Certified in Healthcare Compliance (CHC®) Exam Prep
2026 Updated Practice Questions — Comprehensive
Healthcare Compliance Review Detailed Explanations,
Verified Answers, Complete Success Workbook
DOMAIN 1: STANDARDS, POLICIES, AND PROCEDURES (~11%)
Question 1
A healthcare organization is developing its compliance program. According to the
OIG's Seven Elements of an Effective Compliance Program, which element forms
the FOUNDATION upon which all other elements are built?
A) Auditing and monitoring
B) Written policies, procedures, and standards of conduct
C) Designation of a compliance officer
D) Training and education
Rationale: Written policies, procedures, and standards of conduct form
the foundation of an effective compliance program. They establish clear
expectations for behavior, provide guidance on regulatory requirements, and serve
as the reference point for all other compliance activities. Without well-drafted
policies, the other six elements lack direction and consistency.
Question 2
A hospital's compliance officer is drafting a policy on the False Claims Act. Which
of the following is the MOST important element to include in this policy?
A) A list of all Medicare billing codes
B) A clear explanation of what constitutes a false claim and the organization's
prohibition on submitting false claims
C) The name of the organization's legal counsel
D) A list of all government auditors
Rationale: The policy should provide a clear explanation of what constitutes a
false claim and explicitly state the organization's prohibition on submitting false
claims. This ensures that all employees understand the organization's zero-
tolerance stance on fraud and know what behaviors are prohibited.
,Question 3
Under the Federal False Claims Act (FCA), which of the following actions
constitutes a violation?
A) Submitting a claim with a minor billing error that was promptly corrected
B) Knowingly submitting a claim for services that were not provided
C) Submitting a claim with a documentation omission that was unintentional
D) Submitting a claim that was denied by the payer
Rationale: The FCA prohibits knowingly submitting false or fraudulent
claims to government programs. "Knowingly" includes actual knowledge,
deliberate ignorance, or reckless disregard of the truth. A minor billing error
promptly corrected or an unintentional documentation omission does not meet the
"knowing" standard.
Question 4
A compliance officer is drafting a policy on the Anti-Kickback Statute (AKS).
Which of the following should be included as a key component?
A) A list of all permissible referral arrangements
B) An explanation of the AKS prohibition and the available safe harbors
C) A list of all federal healthcare programs
D) A description of the organization's billing process
Rationale: The policy should explain the AKS prohibition and identify
the available safe harbors that protect certain arrangements from prosecution.
Safe harbors specify payment and business practices that are not treated as criminal
offenses under the AKS, even if they could potentially induce referrals.
Question 5
A physician group is reviewing its compensation arrangements. Under the Stark
Law, which of the following is a key requirement for a compensation arrangement
to qualify for an exception?
A) The arrangement must be in writing and signed by both parties
B) The compensation must be consistent with fair market value and not take
,into account the volume or value of referrals
C) The arrangement must be reviewed by Medicare
D) The arrangement must be approved by the state medical board
Rationale: Under the Stark Law, compensation must be consistent with fair
market value and not take into account the volume or value of referrals or
other business generated between the parties. This ensures that financial
relationships do not improperly influence referrals.
Question 6
A hospital is developing a code of conduct. According to best practices, what is the
PRIMARY purpose of a code of conduct?
A) To satisfy a regulatory requirement
B) To communicate the organization's core values and ethical expectations to
all stakeholders
C) To replace all other policies
D) To protect the organization from all liability
Rationale: A code of conduct serves to communicate the organization's core
values and ethical expectations to employees, physicians, vendors, and other
stakeholders. It provides a high-level framework for ethical decision-making and
sets the tone for the compliance program.
Question 7
A compliance officer is reviewing a policy on conflicts of interest. Which of the
following is the MOST important element to include?
A) A prohibition on all gifts
B) A requirement for annual disclosure of financial relationships and a
process for managing identified conflicts
C) A list of all vendors
D) A prohibition on all outside employment
Rationale: An effective conflict-of-interest policy should include a requirement
for annual disclosure of financial relationships and a process for managing
identified conflicts. Not all conflicts can be avoided, but they must be identified,
disclosed, and appropriately managed.
, Question 8
Which of the following is a key requirement for policies and procedures under an
effective compliance program?
A) They should be written in legal terminology
B) They should be written in clear, understandable language and readily
accessible to all employees
C) They should be reviewed only when a violation occurs
D) They should be approved by the board annually
Rationale: Policies should be written in clear, understandable language and
be readily accessible to all employees. Complex legal terminology can confuse
employees and undermine compliance. Policies should be reviewed regularly, not
only when violations occur.
Question 9
A home health agency is developing a compliance policy on Medicare billing.
According to OIG guidance, which of the following should be included?
A) A statement that billing errors are acceptable
B) A clear description of documentation requirements and the prohibition on
upcoding
C) A list of all Medicare beneficiaries
D) A statement that Medicare billing is the billing department's sole responsibility
Rationale: The policy should include a clear description of documentation
requirements and a prohibition on upcoding (billing for a higher level of service
than was actually provided). All clinical and billing staff should understand that
accurate documentation is the foundation of proper billing.
Question 10
A compliance officer is reviewing the organization's vendor contracting process.
Which of the following is a key compliance consideration?
