HCCA CHC/CHPC COMPLIANCE
EXAMINATION
2026/2027 Examination
1|Page
,HCCA CHC/CHPC COMPLIANCE EXAMINATION
2026/2027 Examination
Total Questions: 200
Instructions:
• Answer all questions.
• Select the single best answer.
• Each question has four answer choices: A, B, C, and D.
• Select only ONE answer for each question.
SECTION 1: COMPLIANCE PROGRAM ADMINISTRATION AND GOVERNANCE
Questions 1–25
Q1. A newly appointed compliance officer at a mid-sized health system is reviewing the
organization's governance documents. The compliance committee charter has not been updated in
five years and does not define the committee's authority to approve corrective action plans.
According to OIG guidance, which action should the compliance officer prioritize?
A. Request that the board dissolve the committee and assume direct oversight
B. Revise the charter to define roles, responsibilities, meeting frequency, and decision-making
authority
C. Increase committee meeting frequency to monthly without modifying the charter
D. Delegate committee responsibilities to the internal audit department
Correct Answer: B. Revise the charter to define roles, responsibilities, meeting frequency, and
decision-making authority
Rationale: OIG guidance emphasizes that effective compliance committees require formalized
governance structures with clear authority. A charter that defines roles, responsibilities, and
decision-making authority operationalizes oversight requirements. Increasing frequency (C) does not
address undefined authority. Dissolving the committee (A) eliminates multidisciplinary oversight.
Delegating to internal audit (D) creates independence conflicts.
Q2. A compliance officer is evaluating the organization's reporting structure. The CCO currently
reports to the Chief Financial Officer. Based on OIG expectations for independence, what reporting
relationship would best support an effective compliance program?
A. Reporting to the CFO provides adequate independence because finance oversees budgets
B. Reporting to the General Counsel ensures legal privilege protection
C. Reporting to the Board or a designated board committee with direct access to leadership
D. Reporting to the Human Resources Director ensures personnel matters are integrated
Correct Answer: C. Reporting to the Board or a designated board committee with direct access
to leadership
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, Rationale: OIG guidance emphasizes that the compliance officer must have direct and ready
access to the governing body and authority to act independently. Reporting to the CFO (A) creates a
conflict because finance may be involved in compliance issues. Reporting to legal counsel (B) is
insufficient because legal and compliance serve distinct functions. Reporting to HR (D) does not
provide the organizational authority needed.
Q3. A 600-bed teaching hospital is conducting its annual compliance risk assessment. The
compliance officer identifies that the hospital's billing department has experienced high turnover in
the past year, and several new coders have been hired. Which risk factor should the compliance
officer weigh most heavily in prioritizing this area?
A. The hospital's overall patient satisfaction scores
B. The experience level and training status of new billing personnel
C. The number of hospital beds and inpatient volume
D. The age of the hospital's physical infrastructure
Correct Answer: B. The experience level and training status of new billing personnel
Rationale: Risk assessments should consider factors that increase the likelihood of compliance
failures. High turnover and inexperienced staff in billing create elevated risk for coding errors and
improper claims. Patient satisfaction (A) does not directly correlate with billing compliance risk. Bed
count (C) and infrastructure age (D) are not primary compliance risk indicators.
Q4. A compliance officer discovers that the organization's Code of Conduct has not been
reviewed or updated in over six years. Several regulatory changes have occurred during that period.
What is the most appropriate action?
A. Leave the Code unchanged because it was approved by the board
B. Conduct a comprehensive review and update to align with current regulations and organizational
changes
C. Replace the Code entirely with a generic template from a professional association
D. Distribute a memo to staff listing the regulatory changes instead of updating the Code
Correct Answer: B. Conduct a comprehensive review and update to align with current
regulations and organizational changes
Rationale: The Code of Conduct must remain current and aligned with applicable laws and
organizational operations. Regular review ensures relevance and effectiveness. Leaving it unchanged
(A) creates risk that employees follow outdated guidance. Using a generic template (C) loses
organizational specificity. A memo (D) does not substitute for a formal, updated Code.
Q5. A multi-hospital system is developing its annual compliance work plan. The CCO wants to
ensure the plan reflects OIG priorities. Which approach best demonstrates a risk-based work plan?
