Page 1 of 84
ACE HEALTHCARE COMPLIANCE UP -TO -DATE -
PRACTICE (150) QUESTIONS WITH RADICLE
RATIONALES
Exam coverage:
I. Section 1 (Q1–25): OIG compliance program fundamentals,
seven core elements, GCPG, MA ICPG, and Board/CO
oversight requirements.
II. Section 2 (Q26–50): Fraud and abuse laws—False Claims Act
, Stark Law, Anti-Kickback Statute, and DOJ-HHS FCA
Working Group priorities.
III. Section 3 (Q51–75): HIPAA Privacy and Security Rule
compliance, proposed 2025 Security Rule updates, and OCR
enforcement trends.
IV. Section 4 (Q76–100): Corporate Integrity Agreements (CIA),
OIG's 2026 modernized CIA, and DOJ enforcement actions.
V. Section 5 (Q101–125): Compliance program structure and
operations—risk assessments, training, auditing, monitoring,
communication, and billing compliance.
VI. Section 6 (Q126–150): Emerging issues—value-based care
exceptions to Stark/AKS, AI and individualized clinical
determinations, provider directory accuracy, and prior
authorization risks.
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Section 1: Foundations of Healthcare Compliance & OIG
Guidance (Questions 1–25)
Question 1
The U.S. Department of Health and Human Services Office of
Inspector General (OIG) has issued compliance program
guidance that recommends a set of core elements to serve as
the foundation of an effective compliance program. Which of
the following correctly identifies the seven core elements
recommended by the OIG?
A. Written policies and procedures, compliance officer and
committee, training and education, lines of communication,
monitoring and auditing, enforcement of standards, and prompt
response to detected problems
B. Written policies and procedures, financial auditing,
employee background checks, social media monitoring, patient
satisfaction surveys, quality improvement, and risk assessment
C. Compliance officer, legal counsel, external auditors, board of
directors, human resources, information technology, and
clinical leadership
D. Policies and procedures, employee handbooks, code of
conduct, disciplinary guidelines, reporting hotline, risk
management, and quality assurance
CORRECT ANSWER: A
RATIONALE: The OIG compliance program guidance
recommends seven core elements: (1) implementing written
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policies and procedures; (2) designating a compliance officer
and compliance committee; (3) conducting effective training
and education; (4) developing effective lines of communication;
(5) conducting internal monitoring and auditing; (6) enforcing
standards through well-publicized disciplinary guidelines; and
(7) responding promptly to detected problems and undertaking
corrective action.
Question 2
A healthcare organization is developing a compliance program
and wants to ensure it meets OIG expectations. According to
OIG guidance, which of the following is the most accurate
description of the purpose of compliance programs?
A. Compliance programs are primarily designed to maximize
reimbursement from federal healthcare programs
B. Compliance programs are voluntary guidance that helps
organizations monitor adherence to applicable statutes,
regulations, and program requirements
C. Compliance programs are mandatory for all healthcare
providers and require annual certification
D. Compliance programs are only required for organizations
that have been subject to prior enforcement actions
CORRECT ANSWER: B
RATIONALE: OIG's General Compliance Program Guidance
(GCPG) is a reference guide for the healthcare compliance
community that provides information about relevant Federal
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laws, compliance program infrastructure, OIG resources, and
other items useful for understanding healthcare compliance.
The guidance is voluntary and not binding on any individual or
entity.
Question 3
A compliance officer is reviewing the organization's compliance
program structure. According to OIG guidance, which of the
following is a recommended characteristic of an effective
compliance officer role?
A. The compliance officer should report to the Chief Financial
Officer and have responsibility for billing operations
B. The compliance officer should report directly to either the
CEO or the Board, have direct and independent access to the
Board, and possess sufficient stature to interact as an equal
with other senior leaders
C. The compliance officer should be a part-time role filled by the
organization's legal counsel
D. The compliance officer should be primarily responsible for
marketing and business development
CORRECT ANSWER: B
RATIONALE: OIG's updated Corporate Integrity Agreement (CIA)
template requires the Compliance Officer to report directly to
either the CEO or the Board, have direct and independent
access to the Board, and possess "sufficient stature" to interact
ACE HEALTHCARE COMPLIANCE UP -TO -DATE -
PRACTICE (150) QUESTIONS WITH RADICLE
RATIONALES
Exam coverage:
I. Section 1 (Q1–25): OIG compliance program fundamentals,
seven core elements, GCPG, MA ICPG, and Board/CO
oversight requirements.
