Investigations, Reporting, and Ethics Flashcards
7 cards from real RCC practice questions. Tap to flip, then mark Knew It or Still Learning — missed cards come back until you master them.
Read the first 7 Investigations, Reporting, and Ethics flashcards as text
A compliance officer discovers that a minor policy violation occurred two years ago but was never reported. The employee involved has since left the company. What is the most appropriate action?
Answer: Document the finding, assess residual risk, and determine if disclosure to regulators is required
Even historical violations must be documented, risk-assessed, and evaluated for any applicable reporting obligations before a disposition decision is made.
Which of the following is an example of 'ethical fading' in an organization?
Answer: Employees gradually rationalizing unethical behavior until it seems normal
Ethical fading describes the psychological process by which ethical considerations fade from awareness, leading employees to rationalize misconduct incrementally.
Under the False Claims Act qui tam provisions, what percentage of recovered proceeds can a whistleblower (relator) receive when the government intervenes in the case?
Answer: 15–25%
When the government intervenes in a False Claims Act case, the relator is entitled to receive between 15% and 25% of the proceeds of the action or settlement.
What is the primary role of the Office of Inspector General (OIG) in the context of healthcare compliance?
Answer: Investigating fraud, waste, and abuse in federal healthcare programs
The HHS OIG investigates and combats fraud, waste, and abuse in Medicare, Medicaid, and other federal healthcare programs.
During an investigation, a witness refuses to be interviewed and cites the Fifth Amendment. In an internal corporate investigation, what is the legal significance of this assertion?
Answer: The employee may refuse to cooperate, and the company may draw an adverse inference and take employment action
The Fifth Amendment protects against government compulsion; private employers can draw adverse employment inferences and take action when employees refuse to cooperate with internal investigations.
What is 'integrated disclosure' in the context of SEC reporting obligations?
Answer: The requirement to include risk factors, MD&A, and financial statements in a single annual report
Integrated disclosure refers to the SEC's system where companies provide comprehensive information—including risk factors, MD&A, and financials—in a single Form 10-K rather than separate filings.
A compliance officer learns that a vendor is paying kickbacks to a company's procurement manager. Under the Robinson-Patman Act and general anti-corruption principles, which of the following best describes the company's risk?
Answer: The company may face liability for commercial bribery, and the manager faces criminal exposure
Commercial bribery involving kickbacks exposes both the individual employee and the company to legal liability under various federal and state anti-corruption and commercial bribery laws.