CHC Compliance Program Administration 3 — Questions and Answers
Question 1: Which document outlines the standards of conduct and ethical expectations for all employees in a healthcare organization's compliance program?
- The corporate integrity agreement
- The code of conduct (Correct answer)
- The compliance work plan
- The audit report
Correct answer: The code of conduct
The code of conduct establishes the organization's ethical standards and behavioral expectations that all employees are required to follow.
Question 2: A compliance officer at a large health system wants to benchmark the organization's compliance program. Which is the MOST credible benchmarking resource?
- Competitor press releases
- HCCA/OIG Healthcare Compliance Program Effectiveness Resource Guide (Correct answer)
- Social media compliance forums
- Industry salary surveys
Correct answer: HCCA/OIG Healthcare Compliance Program Effectiveness Resource Guide
The HCCA/OIG Healthcare Compliance Program Effectiveness Resource Guide provides authoritative benchmarks and practices for evaluating compliance programs.
Question 3: What does 'tone at the top' refer to in the context of healthcare compliance?
- The pitch of the compliance officer's presentation voice
- Leadership's demonstrated commitment to ethical behavior and compliance (Correct answer)
- The hierarchy of compliance reporting lines
- The order in which compliance policies are reviewed
Correct answer: Leadership's demonstrated commitment to ethical behavior and compliance
Tone at the top refers to the culture of integrity set by senior leadership, which significantly influences employee compliance behavior throughout the organization.
Question 4: In a Corporate Integrity Agreement (CIA), what is the role of the Independent Review Organization (IRO)?
- To manage the organization's compliance training program
- To conduct independent reviews of claims and practices as required by the CIA (Correct answer)
- To replace the compliance officer during the CIA period
- To negotiate the terms of the CIA with the OIG
Correct answer: To conduct independent reviews of claims and practices as required by the CIA
An IRO conducts independent, objective reviews of the organization's billing, coding, and other practices as specified in the CIA to verify compliance.
Question 5: Which of the following scenarios BEST illustrates a conflict of interest that a compliance officer should address?
- An employee who takes a vacation day during audit season
- A physician who refers patients to a physical therapy clinic in which they have a financial interest (Correct answer)
- A compliance officer who attends an industry conference
- A nurse who works overtime during a staff shortage
Correct answer: A physician who refers patients to a physical therapy clinic in which they have a financial interest
A physician referring patients to a facility in which they have a financial interest represents a classic conflict of interest and potential Stark Law violation.
Question 6: What is the significance of conducting compliance program audits on a 'risk-stratified' basis?
- It ensures every department is audited equally regardless of risk level
- It allocates audit resources to areas with the highest compliance risk first (Correct answer)
- It eliminates the need for routine audits
- It focuses audits exclusively on billing and coding
Correct answer: It allocates audit resources to areas with the highest compliance risk first
Risk-stratified auditing directs compliance resources toward the areas most likely to have compliance issues, maximizing the program's effectiveness.
Question 7: When developing a compliance training program, which population should receive the MOST specialized and detailed training content?
- Administrative support staff
- High-risk employees whose job functions directly involve regulated activities (Correct answer)
- All employees equally, with identical content
- New hires only, during their first week
Correct answer: High-risk employees whose job functions directly involve regulated activities
Employees in high-risk roles—such as coders, billers, and clinicians—need specialized training tailored to the specific compliance risks associated with their duties.
CHC Compliance Program Administration 3
Which document outlines the standards of conduct and ethical expectations for all employees in a healthcare organization's compliance program?