CPCO 2026 Exam Prep: Compliance Officer
Practice Questions with Answer Rationales
Healthcare Law | HIPAA | Fraud & Abuse |
Ethics | Risk Management | Regulatory
Compliance Review
SECTION 1: HEALTHCARE LAW (Questions 1–22)
1. Under the False Claims Act (31 U.S.C. § 3729), what does the term
"knowingly" include?
A) Only actual knowledge that a claim is false
B) Actual knowledge, deliberate ignorance, and reckless disregard of the truth
or falsity of information
C) Only intentional fraud with proven intent to deceive
D) Negligent submission of a false claim
Rationale: The FCA defines "knowingly" to include actual knowledge, deliberate
ignorance, and reckless disregard of the truth or falsity of the information. This
means providers cannot avoid liability by claiming they did not intend to defraud
the government if they acted with reckless disregard.
2. What are the civil penalties under the False Claims Act for each false
claim?
A) Up to $5,000 per claim
B) Civil fines per claim plus up to three times the government's damages
C) Only the amount of the false claim
D) No civil penalties; only criminal penalties apply
,Rationale: The FCA imposes civil fines per claim plus up to three times the
government's damages. The exact fine amount is adjusted annually for inflation.
These penalties are designed to deter fraud and recover losses to federal programs.
3. What is the qui tam provision of the False Claims Act?
A) A provision that allows the government to dismiss a case
B) A provision that allows private individuals to file suit on behalf of the
government
C) A provision that limits damages
D) A provision that requires mandatory arbitration
Rationale: The qui tam (whistleblower) provision of the FCA allows private
individuals (relators) to file suit on behalf of the government against entities that
have defrauded federal programs. The relator may receive a percentage of the
recovery.
4. What is the statute of limitations for a False Claims Act action?
A) 2 years from the date of the violation
B) 6 years from the date of the violation, or 3 years after the government
knows or should have known of the violation (whichever is longer), but no
more than 10 years
C) 10 years from the date of the violation
D) 1 year from the date of the violation
Rationale: The FCA has a two-part statute of limitations: (1) 6 years from the date
of the violation, or (2) 3 years after the government knows or should have known
of the violation, whichever is longer, but no more than 10 years.
5. What is the Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b))?
A) A law that prohibits self-referral for laboratory services only
,B) A law that prohibits knowingly and willfully offering, paying, soliciting, or
receiving remuneration to induce referrals for services covered by federal
healthcare programs
C) A law that sets Medicare payment rates
D) A law that governs HIPAA
Rationale: The Anti-Kickback Statute (AKS) prohibits the exchange of anything
of value to induce or reward referrals for items or services payable by federal
healthcare programs. Violations can result in criminal penalties and exclusion from
federal programs.
6. What is the mental state required for a violation of the Anti-Kickback
Statute?
A) Negligence
B) Knowingly and willfully
C) Strict liability
D) Reckless disregard only
Rationale: The AKS requires that the defendant acted "knowingly and willfully."
This means the government must prove that the defendant knew the conduct was
unlawful. However, OIG has clarified that a person need not have actual
knowledge of the statute or specific intent to violate it.
7. What are safe harbors under the Anti-Kickback Statute?
A) Legal protections for all business arrangements
B) Regulatory provisions that describe payment and business practices that
are not treated as offenses under the statute
C) Exceptions that apply only to hospitals
D) Provisions that apply only to physicians
Rationale: Safe harbors are regulatory provisions that describe various payment
and business practices that, although they potentially implicate the AKS, are not
, treated as offenses under the statute. Safe harbors include protection for certain
discounts/rebates, warranties, employment and services arrangements.
8. What is the Stark Law (Physician Self-Referral Law, 42 U.S.C. § 1395nn)?
A) A law that prohibits all physician referrals
B) A law that prohibits physician self-referral for designated health services
(DHS) payable by Medicare and Medicaid
C) A law that sets Medicare payment rates
D) A law that governs HIPAA
Rationale: The Stark Law prohibits physicians from referring patients to entities
with which they (or immediate family members) have a financial relationship for
designated health services (DHS) payable by Medicare and Medicaid, unless an
exception applies. The Stark Law is a strict liability statute.
9. What is the key difference between the Stark Law and the Anti-Kickback
Statute?
A) The Stark Law applies to all payers; the AKS applies only to Medicare
B) The Stark Law is a strict liability statute; the AKS is an intent-based
statute
C) The Stark Law has criminal penalties; the AKS has only civil penalties
D) The Stark Law applies only to hospitals
Rationale: The Stark Law is a strict liability statute, meaning intent is not required
for a violation. The AKS is an intent-based statute, requiring knowing and willful
conduct. A financial arrangement may satisfy all elements of a Stark exception yet
still violate the AKS.
