CCT Seven Elements of Compliance 2

Question 1

Which OIG guidance document first established the Seven Elements of an Effective Compliance Program for healthcare organizations?

Accepted Answer

Compliance Program Guidance for Hospitals (1998)

Answer

Federal Sentencing Guidelines (1991)

Answer

Sarbanes-Oxley Act (2002)

Answer

HIPAA Privacy Rule (2003)

Question 2

A compliance officer discovers that employees routinely bypass the anonymous hotline because they fear retaliation. Which of the Seven Elements is most directly compromised?

Accepted Answer

Open lines of communication

Answer

Effective training and education

Answer

Written policies and procedures

Answer

Internal monitoring and auditing

Question 3

Under the Seven Elements, disciplinary guidelines must be publicized to employees primarily to achieve which goal?

Accepted Answer

Deter future violations through awareness of consequences

Answer

Satisfy external audit requirements

Answer

Reduce HR workload by standardizing terminations

Answer

Comply with state employment law

Question 4

An organization responds to a billing audit finding by retraining coders but takes no action for 90 days. Which element of the Seven Elements is being violated?

Accepted Answer

Prompt response to detected offenses

Answer

Enforcement of disciplinary standards

Answer

Written policies and procedures

Answer

Designation of a compliance officer

Question 5

Which scenario best demonstrates effective internal monitoring under the Seven Elements?

Accepted Answer

Running quarterly claims audits comparing billed codes to documentation

Answer

Conducting an annual review of the compliance policy manual

Answer

Requiring department managers to self-certify compliance annually

Answer

Posting the Code of Conduct in the employee break room

Question 6

The Federal Sentencing Guidelines credit organizations with reduced culpability when they have an effective compliance program. Which criterion from those guidelines most directly corresponds to the 'compliance officer' element?

Accepted Answer

High-level personnel must have oversight responsibility for the program

Answer

The organization must self-report violations to authorities

Answer

Employees must complete annual ethics training

Answer

Policies must be reviewed every two years

Question 7

A compliance committee meets only when a crisis occurs. How does this practice undermine the Seven Elements framework?

Accepted Answer

It prevents proactive oversight and ongoing monitoring

Answer

It violates written policy requirements

Answer

It eliminates the need for a compliance officer

Answer

It invalidates training records