CHC Standards, Policies, and Procedures 3 — Questions and Answers
Question 1: Which of the following BEST describes the purpose of a code of conduct in a healthcare compliance program?
- To replace detailed policies and procedures in small organizations
- To articulate the organization's ethical principles and behavioral expectations for all personnel (Correct answer)
- To serve as a legally binding contract between employees and regulators
- To document financial penalties associated with compliance failures
Correct answer: To articulate the organization's ethical principles and behavioral expectations for all personnel
A code of conduct communicates the organization's core values and sets behavioral expectations as the ethical foundation of the compliance program.
Question 2: Under the Stark Law, which of the following financial relationships between a physician and a hospital would require a written exception?
- A physician treating Medicare patients at a non-related hospital
- A physician who owns stock in the hospital and refers Medicare patients there (Correct answer)
- A physician employed full-time by the hospital under a salary arrangement
- A physician providing pro bono care at a community health fair
Correct answer: A physician who owns stock in the hospital and refers Medicare patients there
Stark Law prohibits physician self-referrals unless a specific exception applies; physician ownership with referrals to that entity requires careful structuring under an applicable exception.
Question 3: A compliance officer discovers that a departmental procedure contradicts a newly updated organization-wide policy. The BEST course of action is to:
- Allow departments to follow whichever document they prefer
- Immediately suspend the department's operations until resolved
- Escalate to department leadership and legal to align the procedure with the policy (Correct answer)
- Archive both documents and draft an entirely new policy from scratch
Correct answer: Escalate to department leadership and legal to align the procedure with the policy
Conflicting documents create compliance risk; the compliance officer should work with department leadership and legal counsel to reconcile the procedure with the governing policy.
Question 4: The False Claims Act (FCA) imposes liability on healthcare organizations that submit claims that are:
- Late but accurate
- Knowingly false or fraudulent to government payers (Correct answer)
- Denied and subsequently appealed
- Coded using outdated but not incorrect billing codes
Correct answer: Knowingly false or fraudulent to government payers
The FCA targets knowingly false, fraudulent, or recklessly disregarded claims submitted to federal healthcare programs.
Question 5: Which document type provides the authoritative basis (the 'why') that all related procedures and work instructions should reference?
- Work instruction
- Standard operating procedure
- Policy (Correct answer)
- Audit checklist
Correct answer: Policy
A policy establishes the organizational rule or principle that gives authority and rationale to the procedures and work instructions that implement it.
Question 6: According to CMS Conditions of Participation, hospitals must have policies governing patient rights. Which of the following is a required patient right that must be reflected in those policies?
- The right to choose the hospital's attending physician from any state
- The right to receive care in a safe setting and to be free from abuse (Correct answer)
- The right to waive all billing statements upon request
- The right to approve all clinical decisions made by their care team
Correct answer: The right to receive care in a safe setting and to be free from abuse
CMS Conditions of Participation require hospitals to have policies ensuring patients receive care in a safe environment, free from abuse, neglect, and exploitation.
Question 7: A healthcare organization's policy requires dual authorization for wire transfers over $100,000. This control is designed primarily to prevent:
- Coding and billing errors
- Fraudulent financial transactions and embezzlement (Correct answer)
- HIPAA privacy breaches
- Violations of the Stark Law
Correct answer: Fraudulent financial transactions and embezzlement
Dual authorization controls on large financial transactions are a segregation-of-duties safeguard against internal fraud and embezzlement.
CHC Standards, Policies, and Procedures 3
Which of the following BEST describes the purpose of a code of conduct in a healthcare compliance program?