CCT Seven Elements of Compliance 3 â Questions and Answers
Question 1: Which of the Seven Elements requires that an organization have a mechanism to receive and investigate reports of potential misconduct without fear of retaliation?
- Enforcement of disciplinary standards
- Written policies and procedures
- Effective lines of communication (Correct answer)
- Prompt response to detected offenses
Correct answer: Effective lines of communication
Effective lines of communicationâthe fourth elementâinclude anonymous hotlines and non-retaliation policies to encourage reporting of suspected violations.
Question 2: 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?
- Providing annual compliance training
- Periodically reviewing and updating written policies (Correct answer)
- Publishing disciplinary guidelines to staff
- Auditing claims before submission
Correct 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.
Question 3: 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?
- Designating a compliance officer with sufficient authority and resources (Correct answer)
- Effective training and education
- Internal monitoring and auditing
- Prompt response to detected offenses
Correct 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.
Question 4: 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?
- Effective lines of communication
- Internal monitoring and auditing
- Effective training and education (Correct answer)
- Enforcement of disciplinary standards
Correct answer: Effective training and education
The third elementâeffective training and educationârequires that all relevant personnel complete compliance training, so a 40% gap signals a major deficiency.
Question 5: 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?
- Written policies and procedures
- Internal monitoring and auditing
- Enforcement of disciplinary standards
- Prompt response to detected offenses and corrective action (Correct answer)
Correct 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.
Question 6: Which statement best describes the role of the compliance committee in relation to the compliance officer under the Seven Elements?
- The committee replaces the compliance officer in small organizations
- The committee provides oversight and multidisciplinary support to the compliance officer (Correct answer)
- The committee conducts audits independently of the compliance officer
- The committee is responsible solely for drafting policies
Correct 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.
Question 7: A company applies progressive discipline (counseling â written warning â termination) consistently regardless of employee seniority. This practice best demonstrates which element?
- Open lines of communication
- Internal auditing
- Enforcement of standards through disciplinary guidelines applied consistently (Correct answer)
- Prompt corrective action
Correct answer: Enforcement of standards through disciplinary guidelines applied consistently
Consistent application of disciplinary standards regardless of rank is the hallmark of the sixth elementâenforcement through well-publicized and fairly applied guidelines.
CCT Seven Elements of Compliance 3
Which of the Seven Elements requires that an organization have a mechanism to receive and investigate reports of potential misconduct without fear of retaliation?