HCCA CHC/CHPC EXAM STUDY GUIDE 2026
QUESTIONS AND SOLUTIONS ALREADY
PASSED
‣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 Answer: 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 Answer: 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 Answer: 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 Answer: b. ACA section 1557 is the correct answer.
a. ACA section 6102 requires owners, operators, and administrators of LTC facilities to
adopt effective compliance.
c. ACA section 6002 requires the establishment of a transparency program, now known
as CMS Open Payments.
‣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. Answer: 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 Answer: 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 Answer: 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 Answer: Creation
Use
Maintenance
Retention
Disposition
‣Standards of Conduct (written P&Ps) Answer: Demonstrate the organization's ethical
attitude and its "enterprise-wide" emphasis on compliance with all applicable laws and
regulations
,‣Code of Conduct: Content Checklist Answer: • 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 Answer: 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 Answer: • 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: Answer: • 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? Answer: 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 Answer:
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?
Answer: 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. Answer: 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 Answer: • 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: Answer: 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: Answer: Standards of conduct and P&Ps
‣For Enforcement and Disciplinary Actions, Policies should include: Answer: 1. non-
compliant consequences
2. employees duty to report non-compliance
3. list parties responsible for appropriate action
QUESTIONS AND SOLUTIONS ALREADY
PASSED
‣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 Answer: 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 Answer: 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 Answer: 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 Answer: b. ACA section 1557 is the correct answer.
a. ACA section 6102 requires owners, operators, and administrators of LTC facilities to
adopt effective compliance.
c. ACA section 6002 requires the establishment of a transparency program, now known
as CMS Open Payments.
‣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. Answer: 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 Answer: 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 Answer: 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 Answer: Creation
Use
Maintenance
Retention
Disposition
‣Standards of Conduct (written P&Ps) Answer: Demonstrate the organization's ethical
attitude and its "enterprise-wide" emphasis on compliance with all applicable laws and
regulations
,‣Code of Conduct: Content Checklist Answer: • 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 Answer: 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 Answer: • 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: Answer: • 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? Answer: 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 Answer:
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?
Answer: 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. Answer: 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 Answer: • 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: Answer: 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: Answer: Standards of conduct and P&Ps
‣For Enforcement and Disciplinary Actions, Policies should include: Answer: 1. non-
compliant consequences
2. employees duty to report non-compliance
3. list parties responsible for appropriate action
