HCCA CHC AND CHPC CERTIFICATION
COMPREHENSIVE EXAM 2026/2027
QUESTIONS AND ANSWERS LATEST
UPDATE THIS YEAR - JUST RELEASED
1. According to the OIG’s Compliance Program Guidance, what is considered the ultimate
responsibility of the Board of Directors regarding the compliance program?
A. Providing oversight and ensuring the program’s effectiveness
B. Directing the daily operations of the compliance department
C. Conducting all internal investigations personally
D. Drafting the individual clinical policies for the hospital
Answer: A
Conceptual Explanation: The Board of Directors has a fiduciary duty to exercise
reasonable oversight of the compliance program, ensuring it is robust and adequately
resourced, rather than managing day-to-day tasks.
2. Under the Stark Law, which of the following is a key requirement for the ‘Fair Market
Value’ exception regarding physician compensation?
A. The arrangement must be in writing and signed by the parties
B. The compensation must be determined by the volume of referrals
,C. Compensation can exceed market rates if the physician is a top producer
D. The agreement can be oral as long as the payments are consistent
Answer: A
Conceptual Explanation: The Stark Law generally requires that compensation
arrangements be in writing, signed by both parties, and that compensation not be
determined by the volume or value of referrals.
3. A compliance officer discovers a potential overpayment from Medicare. Under the ‘60-Day
Rule,’ when does the 60-day period for reporting and returning the overpayment begin?
A. When the overpayment is identified through reasonable diligence
B. When the overpayment is quantified and confirmed
C. When the overpayment is first suspected
D. When the fiscal intermediary sends a demand letter
Answer: A
Conceptual Explanation: The 60-day clock begins when the overpayment is ‘identified,’
which includes when a person has or should have, through reasonable diligence,
determined that an overpayment was received.
4. Which element is crucial for a whistleblower to file a successful ‘Qui Tam’ lawsuit under
the False Claims Act?
A. The whistleblower must be a current employee
, B. The government must have already been aware of the fraud
C. The lawsuit must be filed in a public newspaper first
D. The whistleblower (relator) must provide original information
Answer: D
Conceptual Explanation: Under the False Claims Act, a relator must generally provide
original information that is not already publicly disclosed or known to the government to
successfully maintain a qui tam action.
5. In the context of the HIPAA Privacy Rule, what does the ‘Minimum Necessary’ standard
require?
A. Limiting PHI access to the amount reasonably necessary to achieve the purpose
B. Using the least amount of PHI for any purpose, including treatment
C. Only allowing physicians to see the full medical record
D. Encrypting all data sent between providers regardless of content
Answer: A
Conceptual Explanation: The Minimum Necessary standard requires covered entities to
take reasonable steps to limit the use or disclosure of PHI to the minimum amount
necessary to accomplish the intended purpose (note: it does not apply to disclosures for
treatment).
COMPREHENSIVE EXAM 2026/2027
QUESTIONS AND ANSWERS LATEST
UPDATE THIS YEAR - JUST RELEASED
1. According to the OIG’s Compliance Program Guidance, what is considered the ultimate
responsibility of the Board of Directors regarding the compliance program?
A. Providing oversight and ensuring the program’s effectiveness
B. Directing the daily operations of the compliance department
C. Conducting all internal investigations personally
D. Drafting the individual clinical policies for the hospital
Answer: A
Conceptual Explanation: The Board of Directors has a fiduciary duty to exercise
reasonable oversight of the compliance program, ensuring it is robust and adequately
resourced, rather than managing day-to-day tasks.
2. Under the Stark Law, which of the following is a key requirement for the ‘Fair Market
Value’ exception regarding physician compensation?
A. The arrangement must be in writing and signed by the parties
B. The compensation must be determined by the volume of referrals
,C. Compensation can exceed market rates if the physician is a top producer
D. The agreement can be oral as long as the payments are consistent
Answer: A
Conceptual Explanation: The Stark Law generally requires that compensation
arrangements be in writing, signed by both parties, and that compensation not be
determined by the volume or value of referrals.
3. A compliance officer discovers a potential overpayment from Medicare. Under the ‘60-Day
Rule,’ when does the 60-day period for reporting and returning the overpayment begin?
A. When the overpayment is identified through reasonable diligence
B. When the overpayment is quantified and confirmed
C. When the overpayment is first suspected
D. When the fiscal intermediary sends a demand letter
Answer: A
Conceptual Explanation: The 60-day clock begins when the overpayment is ‘identified,’
which includes when a person has or should have, through reasonable diligence,
determined that an overpayment was received.
4. Which element is crucial for a whistleblower to file a successful ‘Qui Tam’ lawsuit under
the False Claims Act?
A. The whistleblower must be a current employee
, B. The government must have already been aware of the fraud
C. The lawsuit must be filed in a public newspaper first
D. The whistleblower (relator) must provide original information
Answer: D
Conceptual Explanation: Under the False Claims Act, a relator must generally provide
original information that is not already publicly disclosed or known to the government to
successfully maintain a qui tam action.
5. In the context of the HIPAA Privacy Rule, what does the ‘Minimum Necessary’ standard
require?
A. Limiting PHI access to the amount reasonably necessary to achieve the purpose
B. Using the least amount of PHI for any purpose, including treatment
C. Only allowing physicians to see the full medical record
D. Encrypting all data sent between providers regardless of content
Answer: A
Conceptual Explanation: The Minimum Necessary standard requires covered entities to
take reasonable steps to limit the use or disclosure of PHI to the minimum amount
necessary to accomplish the intended purpose (note: it does not apply to disclosures for
treatment).
