CHC LATEST 2026 ACTUAL FINAL EXAM QUESTIONS AND
SOLUTIONS RATED A+
✔✔Common Conflicts of Interest - ✔✔1. use of company information for personal gain
(i.e. insider trading)
2. general financial interests (hidden ownership, bid-rigging, etc.)
3. moonlighting (employment and future job offers)
4. service on board of directors
5. relationships - nepotism
6. relatives/partners as suppliers, vendors, customers, etc.
7. pressure to use manager's relative
8. kickbacks and rebates
9. gifts from vendors, customers, etc.
10. improper use of company assets
✔✔Addressing Conflicts - ✔✔1. federal legislation
2. PhRMA Code on interactions with healthcare professionals
3. guidance for pharmaceutical manufacturers
4. OIG special advisory bulletin - Aug 20, 2002
5. AdvaMed Code of Ethics - 1/1/2004
✔✔Physician Payment Sunshine Act (*) - ✔✔1. drug and device manufacturers must
disclose to government on a quarterly basis anything of value provided to physicians or
teaching hospitals
2. report must describe the form of payment (cash, in-kind items/services, stock, etc.)
3. must describe the nature of the payment/transfer of value (consulting fees,
compensation for services, honoraria, gift, entertainment, food, travel, education,
research, charitable contribution, royalty, etc.) (*)
4. report not to include payments less than $10 (or less than $100/year), product
samples, patient education materials, loan of device for less than 90 days, warranty
replacements, items for use as a patient, discounts/rebates, items used in charity care,
dividends from publically traded company
✔✔Internal Revenue Services (IRS) 501(c)(3) and Conflict of Interest - ✔✔the purpose
of the conflict of interest policy is to protect this tax-exempt organization's interest when
it is contemplating entering into a transaction or arrangement that might benefit the
private interest of an officer or director of the organization or might result in a possible
excess benefit transaction
✔✔Conflict of Interest Policy (*) - ✔✔consists of a set of procedures to follow to avoid
the possibility that those in positions of authority over an organization may receive an
inappropriate benefit
✔✔IRS - Determining Conflict of Interest (*) - ✔✔1. interested person
,2. financial interest (ownership or investment, compensation, negotiating agreement,
business, investment, family)
3. duty to disclose
✔✔PhRMA Code (*) - ✔✔1. voluntary code
2. ethical relationships with health care professionals
3. basic interactions (intended to benefit patients)
4. promotional materials must be accurate (not misleading), make only substantiated
claims, reflect the balance between risks and benefits, and be consistent with all FDA
requirements
5. informational presentations, professional workday, and occasional meals all OK
6. entertainment and recreation items not appropriate
7. OK to provide continuing medical education, scholarships and educational funds, and
educational/practice related items (*)
8. OK - compensation, venue, consultants
9. NOT OK - inducements, token arrangements
✔✔OIG Special Advisory Bulletin (*) - ✔✔1. providers can offer Medicare beneficiaries
inexpensive gifts ($10 each, not greater than $50 annually)
2. can offer more expensive items if it meets a statutory exception
✔✔AdvaMed Code of Ethics - ✔✔1. for device manufacturers
2. voluntary
3. company training and education
4. third party training/education - depend on venue
5. sales/promotional meeting - depend on venue
6. consulting arrangements
7. gifts - only that they can use themselves - less than $100
8. reimbursement OK at market value
9. education grants - can't decide recipient
✔✔National Science Foundation (NSF) Conflict of Interest (*) - ✔✔1. first to require
2. requires investigator to disclose to a responsible representative of the institution a