A. Allocating equal time to every department regardless of risk profile
B. Focusing exclusively on departments with past violations
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, C. Prioritizing audit and monitoring activities based on documented risk assessment findings
D. Scheduling training sessions for all employees at the same time each year
Correct Answer: C. Prioritizing audit and monitoring activities based on documented risk
assessment findings
Rationale: OIG guidance advocates for risk-based allocation of compliance resources. A work
plan should prioritize activities based on documented risk assessments. Equal allocation (A) ignores
risk differences. Focusing only on past violations (B) misses emerging risks. Uniform training timing
(D) does not reflect risk prioritization.
Q6. The compliance committee at a large physician practice has been meeting quarterly but
attendance has declined. Several members send subordinates in their place. What is the most
significant concern with this pattern?
A. Subordinates may not have authority to make committee decisions
B. The committee is meeting too frequently for a physician practice
C. Quarterly meetings are excessive under OIG guidance
D. Committee members should never send representatives
Correct Answer: A. Subordinates may not have authority to make committee decisions
Rationale: Compliance committee members must have authority to make decisions and commit
resources. Sending subordinates without decision-making authority undermines the committee's
effectiveness. Meeting frequency (B, C) is not the primary concern. While representation may be
appropriate in some circumstances, the loss of decision-making authority (D) is the critical issue.
Q7. A compliance officer is assessing whether the organization's compliance program meets the
Federal Sentencing Guidelines' effectiveness criteria. Which factor is most critical to demonstrating
an effective program?
A. The number of policies and procedures in the compliance manual
B. The organization's commitment to due diligence in preventing and detecting misconduct
C. The dollar amount budgeted for compliance activities
D. The frequency of external audits conducted by consultants
Correct Answer: B. The organization's commitment to due diligence in preventing and detecting
misconduct
Rationale: The Federal Sentencing Guidelines focus on whether the organization exercised due
diligence to prevent and detect criminal conduct. Policy volume (A) alone does not demonstrate
effectiveness. Budget amount (C) and external audit frequency (D) are inputs, not outcome
measures of effectiveness.
Q8. A compliance officer learns that a department manager has been discouraging staff from
calling the compliance hotline, telling them to "handle issues internally." What is the compliance
officer's most appropriate first response?
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EXAMINATION
2026/2027 Examination
1|Page
,HCCA CHC/CHPC COMPLIANCE EXAMINATION
2026/2027 Examination
Total Questions: 200
Instructions:
• Answer all questions.
• Select the single best answer.
• Each question has four answer choices: A, B, C, and D.
• Select only ONE answer for each question.
SECTION 1: COMPLIANCE PROGRAM ADMINISTRATION AND GOVERNANCE
Questions 1–25
Q1. A newly appointed compliance officer at a mid-sized health system is reviewing the
organization's governance documents. The compliance committee charter has not been updated in
five years and does not define the committee's authority to approve corrective action plans.
According to OIG guidance, which action should the compliance officer prioritize?
A. Request that the board dissolve the committee and assume direct oversight
B. Revise the charter to define roles, responsibilities, meeting frequency, and decision-making
authority
C. Increase committee meeting frequency to monthly without modifying the charter
D. Delegate committee responsibilities to the internal audit department
Correct Answer: B. Revise the charter to define roles, responsibilities, meeting frequency, and
decision-making authority
Rationale: OIG guidance emphasizes that effective compliance committees require formalized
governance structures with clear authority. A charter that defines roles, responsibilities, and
decision-making authority operationalizes oversight requirements. Increasing frequency (C) does not
address undefined authority. Dissolving the committee (A) eliminates multidisciplinary oversight.
Delegating to internal audit (D) creates independence conflicts.
Q2. A compliance officer is evaluating the organization's reporting structure. The CCO currently
reports to the Chief Financial Officer. Based on OIG expectations for independence, what reporting
relationship would best support an effective compliance program?
A. Reporting to the CFO provides adequate independence because finance oversees budgets
B. Reporting to the General Counsel ensures legal privilege protection
C. Reporting to the Board or a designated board committee with direct access to leadership
D. Reporting to the Human Resources Director ensures personnel matters are integrated
Correct Answer: C. Reporting to the Board or a designated board committee with direct access
to leadership
2|Page
, Rationale: OIG guidance emphasizes that the compliance officer must have direct and ready
access to the governing body and authority to act independently. Reporting to the CFO (A) creates a
conflict because finance may be involved in compliance issues. Reporting to legal counsel (B) is
insufficient because legal and compliance serve distinct functions. Reporting to HR (D) does not
provide the organizational authority needed.
