HCCA - CHC Study Questions (Master Flashcards) | Certified in Healthcare Compliance | Complete Questions & Verified Answers
True or False: True
The ACA requires that all providers adopt a compliance
plan as a condition of enrollment with Medicare, ref. ACA section 6102
Medicaid, and Children's Health Insurance Program
(CHIP).
According to HHS-OIG - what are three important 1.Protect our programs
reasons for proper documentation in Compliance? (hint: 2.Protect your patients
protections) 3.Protect the Provider
https://oig.hhs.gov/newsroom/podcasts/2011/heat/heat09-
trans.asp#:~:text=Proper%20documentation%2C%20both%20in%20patients,to
%20protect%20you%20the%20provider.
At which level of the Medicare Part A or Part B appeals c. . third level of appeal
process is the appeal decision by the Office of Medicare
Hearings and Appeals (OMHA)? Frist level - redetermination by Medicare contractor
a. first level of appeal Second level - reconsideration by Independent contractor
b. second level of appeal Third appeal - Administrative Law Judge (ALJ) hearing
c. third level of appeal Fourth appeal - review by Medicare Appeals Council
d. fourth level of appeal Fifth appeal - review in Federal District Court
https://www.hhs.gov/about/agencies/omha/the-appeals-process/index.html
What should CCO be able to do? (What skills should this a. Leadership skills,
person have?) Choose all that apply. c. Skills to design and implement a compliance program, and
a. Leadership skills. d. Be able to anticipate new risk areas.
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.
Which of the following is an absolute necessity in order c. non-retaliation for whistleblowers
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
A Compliance Program with well written policies and d. will not be successful without the proper oversight
procedures:
a. can be successful if consistently reviewed and Regardless of having the best written policies in place that are
maintained reviewed/maintained consistently, and read and disseminated accordingly, will
b. cannot be effective due to the sheer volume presented fail if there is no proper oversight to ensure they are actually being followed and
c. will be effective if read by management understood.
d. will not be successful without the proper oversight
A Compliance Officer can achieve a higher level of b. increasing management involvement.
compliance and ethics engagement by:
a. ensuring leadership reads the policies Compliance is everyone's responsibility, but management involvement is crucial.
b. increasing management involvement They have a direct contact with employees, they know and understand their
c. responding to compliance hotline calls staff's needs and concerns, and have the most influence over employee's actions
d. monitoring the code of conduct 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 c. Balance Budget Act of 1997
permanently excluded from all federal health care
programs if found guilty of a healthcare related fraud a Also known as a BBA "three strikes rule"
third time:
a. Deficit Reduction Act of 2005
b. False Claims Act
c. Balance Budget Act of 1997
d. Social Security Act section 1128d
What section of the ACA prevents discrimination against b. ACA section 1557 is the correct answer.
individuals with limited English proficiency (LEP), and
also prohibits discrimination in healthcare programs and
activities that receive federal funding, based on race, a. ACA section 6102 requires owners, operators, and administrators of LTC
color, national origin, sex, age, or disability. facilities to adopt effective compliance.
a. ACA section 6102 c. ACA section 6002 requires the establishment of a transparency program, now
b. ACA section 1557 known as CMS Open Payments.
c. ACA section 6002
,HCCA - CHC Study Questions (Master Flashcards) | Certified in Healthcare Compliance | Complete Questions & Verified Answers
Which statement is TRUE regarding compliance a. Compliance programs are considered more dangerous if they are developed
programs? but not implemented.
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.
An individual's understanding of the compliance aspects a. annual evaluations
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
Formal statement outlining a plan for a specified subject c. Policy document
area. It usually cites state and/or federal required actions
or standards. CAP - outlines corrective action plan
a. CAP Procedure - describes process/steps under a certain criteria
b. Procedure document Legal standards - mandatory action or rule
c. Policy document
d. Legal standards
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
,HCCA - CHC Study Questions (Master Flashcards) | Certified in Healthcare Compliance | Complete Questions & Verified Answers
When should Code of Conduct be distributed to new Must be distributed within 90 days of hire
employees?
RAT-STATS is: (select all that apply) a. b. d.
a. statistical software to select randomized samples
b. government statistical rule software developed in the The software can be used by other entities other than hospitals, so option "c." is
1970s not precisely accurate, but it is free to use and can be downloaded here:
c. free hospital statistical software https://oig.hhs.gov/compliance/rat-stats/index.asp
d. recommended by OIG, CMS and other agencies to
select random samples
What is the term called for an organization's commitment Code of Conduct
to compliance by management, employees, and
contractors. Statement should summarize ethical
behavior and legal principles under which the healthcare
organization operates?
