CHC - Certified in Healthcare Compliance Remedial Measures and Discipline Questions and Answers

Question 1

A high-performing, senior-level manager with a long tenure at a hospital is found to have committed a clear violation of the organization's conflict of interest policy. When determining the appropriate disciplinary action, which principle is MOST critical for the compliance officer to uphold?

Accepted Answer

The disciplinary action must be consistent with the organization's well-publicized standards for such a violation.

Answer

According to OIG guidance, a fundamental element of an effective compliance program is the consistent and vigorous enforcement of disciplinary standards for all employees, regardless of their position, tenure, or performance history. [13, 19] Applying standards fairly and equally reinforces the organization's commitment to compliance and ensures that no one is perceived as being above the rules.

Question 2

What is the primary purpose of developing a Corrective Action Plan (CAP) after an internal investigation substantiates a compliance deficiency?

Accepted Answer

To identify and remedy the root cause of the non-compliance to prevent its recurrence.

Answer

A Corrective Action Plan (CAP) is a forward-looking tool designed to address the systemic issues that led to a compliance failure. [8, 14] Its main goal is to identify the root cause—such as a flawed process, inadequate training, or technical gap—and implement specific, measurable steps to fix the problem and prevent it from happening again. [6, 14]

Question 3

A hospital's internal audit identifies a systemic billing software error that resulted in significant overpayments from Medicare over the past two years. After quantifying the amount, what is the organization's primary obligation under the Patient Protection and Affordable Care Act (ACA)?

Accepted Answer

To report and return the overpayment within 60 days of its identification.

Answer

The ACA established the "60-day rule," which requires a person who has received an overpayment from a federal healthcare program to report and return it within 60 days of the date the overpayment was identified. [3, 27, 30] Failure to do so can convert the overpayment into a potential violation of the False Claims Act. [27, 29]

Question 4

Which of the following actions BEST demonstrates an organization's commitment to its non-retaliation policy for employees who report compliance concerns?

Accepted Answer

Consistently communicating the policy and taking swift, visible action against any perceived retaliation.

Answer

An effective non-retaliation program relies on building trust. [9] This is best achieved through continuous communication of the policy's protections, coupled with visible and consistent enforcement when potential retaliation is identified. [4, 5, 21] This demonstrates to employees that leadership is serious about protecting those who speak up in good faith.

Question 5

An investigation reveals that a new medical assistant improperly accessed a celebrity patient's electronic health record out of curiosity. The medical assistant claims they were unaware this was a violation. Which remedial measure would BEST address the root cause of this HIPAA violation?

Accepted Answer

Implementing role-based access controls and providing targeted retraining for all staff on 'minimum necessary' access.

Answer

Effective remediation focuses on fixing the underlying cause to prevent future incidents. [17, 22] The root cause here is twofold: a lack of specific knowledge (a training gap) and potentially overly broad system permissions (a technical gap). Implementing role-based access to enforce the 'minimum necessary' principle and providing specific, targeted retraining on patient privacy and appropriate data access addresses both systemic issues. [12, 26]

CHC - Certified in Healthcare Compliance Practice Test

CHC - Certified in Healthcare Compliance Practice Test

CHC - Certified in Healthcare Compliance Remedial Measures and Discipline Questions and Answers