CHC LATEST 2026 TEST PAPER QUESTIONS AND
SOLUTIONS RATED A+
and Security
✔✔THEME - ✔✔must hold employees accountable to raise issues
✔✔Yates Memo - ✔✔- Individual Accountability for Corporate Wrongdoing
- seek accountability from the individuals who perpetrated the wrongdoing (go after the
individual)
* deters future illegal activity
* incentivizes changes in corporate behavior
* ensures that the proper parties are held responsible for their actions
* promotes the public's confidence in the justice system
✔✔CHC EXAM the 7 elements of a compliance plan - ✔✔1. standards and procedures
2. oversight
3. education and training
4. monitoring and auditing
5. reporting
6. enforcement and discipline
7. response and prevention
✔✔Oversight and Accountability - ✔✔- Governing authority - knowledgable about
compliance program w/ reasonable oversight (BOD)
- direct access to the board (not through legal)
- Compliance Program's Infrastructure (buy-in/commitment from these people):
* BOD
* oversight committee
* mangagement
* Physicians
* Compliance Officer
* Staff
- According to the OIG, compliance shouldn't report up to legal but rather straight to the
Board
- Compliance Oversight Committee recommended by the OIG. participate in the risk
assessment process (ask what they see being the risks for the organization). annual
review and evaluation of the compliance program (helpful with prioritizing risks
✔✔Oversight Committee Composition - ✔✔- Chair: Compliance officer
- physicians
- compliance officer
,- coding/billing expert
- senior management/administrator
- legal counsel
✔✔CHC Exam - ✔✔- Compliance officer should NOT terminate employee for fraud
BUT can recommend termination for fraud
✔✔Board of Directors - ✔✔- Bod's duty of care
- don't give responsibility to those who should have known were criminals
✔✔Risk Assessment - ✔✔- 1) identify the risk
-2 Analyze/evaluate the risk
- 3) Prioritize the risk
- 4) mitigate the risk (i.e.: education/training/auditing/monitoring)
- risk assessment is the basis for other elements of the program such as audit and
motoring and education plans. helps determine risk tolerance of an organization
✔✔Standards & Procedures - ✔✔- Code of Conduct
- hotline
- risk assessment methods
- conflict of interest
- privacy
- write in plain language (i.e.: 6th grade language)
✔✔Monitoring & Auditing - ✔✔- audit and monitoring plan is based on risk assessment
and is scalable to the organization's risks and resources
- essential for effectiveness - assists in detecting criminal conduct
- audits - independent/objective (can't have a manager role in what you are auditing. i
can't audit the compliance department)
- monitoring - management tool usually, can be objective but not always
✔✔Reporting - ✔✔- Hotline
- anonymous and confidential to the extent allowed by law
- policy on non-retaliation/non-retribution (remember can't obstruct an investigation)
- address matters in a timely and consistent way
, ✔✔Enforcement/Discipline - ✔✔- take reasonable steps to prevent/deter non-compliant
behavior
- 2 areas assisting in deterrence:
1. incentives (ie: performance reviews/compensation tied to compliance metrics)
2. consistency in enforcement (support from senior management; board)
✔✔Response/Prevention - ✔✔- how to do investigations
- triage by management/HR; attorney; and compliance department
- prevent: if analysis is conducted w/ each issue, patterns and trends can be identified
and thus assisting w/ prevention of the same issues reoccurring
- 2 common areas for remediation: education due to lack of knowledge and
policies/procedures due to unclear expectations and/or not in written format. Corrective
action plan will usually include one of these. CAP should be manager's job
✔✔Compliance Office Role - ✔✔- The Compliance Office should serve as a catalyst to:
* Build ownership and accountability for the program throughout the institution
* Identify vulnerabilities
* Assure that management has responded to the needs and address controls to assure
risks are mitigated
- to get buy in: use motivation; education; participation; and cooperation
✔✔Code of Conduct - ✔✔- Company's ethical attitude
- Emphasis on compliance with all applicable laws and regulations
- Applies to all employees and all representatives
- Tailored to culture, business, corporate identity
- Should be plain and concise
- Have 1 code for all
- all employees should sign attestation annually
- training should be provided on the Code
- Compliance with the Cod should be enforced consistently
- IMPORTANT: discipline for noncompliance should be stated in the Code
