HCCA CHC/CHPC COMPLIANCE FINAL
EXAM QUESTIONS AND ANSWERS
LATEST UPDATE THIS YEAR - JUST
RELEASED
1. According to the Federal Sentencing Guidelines for Organizations (FSGO), which of the
following is most critical for a compliance program to be considered ‘effective’?
A. The program must have a specific budget exceeding 1% of total revenue.
B. The Chief Compliance Officer must be an attorney.
C. The organization must exercise due diligence to prevent and detect criminal conduct.
D. The program must guarantee that no violations of law will occur.
Answer: C
Conceptual Explanation: The FSGO emphasizes that the hallmark of an effective program
is the exercise of due diligence to prevent and detect criminal conduct and the promotion of
an organizational culture that encourages ethical conduct.
2. Under the False Claims Act, what does the term ‘scienter’ refer to?
A. Knowledge of falsity, including actual knowledge, deliberate ignorance, or reckless
disregard.
B. The amount of damages the government can seek.
,C. The requirement that the government proves specific intent to defraud.
D. A procedural rule for filing a qui tam lawsuit.
Answer: A
Conceptual Explanation: Scienter in the False Claims Act does not require specific intent
to defraud; it includes actual knowledge, acting in deliberate ignorance of the truth, or
acting in reckless disregard of the truth.
3. Which landmark case established that a board of directors has a duty to ensure a corporate
information and reporting system exists?
A. Upjohn Co. v. United States
B. United States v. Krizek
C. In re Caremark International Inc. Derivative Litigation
D. Thompson v. Western States Medical Center
Answer: C
Conceptual Explanation: The Caremark case established the ‘Caremark Duty,’ which
requires directors to make a good-faith effort to ensure that a compliance and reporting
system exists.
4. The Anti-Kickback Statute is a ‘remediable’ statute, but how does it differ primarily from
the Stark Law?
A. The Anti-Kickback Statute is a civil law only.
, B. The Anti-Kickback Statute requires proof of intent, while the Stark Law is a strict liability
statute.
C. The Stark Law requires proof of intent, whereas the Anti-Kickback Statute does not.
D. The Anti-Kickback Statute only applies to physicians.
Answer: B
Conceptual Explanation: The Anti-Kickback Statute is intent-based (knowing and willful),
while the Stark Law is a strict liability statute, meaning no intent to violate the law is
required.
5. Under HIPAA, when is a Business Associate Agreement (BAA) NOT required?
A. When sharing PHI with a third-party billing company.
B. When sharing PHI with a healthcare provider for treatment purposes.
C. When sharing PHI with a cloud storage provider.
D. When sharing PHI with an external auditor.
Answer: B
Conceptual Explanation: HIPAA specifically excludes disclosures between healthcare
providers for treatment purposes from the BAA requirement.
6. What is the ‘Minimum Necessary’ standard under HIPAA?
A. The requirement to use only the minimum PHI necessary to accomplish the intended
purpose.
EXAM QUESTIONS AND ANSWERS
LATEST UPDATE THIS YEAR - JUST
RELEASED
1. According to the Federal Sentencing Guidelines for Organizations (FSGO), which of the
following is most critical for a compliance program to be considered ‘effective’?
A. The program must have a specific budget exceeding 1% of total revenue.
B. The Chief Compliance Officer must be an attorney.
C. The organization must exercise due diligence to prevent and detect criminal conduct.
D. The program must guarantee that no violations of law will occur.
Answer: C
Conceptual Explanation: The FSGO emphasizes that the hallmark of an effective program
is the exercise of due diligence to prevent and detect criminal conduct and the promotion of
an organizational culture that encourages ethical conduct.
2. Under the False Claims Act, what does the term ‘scienter’ refer to?
A. Knowledge of falsity, including actual knowledge, deliberate ignorance, or reckless
disregard.
B. The amount of damages the government can seek.
,C. The requirement that the government proves specific intent to defraud.
D. A procedural rule for filing a qui tam lawsuit.
Answer: A
Conceptual Explanation: Scienter in the False Claims Act does not require specific intent
to defraud; it includes actual knowledge, acting in deliberate ignorance of the truth, or
acting in reckless disregard of the truth.
3. Which landmark case established that a board of directors has a duty to ensure a corporate
information and reporting system exists?
A. Upjohn Co. v. United States
B. United States v. Krizek
C. In re Caremark International Inc. Derivative Litigation
D. Thompson v. Western States Medical Center
Answer: C
Conceptual Explanation: The Caremark case established the ‘Caremark Duty,’ which
requires directors to make a good-faith effort to ensure that a compliance and reporting
system exists.
4. The Anti-Kickback Statute is a ‘remediable’ statute, but how does it differ primarily from
the Stark Law?
A. The Anti-Kickback Statute is a civil law only.
, B. The Anti-Kickback Statute requires proof of intent, while the Stark Law is a strict liability
statute.
C. The Stark Law requires proof of intent, whereas the Anti-Kickback Statute does not.
D. The Anti-Kickback Statute only applies to physicians.
Answer: B
Conceptual Explanation: The Anti-Kickback Statute is intent-based (knowing and willful),
while the Stark Law is a strict liability statute, meaning no intent to violate the law is
required.
5. Under HIPAA, when is a Business Associate Agreement (BAA) NOT required?
A. When sharing PHI with a third-party billing company.
B. When sharing PHI with a healthcare provider for treatment purposes.
C. When sharing PHI with a cloud storage provider.
D. When sharing PHI with an external auditor.
Answer: B
Conceptual Explanation: HIPAA specifically excludes disclosures between healthcare
providers for treatment purposes from the BAA requirement.
6. What is the ‘Minimum Necessary’ standard under HIPAA?
A. The requirement to use only the minimum PHI necessary to accomplish the intended
purpose.
