CHC Compliance Risk Assessments 3 — Questions and Answers
Question 1: Under OIG compliance program guidance, how frequently should a healthcare organization's compliance risk assessment be reviewed?
- Every five years
- Only when a new regulation is enacted
- At least annually or when significant changes occur (Correct answer)
- Every two years as part of an accreditation cycle
Correct answer: At least annually or when significant changes occur
The OIG recommends that risk assessments be conducted at least annually and revisited whenever significant organizational or regulatory changes occur.
Question 2: Which stakeholder group's input is MOST critical to include during a compliance risk assessment interview phase?
- Investors and shareholders
- Front-line staff who perform day-to-day operations (Correct answer)
- Legal counsel only
- Patients and community members
Correct answer: Front-line staff who perform day-to-day operations
Front-line staff have direct knowledge of operational vulnerabilities and process breakdowns that may not be visible to leadership.
Question 3: A compliance officer is rating risks on a 1-5 scale for both likelihood and impact. What does this technique produce?
- A compliance audit report
- A risk score used to rank and prioritize risks (Correct answer)
- A corrective action plan
- A regulatory submission document
Correct answer: A risk score used to rank and prioritize risks
Multiplying likelihood and impact scores produces a composite risk score that allows the compliance team to rank and prioritize mitigation efforts.
Question 4: A healthcare system is expanding into a new state with different Medicaid billing rules. How should the compliance team respond?
- Wait for regulators to flag violations before assessing
- Conduct a targeted risk assessment specific to the new state requirements (Correct answer)
- Apply the existing risk assessment without modifications
- Defer the assessment to the state Medicaid office
Correct answer: Conduct a targeted risk assessment specific to the new state requirements
Geographic or service-line expansions trigger the need for a targeted risk assessment to identify jurisdiction-specific compliance exposures.
Question 5: What is the PRIMARY purpose of benchmarking against OIG Work Plans during a compliance risk assessment?
- To satisfy Joint Commission accreditation requirements
- To identify areas regulators are actively scrutinizing for potential fraud and abuse (Correct answer)
- To replace internal audit findings
- To determine employee compensation benchmarks
Correct answer: To identify areas regulators are actively scrutinizing for potential fraud and abuse
The OIG Work Plan highlights audit and enforcement priorities, helping organizations proactively focus their risk assessments on areas of heightened regulatory interest.
Question 6: During a risk assessment, a compliance analyst finds that a control exists on paper but is not being followed in practice. This gap is BEST described as:
- An inherent risk
- A design deficiency
- An operating effectiveness failure (Correct answer)
- A documentation error
Correct answer: An operating effectiveness failure
A control that exists but is not consistently followed represents an operating effectiveness failure, as the control design is adequate but its execution is not.
Question 7: Which of the following is a key output of a completed healthcare compliance risk assessment?
- A finalized employee disciplinary policy
- A prioritized risk register with recommended mitigation actions (Correct answer)
- A list of patients flagged for audits
- A billing code crosswalk table
Correct answer: A prioritized risk register with recommended mitigation actions
The risk register documents identified risks, their scores, responsible owners, and recommended controls, serving as the central deliverable of the assessment.
CHC Compliance Risk Assessments 3
Under OIG compliance program guidance, how frequently should a healthcare organization's compliance risk assessment be reviewed?