Q3. A 600-bed teaching hospital is conducting its annual compliance risk assessment. The
compliance officer identifies that the hospital's billing department has experienced high turnover in
the past year, and several new coders have been hired. Which risk factor should the compliance
officer weigh most heavily in prioritizing this area?
A. The hospital's overall patient satisfaction scores
B. The experience level and training status of new billing personnel
C. The number of hospital beds and inpatient volume
D. The age of the hospital's physical infrastructure
Correct Answer: B. The experience level and training status of new billing personnel
Rationale: Risk assessments should consider factors that increase the likelihood of compliance
failures. High turnover and inexperienced staff in billing create elevated risk for coding errors and
improper claims. Patient satisfaction (A) does not directly correlate with billing compliance risk. Bed
count (C) and infrastructure age (D) are not primary compliance risk indicators.
Q4. A compliance officer discovers that the organization's Code of Conduct has not been
reviewed or updated in over six years. Several regulatory changes have occurred during that period.
What is the most appropriate action?
A. Leave the Code unchanged because it was approved by the board
B. Conduct a comprehensive review and update to align with current regulations and organizational
changes
C. Replace the Code entirely with a generic template from a professional association
D. Distribute a memo to staff listing the regulatory changes instead of updating the Code
Correct Answer: B. Conduct a comprehensive review and update to align with current
regulations and organizational changes
Rationale: The Code of Conduct must remain current and aligned with applicable laws and
organizational operations. Regular review ensures relevance and effectiveness. Leaving it unchanged
(A) creates risk that employees follow outdated guidance. Using a generic template (C) loses
organizational specificity. A memo (D) does not substitute for a formal, updated Code.
Q5. A multi-hospital system is developing its annual compliance work plan. The CCO wants to
ensure the plan reflects OIG priorities. Which approach best demonstrates a risk-based work plan?
A. Allocating equal time to every department regardless of risk profile
B. Focusing exclusively on departments with past violations
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, C. Prioritizing audit and monitoring activities based on documented risk assessment findings
D. Scheduling training sessions for all employees at the same time each year
Correct Answer: C. Prioritizing audit and monitoring activities based on documented risk
assessment findings
Rationale: OIG guidance advocates for risk-based allocation of compliance resources. A work
plan should prioritize activities based on documented risk assessments. Equal allocation (A) ignores
risk differences. Focusing only on past violations (B) misses emerging risks. Uniform training timing
(D) does not reflect risk prioritization.
Q6. The compliance committee at a large physician practice has been meeting quarterly but
attendance has declined. Several members send subordinates in their place. What is the most
significant concern with this pattern?
A. Subordinates may not have authority to make committee decisions
B. The committee is meeting too frequently for a physician practice
C. Quarterly meetings are excessive under OIG guidance
D. Committee members should never send representatives
Correct Answer: A. Subordinates may not have authority to make committee decisions
Rationale: Compliance committee members must have authority to make decisions and commit
resources. Sending subordinates without decision-making authority undermines the committee's
effectiveness. Meeting frequency (B, C) is not the primary concern. While representation may be
appropriate in some circumstances, the loss of decision-making authority (D) is the critical issue.
Q7. A compliance officer is assessing whether the organization's compliance program meets the
Federal Sentencing Guidelines' effectiveness criteria. Which factor is most critical to demonstrating
an effective program?
A. The number of policies and procedures in the compliance manual
B. The organization's commitment to due diligence in preventing and detecting misconduct
C. The dollar amount budgeted for compliance activities
D. The frequency of external audits conducted by consultants
Correct Answer: B. The organization's commitment to due diligence in preventing and detecting
misconduct
Rationale: The Federal Sentencing Guidelines focus on whether the organization exercised due
diligence to prevent and detect criminal conduct. Policy volume (A) alone does not demonstrate
effectiveness. Budget amount (C) and external audit frequency (D) are inputs, not outcome
measures of effectiveness.
Q8. A compliance officer learns that a department manager has been discouraging staff from
calling the compliance hotline, telling them to "handle issues internally." What is the compliance
officer's most appropriate first response?
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