In the course of an audit, you find that disciplinary b. Get HR involved and recommend the use of progressive discipline policies
actions against certain physicians and high level
executives for non-compliance in the organization have OIG recommends setting forth the degrees of disciplinary actions. Progressive
been unfair and inconsistent with current policies & discipline provides a structure and a set of discipline standards for
procedures. What is your first course of action managers/supervisors to follow to ensure discipline is fair, equitable and
.a. Work with legal counsel to enforce proper disciplinary consistent.
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.
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 For any reporting method to be effective, employees must accept that there will
in this policy: 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 1. non-compliant consequences
should include: 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 OIG recommends: perform background checks, reference checks, and exclusion
to do/perform: list checks
Which two main documents become tools to build Code of Conduct and P&Ps
compliance program?
, HCCA - CHC Study Questions (Master Flashcards) | Certified in Healthcare Compliance | Complete Questions & Verified Answers
You are the new Compliance Officer, hired after ABC c. Rewrite the CoC in plain and concise language tailored to the hospital so
Hospital reorganized and decided that the General employees can use a general guidance.
Counsel should no longer also serve in that role. Upon
review of the Code of Conduct (CoC), you find that it is Explanation:
written using lots of legal jargon. What action do you • CoC should be clear and concise language easy to understand, and should be
take: tailored to specific issues of the organization
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.
What is the term called for an organization's commitment A) Code of Conduct
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
The U.S. Federal Sentencing Commission was b. 1985, 1987, 1991
organized in _____, published its initial set of guidelines
manual in _____ (known today as the US Sentencing The US Sentencing Guidelines (USSG) can be found here:
Guidelines), and included chapter eight of the Federal https://www.ussc.gov/guidelines.
Sentencing Guidelines for Organizations in _____. Chapter 8 - Sentencing of organizations, includes Parts A-F (Part B 2.b.1 outlines
a. 1980, 1987, 1999 the Compliance and Ethics Program)
b. 1985, 1987, 1991
c. 1980, 1985, 1987
d. 1985, 1990, 2001
Expectations have evolved since 1991 when the US b. DOJ ECCP (Evaluation of Corporate Compliance Programs)
Sentencing Guidelines (USSG) were first drafted
highlighting the importance of an effective compliance The ECCP and other related guidance can be downloaded here:
program (and as a condition of probation) to help detect https://www.justice.gov/criminal/criminal-fraud/policy-materials
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)
The most updated DOJ ECCP (Evaluation of Corporate d. all of the above
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
True or False: True
The ACA requires that all providers adopt a compliance
plan as a condition of enrollment with Medicare, ref. ACA section 6102
Medicaid, and Children's Health Insurance Program
(CHIP).
According to HHS-OIG - what are three important 1.Protect our programs
reasons for proper documentation in Compliance? (hint: 2.Protect your patients
protections) 3.Protect the Provider
https://oig.hhs.gov/newsroom/podcasts/2011/heat/heat09-
trans.asp#:~:text=Proper%20documentation%2C%20both%20in%20patients,to
%20protect%20you%20the%20provider.
At which level of the Medicare Part A or Part B appeals c. . third level of appeal
process is the appeal decision by the Office of Medicare
Hearings and Appeals (OMHA)? Frist level - redetermination by Medicare contractor
a. first level of appeal Second level - reconsideration by Independent contractor
b. second level of appeal Third appeal - Administrative Law Judge (ALJ) hearing
c. third level of appeal Fourth appeal - review by Medicare Appeals Council
d. fourth level of appeal Fifth appeal - review in Federal District Court
https://www.hhs.gov/about/agencies/omha/the-appeals-process/index.html
What should CCO be able to do? (What skills should this a. Leadership skills,
person have?) Choose all that apply. c. Skills to design and implement a compliance program, and
a. Leadership skills. d. Be able to anticipate new risk areas.
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.
Which of the following is an absolute necessity in order c. non-retaliation for whistleblowers
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
A Compliance Program with well written policies and d. will not be successful without the proper oversight
procedures:
a. can be successful if consistently reviewed and Regardless of having the best written policies in place that are
maintained reviewed/maintained consistently, and read and disseminated accordingly, will
b. cannot be effective due to the sheer volume presented fail if there is no proper oversight to ensure they are actually being followed and
c. will be effective if read by management understood.
d. will not be successful without the proper oversight
A Compliance Officer can achieve a higher level of b. increasing management involvement.
compliance and ethics engagement by:
a. ensuring leadership reads the policies Compliance is everyone's responsibility, but management involvement is crucial.