II. Section 2 (Q26–50): Fraud and abuse laws—False Claims Act
, Stark Law, Anti-Kickback Statute, and DOJ-HHS FCA
Working Group priorities.
III. Section 3 (Q51–75): HIPAA Privacy and Security Rule
compliance, proposed 2025 Security Rule updates, and OCR
enforcement trends.
IV. Section 4 (Q76–100): Corporate Integrity Agreements (CIA),
OIG's 2026 modernized CIA, and DOJ enforcement actions.
V. Section 5 (Q101–125): Compliance program structure and
operations—risk assessments, training, auditing, monitoring,
communication, and billing compliance.
VI. Section 6 (Q126–150): Emerging issues—value-based care
exceptions to Stark/AKS, AI and individualized clinical
determinations, provider directory accuracy, and prior
authorization risks.
, Page 2 of 84
Section 1: Foundations of Healthcare Compliance & OIG
Guidance (Questions 1–25)
Question 1
The U.S. Department of Health and Human Services Office of
Inspector General (OIG) has issued compliance program
guidance that recommends a set of core elements to serve as
the foundation of an effective compliance program. Which of
the following correctly identifies the seven core elements
recommended by the OIG?
A. Written policies and procedures, compliance officer and
committee, training and education, lines of communication,
monitoring and auditing, enforcement of standards, and prompt
response to detected problems
B. Written policies and procedures, financial auditing,
employee background checks, social media monitoring, patient
satisfaction surveys, quality improvement, and risk assessment
C. Compliance officer, legal counsel, external auditors, board of
directors, human resources, information technology, and
clinical leadership
D. Policies and procedures, employee handbooks, code of
conduct, disciplinary guidelines, reporting hotline, risk
management, and quality assurance
CORRECT ANSWER: A
RATIONALE: The OIG compliance program guidance
recommends seven core elements: (1) implementing written
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policies and procedures; (2) designating a compliance officer
and compliance committee; (3) conducting effective training
and education; (4) developing effective lines of communication;
(5) conducting internal monitoring and auditing; (6) enforcing
standards through well-publicized disciplinary guidelines; and
(7) responding promptly to detected problems and undertaking
corrective action.
Question 2
A healthcare organization is developing a compliance program
and wants to ensure it meets OIG expectations. According to
OIG guidance, which of the following is the most accurate
description of the purpose of compliance programs?
A. Compliance programs are primarily designed to maximize
reimbursement from federal healthcare programs
B. Compliance programs are voluntary guidance that helps
organizations monitor adherence to applicable statutes,
regulations, and program requirements
C. Compliance programs are mandatory for all healthcare
providers and require annual certification
D. Compliance programs are only required for organizations
that have been subject to prior enforcement actions
CORRECT ANSWER: B
RATIONALE: OIG's General Compliance Program Guidance
(GCPG) is a reference guide for the healthcare compliance
community that provides information about relevant Federal
, Page 4 of 84
laws, compliance program infrastructure, OIG resources, and
other items useful for understanding healthcare compliance.
The guidance is voluntary and not binding on any individual or
entity.
Question 3
A compliance officer is reviewing the organization's compliance
program structure. According to OIG guidance, which of the
following is a recommended characteristic of an effective
compliance officer role?
A. The compliance officer should report to the Chief Financial
Officer and have responsibility for billing operations
B. The compliance officer should report directly to either the
CEO or the Board, have direct and independent access to the
Board, and possess sufficient stature to interact as an equal
with other senior leaders
C. The compliance officer should be a part-time role filled by the
organization's legal counsel
D. The compliance officer should be primarily responsible for
marketing and business development
CORRECT ANSWER: B
RATIONALE: OIG's updated Corporate Integrity Agreement (CIA)
template requires the Compliance Officer to report directly to
either the CEO or the Board, have direct and independent
access to the Board, and possess "sufficient stature" to interact