SOLUTIONS RATED A+
and Security
✔✔THEME - ✔✔must hold employees accountable to raise issues
✔✔Yates Memo - ✔✔- Individual Accountability for Corporate Wrongdoing
- seek accountability from the individuals who perpetrated the wrongdoing (go after the
individual)
* deters future illegal activity
* incentivizes changes in corporate behavior
* ensures that the proper parties are held responsible for their actions
* promotes the public's confidence in the justice system
✔✔CHC EXAM the 7 elements of a compliance plan - ✔✔1. standards and procedures
2. oversight
3. education and training
4. monitoring and auditing
5. reporting
6. enforcement and discipline
7. response and prevention
✔✔Oversight and Accountability - ✔✔- Governing authority - knowledgable about
compliance program w/ reasonable oversight (BOD)
- direct access to the board (not through legal)
- Compliance Program's Infrastructure (buy-in/commitment from these people):
* BOD
* oversight committee
* mangagement
* Physicians
* Compliance Officer
* Staff
- According to the OIG, compliance shouldn't report up to legal but rather straight to the
Board
- Compliance Oversight Committee recommended by the OIG. participate in the risk
assessment process (ask what they see being the risks for the organization). annual
review and evaluation of the compliance program (helpful with prioritizing risks
✔✔Oversight Committee Composition - ✔✔- Chair: Compliance officer
- physicians
- compliance officer
,- coding/billing expert
- senior management/administrator
- legal counsel
✔✔CHC Exam - ✔✔- Compliance officer should NOT terminate employee for fraud
BUT can recommend termination for fraud
✔✔Board of Directors - ✔✔- Bod's duty of care
- don't give responsibility to those who should have known were criminals
✔✔Risk Assessment - ✔✔- 1) identify the risk
-2 Analyze/evaluate the risk
- 3) Prioritize the risk
- 4) mitigate the risk (i.e.: education/training/auditing/monitoring)
- risk assessment is the basis for other elements of the program such as audit and
motoring and education plans. helps determine risk tolerance of an organization
✔✔Standards & Procedures - ✔✔- Code of Conduct
- hotline
- risk assessment methods
- conflict of interest
- privacy
- write in plain language (i.e.: 6th grade language)
✔✔Monitoring & Auditing - ✔✔- audit and monitoring plan is based on risk assessment
and is scalable to the organization's risks and resources
- essential for effectiveness - assists in detecting criminal conduct
- audits - independent/objective (can't have a manager role in what you are auditing. i
can't audit the compliance department)
- monitoring - management tool usually, can be objective but not always
✔✔Reporting - ✔✔- Hotline
- anonymous and confidential to the extent allowed by law
- policy on non-retaliation/non-retribution (remember can't obstruct an investigation)
- address matters in a timely and consistent way
, ✔✔Enforcement/Discipline - ✔✔- take reasonable steps to prevent/deter non-compliant
behavior
- 2 areas assisting in deterrence:
1. incentives (ie: performance reviews/compensation tied to compliance metrics)
2. consistency in enforcement (support from senior management; board)
✔✔Response/Prevention - ✔✔- how to do investigations
- triage by management/HR; attorney; and compliance department
- prevent: if analysis is conducted w/ each issue, patterns and trends can be identified
and thus assisting w/ prevention of the same issues reoccurring
- 2 common areas for remediation: education due to lack of knowledge and
policies/procedures due to unclear expectations and/or not in written format. Corrective
action plan will usually include one of these. CAP should be manager's job
✔✔Compliance Office Role - ✔✔- The Compliance Office should serve as a catalyst to:
* Build ownership and accountability for the program throughout the institution
* Identify vulnerabilities
* Assure that management has responded to the needs and address controls to assure
risks are mitigated
- to get buy in: use motivation; education; participation; and cooperation
✔✔Code of Conduct - ✔✔- Company's ethical attitude
- Emphasis on compliance with all applicable laws and regulations
- Applies to all employees and all representatives
- Tailored to culture, business, corporate identity
- Should be plain and concise
- Have 1 code for all
- all employees should sign attestation annually
- training should be provided on the Code
- Compliance with the Cod should be enforced consistently
- IMPORTANT: discipline for noncompliance should be stated in the Code
