advises the organization on legal and regulatory risks,
defends the organization
✔✔The Internal Audit Function - ✔✔provides an objective evaluation of the existing risk
and internal controls and framework
✔✔The HR Function - ✔✔manages recruiting, screening, and hiring, provides training
and development
✔✔Quality Improvement - ✔✔promotes consistent, safe, and high quality practices
✔✔Compliance Oversight Committee - ✔✔1. Recommended by OIG (*)
2. goals and objectives set by chair
3. oversee implementation and operation of the program
4. review reports, statistical trends, and recommendations from the compliance officer
5. annual review and evaluation of the program
6. includes chair (not compliance officer), physician, compliance officer, coding/billing
expert, senior management/administrator, and legal counsel
7. established rotation
8. mandatory attendance
9. process for member removal
✔✔Compliance Officer - ✔✔1. direct board access
2. high level individual (authority to make decisions)
3. communicator (strong, strict, adheres to policies)
4. operational responsibility (leader, management of daily compliance operations,
implementation of each compliance element*)
5. trust and respect
6. confidentiality
7. stamina and self-confidence
8. leadership and organizational skills
9. spend time with management - get buy-in (*)
10. should not report to or be counsel for an organization (*)
✔✔Physicians (relationship to compliance) - ✔✔1. buy-in is key to success (responsible
for patient care)
2. understand compliance as a necessity
3. documentation and coding responsibility
,✔✔Compliance Staff - ✔✔1. knowledgeable, courteous, and responsive
2. compliance officer
3. compliance analyst
4. educators/trainers
5. employment contracts
✔✔Buy-In (*) - ✔✔1. compliance needs to be part of infrastructure
2. need buy-in from all chiefs
3. required for survival and effectiveness of the program
✔✔Key Buy-In Techniques - ✔✔1. motivation (key)
2. education
3. participation
4. cooperation
✔✔Building Trust - ✔✔1. communicate both good and bad news
2. keep commitments
3. honor confidentiality
4. allow frustrations to ventilate
5. take responsibility for mistakes
✔✔Strategic Planning - ✔✔1. strategic risks
2. mission, vision, and values
3. resource allocation
4. organization direction
5. goal achievement
✔✔Commission of Sponsoring Organizations (COSO) - ✔✔provides a sounds basis for
establishing internal control systems and determining their effectiveness
✔✔Internal Control (definition) (*) - ✔✔a process effected by an entity's board of
directors, management, and other personnel designed to provide reasonable assurance
regarding the achievement of objectives
✔✔Primary Objective of Internal Controls - ✔✔1. reliability and integrity of information
2. compliance with policies, plans, procedures, laws, regulations, and contracts
3. safeguarding of assets
4. economical and efficient use of resources
5. accomplishment of objectives and goals (avoid adverse outcomes)
✔✔COSO Components of Internal Control - ✔✔1. Control Environment (BOT, Senior
Management)
2. Risk Assessment
3. Control Activities (internal controls)
, 4. Information and Communication (appropriate information to people who need it)
5. Monitoring
✔✔Types of Internal Controls - ✔✔1. Preventative (ex: passwords)
2. Detective (ex: audit trails)
3. Directive (ex: policies, procedures, guidelines, etc.)
✔✔Benefits of Controlled Self-Assessment - ✔✔1. increases scope
2. targets audit work
3. frees internal audit resources
4. increases awareness
5. motivates personnel
✔✔Who Manages Risk? - ✔✔1. Administration
2. Legal
3. Quality
4. Risk Management (Patient Complaints)
5. Internal Audit
6. Compliance
✔✔Preparation of Audit Plan - ✔✔1. Identification of audit areas
2. classify audits of these units as operational, financial, compliance, or performance
3. identify the type of audit
✔✔Risk Mitigation Plan (development) - ✔✔1. identify top high-risk areas
2. develop risk mitigation plan
3. discuss draft plan with management
4. issue final risk mitigation plan
✔✔Adult Education Principles - ✔✔1. voluntary - learn based on their perceived need
2. trainers must capitalize on the experiences of participants (*)
3. should be characterized by mutual respect among participants
4. collaborative activity
✔✔Curriculum Design for Adult Learners - ✔✔1. single concept - focus on application
(*)
2. understand whether the concept/ideas will be in concert or in conflict with the learner
3. prefer self-directed and self-designed projects
4. more than one medium
5. control of pace
6. start and stop times
✔✔Classroom Design for Adult Learners - ✔✔1. capitalize on first session
2. physically and psychologically comfortable
3. self-esteem and ego are on the line
SOLUTIONS RATED A+
✔✔Policy (definition) - ✔✔1. statement of an approach to an issue
2. guidance on governing principle
3. rules that govern the organization
✔✔Procedure - ✔✔1. defines implementation of the policy
2. outlines steps to be taken
✔✔Components of Policy - ✔✔1. easy to understand
2. title
3. policy number
4. program area
5. purpose statement
6. definitions
7. responsible party
8. effective date
9. review date
10. related policies and procedures
11. applicability to whom
12. effect of non-compliance
✔✔Compliance Work Plan - ✔✔1. develop an annual road map
2. work with management (*)
3. communicate your plan
4. don't hesitate to make changes
5. include areas of concern and corrective action plans (*)
✔✔What is Infrastructure? - ✔✔basic framework of the organization (*)
organizational chart; strong foundation
buy in and commitment makes the program strong and effective
✔✔Compliance Program's Infrastructure (members) - ✔✔1. Board of Directors
2. Oversight Committee
3. Management
4. Physicians
5. Compliance Officer
6. Staff
✔✔What Impacts Infrastructure? (*) - ✔✔1. size
2. financial resources (compliance budget, people, training) - must match size
3. scope of program (what are you responsible for?)