A) The vendor's marketing materials
B) The inclusion of compliance-related clauses, including the right to audit
2026 Updated Practice Questions — Comprehensive
Healthcare Compliance Review Detailed Explanations,
Verified Answers, Complete Success Workbook
DOMAIN 1: STANDARDS, POLICIES, AND PROCEDURES (~11%)
Question 1
A healthcare organization is developing its compliance program. According to the
OIG's Seven Elements of an Effective Compliance Program, which element forms
the FOUNDATION upon which all other elements are built?
A) Auditing and monitoring
B) Written policies, procedures, and standards of conduct
C) Designation of a compliance officer
D) Training and education
Rationale: Written policies, procedures, and standards of conduct form
the foundation of an effective compliance program. They establish clear
expectations for behavior, provide guidance on regulatory requirements, and serve
as the reference point for all other compliance activities. Without well-drafted
policies, the other six elements lack direction and consistency.
Question 2
A hospital's compliance officer is drafting a policy on the False Claims Act. Which
of the following is the MOST important element to include in this policy?
A) A list of all Medicare billing codes
B) A clear explanation of what constitutes a false claim and the organization's
prohibition on submitting false claims
C) The name of the organization's legal counsel
D) A list of all government auditors
Rationale: The policy should provide a clear explanation of what constitutes a
false claim and explicitly state the organization's prohibition on submitting false
claims. This ensures that all employees understand the organization's zero-
tolerance stance on fraud and know what behaviors are prohibited.
,Question 3
Under the Federal False Claims Act (FCA), which of the following actions
constitutes a violation?
A) Submitting a claim with a minor billing error that was promptly corrected
B) Knowingly submitting a claim for services that were not provided
C) Submitting a claim with a documentation omission that was unintentional
D) Submitting a claim that was denied by the payer
Rationale: The FCA prohibits knowingly submitting false or fraudulent
claims to government programs. "Knowingly" includes actual knowledge,
deliberate ignorance, or reckless disregard of the truth. A minor billing error
promptly corrected or an unintentional documentation omission does not meet the
"knowing" standard.
Question 4
A compliance officer is drafting a policy on the Anti-Kickback Statute (AKS).
Which of the following should be included as a key component?
A) A list of all permissible referral arrangements
B) An explanation of the AKS prohibition and the available safe harbors
C) A list of all federal healthcare programs
D) A description of the organization's billing process
Rationale: The policy should explain the AKS prohibition and identify
the available safe harbors that protect certain arrangements from prosecution.
Safe harbors specify payment and business practices that are not treated as criminal
offenses under the AKS, even if they could potentially induce referrals.
Question 5
A physician group is reviewing its compensation arrangements. Under the Stark
Law, which of the following is a key requirement for a compensation arrangement
to qualify for an exception?
A) The arrangement must be in writing and signed by both parties
B) The compensation must be consistent with fair market value and not take
,into account the volume or value of referrals
C) The arrangement must be reviewed by Medicare
D) The arrangement must be approved by the state medical board
Rationale: Under the Stark Law, compensation must be consistent with fair
market value and not take into account the volume or value of referrals or
other business generated between the parties. This ensures that financial
relationships do not improperly influence referrals.
Question 6
A hospital is developing a code of conduct. According to best practices, what is the
PRIMARY purpose of a code of conduct?
A) To satisfy a regulatory requirement
B) To communicate the organization's core values and ethical expectations to
all stakeholders
C) To replace all other policies
D) To protect the organization from all liability
Rationale: A code of conduct serves to communicate the organization's core
values and ethical expectations to employees, physicians, vendors, and other
stakeholders. It provides a high-level framework for ethical decision-making and
sets the tone for the compliance program.
Question 7
A compliance officer is reviewing a policy on conflicts of interest. Which of the
following is the MOST important element to include?
A) A prohibition on all gifts
B) A requirement for annual disclosure of financial relationships and a
process for managing identified conflicts
C) A list of all vendors
D) A prohibition on all outside employment
Rationale: An effective conflict-of-interest policy should include a requirement
for annual disclosure of financial relationships and a process for managing
identified conflicts. Not all conflicts can be avoided, but they must be identified,
disclosed, and appropriately managed.
, Question 8
Which of the following is a key requirement for policies and procedures under an
effective compliance program?
A) They should be written in legal terminology
B) They should be written in clear, understandable language and readily
accessible to all employees
C) They should be reviewed only when a violation occurs
D) They should be approved by the board annually
Rationale: Policies should be written in clear, understandable language and
be readily accessible to all employees. Complex legal terminology can confuse
employees and undermine compliance. Policies should be reviewed regularly, not
only when violations occur.
Question 9
A home health agency is developing a compliance policy on Medicare billing.
According to OIG guidance, which of the following should be included?
A) A statement that billing errors are acceptable
B) A clear description of documentation requirements and the prohibition on
upcoding
C) A list of all Medicare beneficiaries
D) A statement that Medicare billing is the billing department's sole responsibility
Rationale: The policy should include a clear description of documentation
requirements and a prohibition on upcoding (billing for a higher level of service
than was actually provided). All clinical and billing staff should understand that
accurate documentation is the foundation of proper billing.
Question 10
A compliance officer is reviewing the organization's vendor contracting process.
Which of the following is a key compliance consideration?
A) The vendor's marketing materials
B) The inclusion of compliance-related clauses, including the right to audit
