When developing an effective compliance program for an organization, which one of the fol-
lowing obstacles presents the largest threat to its long-term success?
a. employees fear retaliation for reporting violations
b. there is a lack of buy-in from leadership
c. no established lines of communication exist for disseminating information throughout the
organization
d. the organizational culture does not encourage accountability - ANSWER B. there is lack
of buy-in from leadership
Which one of the following laws applies to physician referrals?
a. Stark Law
b. EMTALA
c. HIPAA
d. False Claims Act - ANSWER A. Stark Law
Which one of the following elements of a compliance program identifies deficiencies and
prioritizes risks for an organization?
a. Retrospective Audit
b. Continual evaluation
c. Education
d. Monitoring and auditing process - ANSWER D. Monitoring and auditing process
Two employees at an organization have been involved in an altercation. One of the employ-
ees used offensive and threatening language toward the other employee following a meet-
ing to discuss delayed progress on an ongoing project. What is the best next step for the
compliance professional?
1
,a. Collaborate with human resources to develop a performance improvement plan for both
employees
b. Refer to the code of conduct to enforce appropriate discipline if the organization's con-
duct guidelines have been broken
c. Provide counseling to both employees, and develop and action plan to prevent future dis-
agreements
d. Terminate the aggressor employee for behavior that does not align with the organization's
mission, vision, and values - ANSWER B. Refer to the code of conduct to enforce appro-
priate discipline if the organization's conduct guidelines have been broken.
Which of the following is NOT an aggravating factor in determining a culpability score?
a. Repeat offense
b. Willful ignorance
c. Prompt reporting of a violation
d. Hindering the government during an investigation - ANSWER C. Prompt reporting of a
violation
A provider conducts a follow-up visit for patient to assess a chronic condition and bills for a
comprehensive new-patient office visit. This is an example of:
a. DRG creep
b. upcoding
c. phantom billing
d. unbundling - ANSWER B. updcoding
When an organization develops education for a compliance program and then provides the
appropriate training, all employees should sign a(n) __________ to confirm awareness and
understanding of the standards of conduct and their roles as relates to compliance.
a. attestation
b. code of conduct contract
c. job description
2
,d. performance review - ANSWER A. attestation
The majority of organizations have the compliance officer report to the:
a. chief executive officer (CEO)
b. chief financial officer (CFO)
c. board of directors
d. general counsel - ANSWER C. Board of directors
A compliance professional is sharing information about regulatory changes with all staff
members. In order to ensure that the detailed information is appropriately interpreted, the
compliance professional invites team members to role-play different scenarios. When refer-
encing the three Cs of communication, this strategy aligns best with which component?
a. concise
b. clear
c. creative
d. contextual - ANSWER C. Creative
All of the following are considered protected health information (PHI) EXCEPT:
a. social security number
b. Internet Protocol address
c. device serial number
d. vital signs - ANSWER D. Vital signs
The best reporting mechanism to quickly and effectively address compliance concerns, as
well as ensure a just culture is maintained, is a(n):
a. open-door policy
b. anonymous compliance hotline
c. secure online portal
d. ombudsman - ANSWER A. Open-door policy
3
, Which one of the following strategies is NOT an effective way to measure the success and/or
progress of a compliance program?
a. Tracking complaints for the year and comparing them to prior years
b. Measuring employee knowledge through written tests administered before and after edu-
cational sessions
c. Developing a disciplinary plan for compliance violations
d. Reviewing findings from audits - ANSWER C. Developing a disciplinary plan for compli-
ance violations
Which one of the following concepts is associated with identifying characteristics within a
system that may lead to errors rather than focusing on individual responsibility?
a. Community culture
b. Systematic culture
c. Hierarchy culture
d. Just culture - ANSWER D. Just culture
An organization has reneged on an agreement to acquire another organization that is filing
for bankruptcy due to the high risk involved. Instead, the organization has decided to focus
on hiring additional external staff to develop their patient outreach program to meet de-
mand. This is an example of:
a. avoidance
b. prevention
c. shifting
d. deference - ANSWER A. Avoidance
A list of individuals or entities excluded from participating in Medicare, Medicaid, and all
other federal healthcare programs can be found via the:
a. SDN List
b. OIG Exclusions Database
4
lowing obstacles presents the largest threat to its long-term success?