for most - compliance is voluntary
,no one size fits all program
✔✔Physicians At Teaching Hospitals (PATH) - ✔✔1. 1990's
2. started putting compliance programs in place for Medicare billing
✔✔The Compliance Function - ✔✔prevention, detection, and resolution of actions
✔✔The Legal Function - ✔✔advises the organization on legal and regulatory risks,
defends the organization
✔✔The Internal Audit Function - ✔✔provides an objective evaluation of the existing risk
and internal controls and framework
✔✔The HR Function - ✔✔manages recruiting, screening, and hiring, provides training
and development
✔✔Quality Improvement - ✔✔promotes consistent, safe, and high quality practices
✔✔Compliance Oversight Committee - ✔✔1. Recommended by OIG (*)
2. goals and objectives set by chair
3. oversee implementation and operation of the program
4. review reports, statistical trends, and recommendations from the compliance officer
5. annual review and evaluation of the program
6. includes chair (not compliance officer), physician, compliance officer, coding/billing
expert, senior management/administrator, and legal counsel
7. established rotation
8. mandatory attendance
9. process for member removal
✔✔Compliance Officer - ✔✔1. direct board access
2. high level individual (authority to make decisions)
3. communicator (strong, strict, adheres to policies)
4. operational responsibility (leader, management of daily compliance operations,
implementation of each compliance element*)
5. trust and respect
6. confidentiality
7. stamina and self-confidence
8. leadership and organizational skills
9. spend time with management - get buy-in (*)
10. should not report to or be counsel for an organization (*)
✔✔Physicians (relationship to compliance) - ✔✔1. buy-in is key to success (responsible
for patient care)
2. understand compliance as a necessity
3. documentation and coding responsibility
,✔✔Compliance Staff - ✔✔1. knowledgeable, courteous, and responsive
2. compliance officer
3. compliance analyst
4. educators/trainers
5. employment contracts
✔✔Buy-In (*) - ✔✔1. compliance needs to be part of infrastructure
2. need buy-in from all chiefs
3. required for survival and effectiveness of the program
✔✔Key Buy-In Techniques - ✔✔1. motivation (key)
2. education
3. participation
4. cooperation
✔✔Building Trust - ✔✔1. communicate both good and bad news
2. keep commitments
3. honor confidentiality
4. allow frustrations to ventilate
5. take responsibility for mistakes
✔✔Strategic Planning - ✔✔1. strategic risks
2. mission, vision, and values
3. resource allocation
4. organization direction
5. goal achievement
✔✔Commission of Sponsoring Organizations (COSO) - ✔✔provides a sounds basis for
establishing internal control systems and determining their effectiveness
✔✔Internal Control (definition) (*) - ✔✔a process effected by an entity's board of
directors, management, and other personnel designed to provide reasonable assurance
regarding the achievement of objectives
✔✔Primary Objective of Internal Controls - ✔✔1. reliability and integrity of information
2. compliance with policies, plans, procedures, laws, regulations, and contracts
3. safeguarding of assets
4. economical and efficient use of resources
5. accomplishment of objectives and goals (avoid adverse outcomes)
✔✔COSO Components of Internal Control - ✔✔1. Control Environment (BOT, Senior
Management)
2. Risk Assessment
3. Control Activities (internal controls)
, 4. Information and Communication (appropriate information to people who need it)
5. Monitoring
✔✔Types of Internal Controls - ✔✔1. Preventative (ex: passwords)
2. Detective (ex: audit trails)
3. Directive (ex: policies, procedures, guidelines, etc.)
✔✔Benefits of Controlled Self-Assessment - ✔✔1. increases scope
2. targets audit work
3. frees internal audit resources
4. increases awareness
5. motivates personnel
✔✔Who Manages Risk? - ✔✔1. Administration
2. Legal
3. Quality
4. Risk Management (Patient Complaints)
5. Internal Audit
6. Compliance
✔✔Preparation of Audit Plan - ✔✔1. Identification of audit areas
2. classify audits of these units as operational, financial, compliance, or performance
3. identify the type of audit
✔✔Risk Mitigation Plan (development) - ✔✔1. identify top high-risk areas
2. develop risk mitigation plan
3. discuss draft plan with management
4. issue final risk mitigation plan
✔✔Adult Education Principles - ✔✔1. voluntary - learn based on their perceived need
2. trainers must capitalize on the experiences of participants (*)
3. should be characterized by mutual respect among participants
4. collaborative activity
✔✔Curriculum Design for Adult Learners - ✔✔1. single concept - focus on application
(*)
2. understand whether the concept/ideas will be in concert or in conflict with the learner
3. prefer self-directed and self-designed projects
4. more than one medium
5. control of pace
6. start and stop times
✔✔Classroom Design for Adult Learners - ✔✔1. capitalize on first session
2. physically and psychologically comfortable
3. self-esteem and ego are on the line