significant financial interest which is anything of monetary value
✔✔NSF Significant Financial Interest (*) - ✔✔the institution is responsible for ensuring
that the investigator reports all significant financial interest prior to submitting the
proposal to NSF
✔✔FDA Guidance: Financial Disclosure by Clinical Investigators (*) - ✔✔FDA will
evaluate the disclosed conflict and may take various actions, including requiring further
testing with non-conflicted investigators before approving drug/device
✔✔Conflicts of Interest - Organizations Conducting Research (*) - ✔✔1. endanger
human subjects' safety
, 2. jeopardize public's faith
3. reduce the public's willingness to participate
4. inhibit future discoveries
5. focus area in OIG work plan
✔✔Sarbanes-Oxley Act of 2002 (*) - ✔✔1. for publically traded (for profit) companies
2. conflict avoidance
3. auditors hired by audit committee (independent)
4. no consulting by audit company
5. limit partner rotations (must rotate every 5 years) (*)
6. hiring of audit company employees - can't use company for at least one year after
✔✔Public Health Service Regulations - ✔✔1. affects public health service governed
agencies such as National Institutes of Health
2. 42 CFR Part 50, Subpart F
3. investigator must disclose any significant financial interest
✔✔Public Health Service - Significant Financial Interest (*) - ✔✔1. income (salary,
royalties, etc.) which aggregated for investor/spouse/dependent children exceeds
$5,000 in 12 months OR
2. equity interest in excess of $10,000 or 5% ownership
✔✔Discipline (*) - ✔✔1. personnel must comply with the law, policies and guidelines,
code of conduct and compliance program
2. personnel have a duty to report suspected violations (subject to disciplinary action)
3. disciplinary actions reflect severity of noncompliance (up to and including termination)
4. part of job performance evaluation criteria
5. work with HR on written disciplinary standards
6. disciplinary actions are documented
7. discipline enforced consistently across organization
✔✔Stark Law Overview (*) - ✔✔1. prohibits a physician from referring patients to an
entity with which the physician has a financial relationship for certain designated health
services that are reimbursable by Medicare unless an exception applies
2. prohibits entity from billing Medicare or any other person/payor for services
performed as a result of prohibited referral
3. prevent over-utilization and unfair competition
4. preserve federal health care program funds
5. civil law only
6. Medicare only
7. strict liability - doesn't require intent
8. must be physician and an entity in the mix
9. exceptions
10. CMS advisory options (need written contract)
SOLUTIONS RATED A+
✔✔Common Conflicts of Interest - ✔✔1. use of company information for personal gain
(i.e. insider trading)
2. general financial interests (hidden ownership, bid-rigging, etc.)
3. moonlighting (employment and future job offers)
4. service on board of directors
5. relationships - nepotism
6. relatives/partners as suppliers, vendors, customers, etc.
7. pressure to use manager's relative
8. kickbacks and rebates
9. gifts from vendors, customers, etc.
10. improper use of company assets
✔✔Addressing Conflicts - ✔✔1. federal legislation
2. PhRMA Code on interactions with healthcare professionals
3. guidance for pharmaceutical manufacturers
4. OIG special advisory bulletin - Aug 20, 2002
5. AdvaMed Code of Ethics - 1/1/2004
✔✔Physician Payment Sunshine Act (*) - ✔✔1. drug and device manufacturers must
disclose to government on a quarterly basis anything of value provided to physicians or
teaching hospitals
2. report must describe the form of payment (cash, in-kind items/services, stock, etc.)
