Seven Elements of Compliance Flashcards

Which of the Seven Elements requires that an organization have a mechanism to receive and investigate reports of potential misconduct without fear of retaliation?

Answer: Effective lines of communication

Effective lines of communication—the fourth element—include anonymous hotlines and non-retaliation policies to encourage reporting of suspected violations.

A hospital's compliance policies are updated only when regulations change and are not reviewed on any regular schedule. Which best practice is the hospital failing to follow?

Answer: Periodically reviewing and updating written policies

Written policies and procedures must be regularly reviewed and updated to remain current, even in the absence of a regulatory change trigger.

A Compliance Officer delegates all day-to-day compliance functions to department managers and rarely engages directly with the program. This situation violates which element?

Answer: Designating a compliance officer with sufficient authority and resources

The compliance officer must be actively engaged and possess genuine authority; delegating all functions without direct oversight undermines this element.

During a compliance audit, it is discovered that 40% of staff have never completed compliance training. Which of the Seven Elements is most clearly deficient?

Answer: Effective training and education

The third element—effective training and education—requires that all relevant personnel complete compliance training, so a 40% gap signals a major deficiency.

An organization discovers overbilling errors through an internal audit and voluntarily discloses them to the OIG within 60 days. This action best reflects which element?

Answer: Prompt response to detected offenses and corrective action

Voluntary disclosure and corrective action taken promptly after detecting an offense exemplifies the seventh element of an effective compliance program.

Which statement best describes the role of the compliance committee in relation to the compliance officer under the Seven Elements?

Answer: The committee provides oversight and multidisciplinary support to the compliance officer

The compliance committee provides cross-functional governance and support, complementing the compliance officer who manages day-to-day operations.

A company applies progressive discipline (counseling → written warning → termination) consistently regardless of employee seniority. This practice best demonstrates which element?

Answer: Enforcement of standards through disciplinary guidelines applied consistently

Consistent application of disciplinary standards regardless of rank is the hallmark of the sixth element—enforcement through well-publicized and fairly applied guidelines.