b. increasing management involvement They have a direct contact with employees, they know and understand their
c. responding to compliance hotline calls staff's needs and concerns, and have the most influence over employee's actions
d. monitoring the code of conduct 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 c. Balance Budget Act of 1997
permanently excluded from all federal health care
programs if found guilty of a healthcare related fraud a Also known as a BBA "three strikes rule"
third time:
a. Deficit Reduction Act of 2005
b. False Claims Act
c. Balance Budget Act of 1997
d. Social Security Act section 1128d
What section of the ACA prevents discrimination against b. ACA section 1557 is the correct answer.
individuals with limited English proficiency (LEP), and
also prohibits discrimination in healthcare programs and
activities that receive federal funding, based on race, a. ACA section 6102 requires owners, operators, and administrators of LTC
color, national origin, sex, age, or disability. facilities to adopt effective compliance.
a. ACA section 6102 c. ACA section 6002 requires the establishment of a transparency program, now
b. ACA section 1557 known as CMS Open Payments.
c. ACA section 6002
,HCCA - CHC Study Questions (Master Flashcards) | Certified in Healthcare Compliance | Complete Questions & Verified Answers
Which statement is TRUE regarding compliance a. Compliance programs are considered more dangerous if they are developed
programs? but not implemented.
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.
An individual's understanding of the compliance aspects a. annual evaluations
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
Formal statement outlining a plan for a specified subject c. Policy document
area. It usually cites state and/or federal required actions
or standards. CAP - outlines corrective action plan
a. CAP Procedure - describes process/steps under a certain criteria
b. Procedure document Legal standards - mandatory action or rule
c. Policy document
d. Legal standards
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
,HCCA - CHC Study Questions (Master Flashcards) | Certified in Healthcare Compliance | Complete Questions & Verified Answers
When should Code of Conduct be distributed to new Must be distributed within 90 days of hire
employees?
RAT-STATS is: (select all that apply) a. b. d.
a. statistical software to select randomized samples
b. government statistical rule software developed in the The software can be used by other entities other than hospitals, so option "c." is
1970s not precisely accurate, but it is free to use and can be downloaded here:
c. free hospital statistical software https://oig.hhs.gov/compliance/rat-stats/index.asp
d. recommended by OIG, CMS and other agencies to
select random samples
What is the term called for an organization's commitment Code of Conduct
to compliance by management, employees, and
contractors. Statement should summarize ethical
behavior and legal principles under which the healthcare
organization operates?
In the course of an audit, you find that disciplinary b. Get HR involved and recommend the use of progressive discipline policies
actions against certain physicians and high level
executives for non-compliance in the organization have OIG recommends setting forth the degrees of disciplinary actions. Progressive
been unfair and inconsistent with current policies & discipline provides a structure and a set of discipline standards for
procedures. What is your first course of action managers/supervisors to follow to ensure discipline is fair, equitable and
.a. Work with legal counsel to enforce proper disciplinary consistent.
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.
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 For any reporting method to be effective, employees must accept that there will
in this policy: 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 1. non-compliant consequences
should include: 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 OIG recommends: perform background checks, reference checks, and exclusion
to do/perform: list checks
Which two main documents become tools to build Code of Conduct and P&Ps
compliance program?
, HCCA - CHC Study Questions (Master Flashcards) | Certified in Healthcare Compliance | Complete Questions & Verified Answers
You are the new Compliance Officer, hired after ABC c. Rewrite the CoC in plain and concise language tailored to the hospital so
Hospital reorganized and decided that the General employees can use a general guidance.
Counsel should no longer also serve in that role. Upon
review of the Code of Conduct (CoC), you find that it is Explanation:
written using lots of legal jargon. What action do you • CoC should be clear and concise language easy to understand, and should be
take: tailored to specific issues of the organization
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.
What is the term called for an organization's commitment A) Code of Conduct
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
The U.S. Federal Sentencing Commission was b. 1985, 1987, 1991
organized in _____, published its initial set of guidelines
manual in _____ (known today as the US Sentencing The US Sentencing Guidelines (USSG) can be found here:
Guidelines), and included chapter eight of the Federal https://www.ussc.gov/guidelines.
Sentencing Guidelines for Organizations in _____. Chapter 8 - Sentencing of organizations, includes Parts A-F (Part B 2.b.1 outlines
a. 1980, 1987, 1999 the Compliance and Ethics Program)
b. 1985, 1987, 1991
c. 1980, 1985, 1987
d. 1985, 1990, 2001
Expectations have evolved since 1991 when the US b. DOJ ECCP (Evaluation of Corporate Compliance Programs)
Sentencing Guidelines (USSG) were first drafted
highlighting the importance of an effective compliance The ECCP and other related guidance can be downloaded here:
program (and as a condition of probation) to help detect https://www.justice.gov/criminal/criminal-fraud/policy-materials
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)
The most updated DOJ ECCP (Evaluation of Corporate d. all of the above
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