a. employees fear retaliation for reporting violations
b. there is a lack of buy-in from leadership
c. no established lines of communication exist for disseminating information throughout the
organization
d. the organizational culture does not encourage accountability - ANSWER B. there is lack
of buy-in from leadership
Which one of the following laws applies to physician referrals?
a. Stark Law
b. EMTALA
c. HIPAA
d. False Claims Act - ANSWER A. Stark Law
Which one of the following elements of a compliance program identifies deficiencies and
prioritizes risks for an organization?
a. Retrospective Audit
b. Continual evaluation
c. Education
d. Monitoring and auditing process - ANSWER D. Monitoring and auditing process
Two employees at an organization have been involved in an altercation. One of the employ-
ees used offensive and threatening language toward the other employee following a meet-
ing to discuss delayed progress on an ongoing project. What is the best next step for the
compliance professional?
1
,a. Collaborate with human resources to develop a performance improvement plan for both
employees
b. Refer to the code of conduct to enforce appropriate discipline if the organization's con-
duct guidelines have been broken
c. Provide counseling to both employees, and develop and action plan to prevent future dis-
agreements
d. Terminate the aggressor employee for behavior that does not align with the organization's
mission, vision, and values - ANSWER B. Refer to the code of conduct to enforce appro-
priate discipline if the organization's conduct guidelines have been broken.
Which of the following is NOT an aggravating factor in determining a culpability score?
a. Repeat offense
b. Willful ignorance
c. Prompt reporting of a violation
d. Hindering the government during an investigation - ANSWER C. Prompt reporting of a
violation
A provider conducts a follow-up visit for patient to assess a chronic condition and bills for a
comprehensive new-patient office visit. This is an example of:
a. DRG creep
b. upcoding
c. phantom billing
d. unbundling - ANSWER B. updcoding
When an organization develops education for a compliance program and then provides the
appropriate training, all employees should sign a(n) __________ to confirm awareness and
understanding of the standards of conduct and their roles as relates to compliance.
a. attestation
b. code of conduct contract
c. job description
2
,d. performance review - ANSWER A. attestation
The majority of organizations have the compliance officer report to the:
a. chief executive officer (CEO)
b. chief financial officer (CFO)
c. board of directors
d. general counsel - ANSWER C. Board of directors
A compliance professional is sharing information about regulatory changes with all staff
members. In order to ensure that the detailed information is appropriately interpreted, the
compliance professional invites team members to role-play different scenarios. When refer-
encing the three Cs of communication, this strategy aligns best with which component?
a. concise
b. clear
c. creative
d. contextual - ANSWER C. Creative
All of the following are considered protected health information (PHI) EXCEPT:
a. social security number
b. Internet Protocol address
c. device serial number
d. vital signs - ANSWER D. Vital signs
The best reporting mechanism to quickly and effectively address compliance concerns, as
well as ensure a just culture is maintained, is a(n):
a. open-door policy
b. anonymous compliance hotline
c. secure online portal
d. ombudsman - ANSWER A. Open-door policy
3
, Which one of the following strategies is NOT an effective way to measure the success and/or
progress of a compliance program?
a. Tracking complaints for the year and comparing them to prior years
b. Measuring employee knowledge through written tests administered before and after edu-
cational sessions
c. Developing a disciplinary plan for compliance violations
d. Reviewing findings from audits - ANSWER C. Developing a disciplinary plan for compli-
ance violations
Which one of the following concepts is associated with identifying characteristics within a
system that may lead to errors rather than focusing on individual responsibility?
a. Community culture
b. Systematic culture
c. Hierarchy culture
d. Just culture - ANSWER D. Just culture
An organization has reneged on an agreement to acquire another organization that is filing
for bankruptcy due to the high risk involved. Instead, the organization has decided to focus
on hiring additional external staff to develop their patient outreach program to meet de-
mand. This is an example of:
a. avoidance
b. prevention
c. shifting
d. deference - ANSWER A. Avoidance
A list of individuals or entities excluded from participating in Medicare, Medicaid, and all
other federal healthcare programs can be found via the:
a. SDN List
b. OIG Exclusions Database
4