3. must describe the nature of the payment/transfer of value (consulting fees,
compensation for services, honoraria, gift, entertainment, food, travel, education,
research, charitable contribution, royalty, etc.) (*)
4. report not to include payments less than $10 (or less than $100/year), product
samples, patient education materials, loan of device for less than 90 days, warranty
replacements, items for use as a patient, discounts/rebates, items used in charity care,
dividends from publically traded company
✔✔Internal Revenue Services (IRS) 501(c)(3) and Conflict of Interest - ✔✔the purpose
of the conflict of interest policy is to protect this tax-exempt organization's interest when
it is contemplating entering into a transaction or arrangement that might benefit the
private interest of an officer or director of the organization or might result in a possible
excess benefit transaction
✔✔Conflict of Interest Policy (*) - ✔✔consists of a set of procedures to follow to avoid
the possibility that those in positions of authority over an organization may receive an
inappropriate benefit
✔✔IRS - Determining Conflict of Interest (*) - ✔✔1. interested person
,2. financial interest (ownership or investment, compensation, negotiating agreement,
business, investment, family)
3. duty to disclose
✔✔PhRMA Code (*) - ✔✔1. voluntary code
2. ethical relationships with health care professionals
3. basic interactions (intended to benefit patients)
4. promotional materials must be accurate (not misleading), make only substantiated
claims, reflect the balance between risks and benefits, and be consistent with all FDA
requirements
5. informational presentations, professional workday, and occasional meals all OK
6. entertainment and recreation items not appropriate
7. OK to provide continuing medical education, scholarships and educational funds, and
educational/practice related items (*)
8. OK - compensation, venue, consultants
9. NOT OK - inducements, token arrangements
✔✔OIG Special Advisory Bulletin (*) - ✔✔1. providers can offer Medicare beneficiaries
inexpensive gifts ($10 each, not greater than $50 annually)
2. can offer more expensive items if it meets a statutory exception
✔✔AdvaMed Code of Ethics - ✔✔1. for device manufacturers
2. voluntary
3. company training and education
4. third party training/education - depend on venue
5. sales/promotional meeting - depend on venue
6. consulting arrangements
7. gifts - only that they can use themselves - less than $100
8. reimbursement OK at market value
9. education grants - can't decide recipient
✔✔National Science Foundation (NSF) Conflict of Interest (*) - ✔✔1. first to require
2. requires investigator to disclose to a responsible representative of the institution a
significant financial interest which is anything of monetary value
✔✔NSF Significant Financial Interest (*) - ✔✔the institution is responsible for ensuring
that the investigator reports all significant financial interest prior to submitting the
proposal to NSF
✔✔FDA Guidance: Financial Disclosure by Clinical Investigators (*) - ✔✔FDA will
evaluate the disclosed conflict and may take various actions, including requiring further
testing with non-conflicted investigators before approving drug/device
✔✔Conflicts of Interest - Organizations Conducting Research (*) - ✔✔1. endanger
human subjects' safety
, 2. jeopardize public's faith
3. reduce the public's willingness to participate
4. inhibit future discoveries
5. focus area in OIG work plan
✔✔Sarbanes-Oxley Act of 2002 (*) - ✔✔1. for publically traded (for profit) companies
2. conflict avoidance
3. auditors hired by audit committee (independent)
4. no consulting by audit company
5. limit partner rotations (must rotate every 5 years) (*)
6. hiring of audit company employees - can't use company for at least one year after
✔✔Public Health Service Regulations - ✔✔1. affects public health service governed
agencies such as National Institutes of Health
2. 42 CFR Part 50, Subpart F
3. investigator must disclose any significant financial interest
✔✔Public Health Service - Significant Financial Interest (*) - ✔✔1. income (salary,
royalties, etc.) which aggregated for investor/spouse/dependent children exceeds
$5,000 in 12 months OR
2. equity interest in excess of $10,000 or 5% ownership
✔✔Discipline (*) - ✔✔1. personnel must comply with the law, policies and guidelines,
code of conduct and compliance program
2. personnel have a duty to report suspected violations (subject to disciplinary action)
3. disciplinary actions reflect severity of noncompliance (up to and including termination)
4. part of job performance evaluation criteria
5. work with HR on written disciplinary standards
6. disciplinary actions are documented
7. discipline enforced consistently across organization
✔✔Stark Law Overview (*) - ✔✔1. prohibits a physician from referring patients to an
entity with which the physician has a financial relationship for certain designated health
services that are reimbursable by Medicare unless an exception applies
2. prohibits entity from billing Medicare or any other person/payor for services
performed as a result of prohibited referral
3. prevent over-utilization and unfair competition
4. preserve federal health care program funds
5. civil law only
6. Medicare only
7. strict liability - doesn't require intent
8. must be physician and an entity in the mix
9. exceptions
10. CMS advisory options (need written contract)