10. What are designated health services (DHS) under the Stark Law?
A) Only hospital services
Practice Questions with Answer Rationales
Healthcare Law | HIPAA | Fraud & Abuse |
Ethics | Risk Management | Regulatory
Compliance Review
SECTION 1: HEALTHCARE LAW (Questions 1–22)
1. Under the False Claims Act (31 U.S.C. § 3729), what does the term
"knowingly" include?
A) Only actual knowledge that a claim is false
B) Actual knowledge, deliberate ignorance, and reckless disregard of the truth
or falsity of information
C) Only intentional fraud with proven intent to deceive
D) Negligent submission of a false claim
Rationale: The FCA defines "knowingly" to include actual knowledge, deliberate
ignorance, and reckless disregard of the truth or falsity of the information. This
means providers cannot avoid liability by claiming they did not intend to defraud
the government if they acted with reckless disregard.
2. What are the civil penalties under the False Claims Act for each false
claim?
A) Up to $5,000 per claim
B) Civil fines per claim plus up to three times the government's damages
C) Only the amount of the false claim
D) No civil penalties; only criminal penalties apply
,Rationale: The FCA imposes civil fines per claim plus up to three times the
government's damages. The exact fine amount is adjusted annually for inflation.
These penalties are designed to deter fraud and recover losses to federal programs.
3. What is the qui tam provision of the False Claims Act?
A) A provision that allows the government to dismiss a case
B) A provision that allows private individuals to file suit on behalf of the
government
C) A provision that limits damages
D) A provision that requires mandatory arbitration
Rationale: The qui tam (whistleblower) provision of the FCA allows private
individuals (relators) to file suit on behalf of the government against entities that
have defrauded federal programs. The relator may receive a percentage of the
recovery.
4. What is the statute of limitations for a False Claims Act action?
A) 2 years from the date of the violation
B) 6 years from the date of the violation, or 3 years after the government
knows or should have known of the violation (whichever is longer), but no
more than 10 years
C) 10 years from the date of the violation
D) 1 year from the date of the violation
Rationale: The FCA has a two-part statute of limitations: (1) 6 years from the date
of the violation, or (2) 3 years after the government knows or should have known
of the violation, whichever is longer, but no more than 10 years.
5. What is the Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b))?
A) A law that prohibits self-referral for laboratory services only
,B) A law that prohibits knowingly and willfully offering, paying, soliciting, or
receiving remuneration to induce referrals for services covered by federal
healthcare programs
C) A law that sets Medicare payment rates
D) A law that governs HIPAA
Rationale: The Anti-Kickback Statute (AKS) prohibits the exchange of anything
of value to induce or reward referrals for items or services payable by federal
healthcare programs. Violations can result in criminal penalties and exclusion from
federal programs.
6. What is the mental state required for a violation of the Anti-Kickback
Statute?
A) Negligence
B) Knowingly and willfully
C) Strict liability
D) Reckless disregard only
Rationale: The AKS requires that the defendant acted "knowingly and willfully."
This means the government must prove that the defendant knew the conduct was
unlawful. However, OIG has clarified that a person need not have actual
knowledge of the statute or specific intent to violate it.
7. What are safe harbors under the Anti-Kickback Statute?
A) Legal protections for all business arrangements
B) Regulatory provisions that describe payment and business practices that
are not treated as offenses under the statute
C) Exceptions that apply only to hospitals
D) Provisions that apply only to physicians
Rationale: Safe harbors are regulatory provisions that describe various payment
and business practices that, although they potentially implicate the AKS, are not
, treated as offenses under the statute. Safe harbors include protection for certain
discounts/rebates, warranties, employment and services arrangements.
8. What is the Stark Law (Physician Self-Referral Law, 42 U.S.C. § 1395nn)?
A) A law that prohibits all physician referrals
B) A law that prohibits physician self-referral for designated health services
(DHS) payable by Medicare and Medicaid
C) A law that sets Medicare payment rates
D) A law that governs HIPAA
Rationale: The Stark Law prohibits physicians from referring patients to entities
with which they (or immediate family members) have a financial relationship for
designated health services (DHS) payable by Medicare and Medicaid, unless an
exception applies. The Stark Law is a strict liability statute.
9. What is the key difference between the Stark Law and the Anti-Kickback
Statute?
A) The Stark Law applies to all payers; the AKS applies only to Medicare
B) The Stark Law is a strict liability statute; the AKS is an intent-based
statute
C) The Stark Law has criminal penalties; the AKS has only civil penalties
D) The Stark Law applies only to hospitals
Rationale: The Stark Law is a strict liability statute, meaning intent is not required
for a violation. The AKS is an intent-based statute, requiring knowing and willful
conduct. A financial arrangement may satisfy all elements of a Stark exception yet
still violate the AKS.
10. What are designated health services (DHS) under the Stark Law?
A) Only hospital services
