new policy regarding timely completion of medical records. Which of the following should be
completed by the department manager to promote compliance with the new policy?
a. Statistically valid sampling audit
b. Monitoring
c. Discovery Audit
d. Retrospective Audit - ANSWER b. Monitoring
For monitoring activities, OIG uses the term regularly to describe the frequency of review.
Which factors should an organization consider when establishing a frequency schedule for
monitoring:
a. Timing of staff job performance evaluations, how often compliance training is provided,
whenever computer upgrades occur, and how many new employees were hired in the target
department.
b. Size of organization, frequency of the activity being monitored, past incidences of miscon-
duct, and current/future investigations.
c. Whether organization used internal or external counsel, timing of the annual financial au-
dit, and number of hotline calls received. - ANSWER b. Size of organization, frequency of
the activity being monitored, past incidences of misconduct, and current/future investiga-
tions.
Ref. Healthcare Compliance Professional's Manual
What is an important first step in creating a compliance team or improving the effectiveness
of an existing one?
a) Making sure senior management has the time and other resources necessary to promote
and carry out compliance improvements
1
,b) Give the CCO the authority to reconcile, standardize, and modify policies where appropri-
ate.
c) Place the organization's CCO on the senior management team
d) None of the above - ANSWER c) Place the organization's CCO on the senior manage-
ment team.
Explanation: This comes straight form Chapter 1 of the Auditing and Monitoring book 2nd
ed. Without being placed on the senior management team, the CCO is unable to effectively
carry out the duties and responsibilities of the office.
An employee has violated the non-retaliation policy, he has spread rumors about employee
who reported him. The compliance professional's first action is to:
a. Create formal hearing for the violator
b. Pursue legal consequence against violator before pursuing work consequences
c. Recommend disciplinary actions against the violator of the non-retaliation policy
d. Dismiss both employees from work - ANSWER c. Recommend disciplinary actions
against the violator of the non-retaliation policy
There is no established template for documenting compliance risks. Each organization
should develop a Risk Assessment that fits its risk profile. The components that are com-
monly used throughout the industry are as follows EXCEPT:
a. Risk Assessment
b. Measuring key risk indicators
c. Identifying key performance indicators
d. Training the leadership of compliance regulation program - ANSWER d. Training the
leadership of compliance regulation program
Ref. ABA CRCM (certified regulatory compliance manager)
2
,After a compliance officer develops a base of knowledge, he/she must begin the art of apply-
ing regulations in a risk management environment. Which of the following is NOT out of a
few things to be kept in mind when determining what to do FIRST?
a. think practically about your role as an advisor, involve all department units in the decision
process rather than making decisions from them
b. calculate the organization's consolidated risk profile
c. make sure you understand the level of risk that the organization will tolerate, so decisions
do not exceed this limit
d. add value by analyzing regulatory requirements for the department units before you pre-
sent proposed/final rules or solutions - ANSWER b. calculate the organization's consoli-
dated risk profile (determine risk tolerance)
Ref. ABA CRCM (certified regulatory compliance manager)
To be effective, compliance risk management professionals must design a framework to en-
sure that management understands the risks and steps to take to mitigate them. The many
roles compliance professionals fill incorporate risk management aspects including:
a. overseeing compliance training targeting higher risk areas
b. tracking regulatory proposals or final rules to understand new risks
c. both a and b - ANSWER c. both a and b
Ref. ABA CRCM (certified regulatory compliance manager)
After an investigation, it was discovered that the organization's reputation is at stake. What
should a Compliance Professional do next?
A. Report the findings to the board
B. Contact legal counsel
C. Advise the CEO and recommend next steps
D. Self-disclose to the OIG - ANSWER B. Contact legal counsel
3
, The compliance officer has completed the non-retaliation policy and it's been officially im-
plemented. The next steps should be:
a. Investigate all reports of violations
b. Post the information publicly in the internet
c. Make the information available to hospital employees
d. Revise it annually - ANSWER c. Make the information available to hospital employees
If during the course of an internal investigation, the compliance officer believes the integrity
of the investigation might be compromised by the continued presence of work force mem-
bers who are the subject of the investigation. In the best interest of the attorney-client privi-
lege, which action would you take?
a. Conduct employee background checks
b. Counsel obtains employee's depositions
c. Destroy documents and other evidence
d. Re-assign employees to other responsibilities until the investigation is completed
e. All of the above - ANSWER d. Re-assign employees to other responsibilities until the
investigation is completed.
Explanation: he/she should recommend that such individuals be temporarily removed from
their current responsibilities until the investigation is completed.
Ref. Healthcare Compliance Professional's Manual
The privacy officer for a hospital has updated the Notice of Privacy Practices/NPP to reflect a
material change because the previous notice did not have a description that individuals have
the right to amend their PHI. The 3rd party review team identified that the NPP did not have
the required information to let individuals know of their right to amend PHI. What's the
BEST course of action to correct deficiency?
A. Make arrangements to mail the new NPP mailed to all patients seen within the last year
at the hospital
B. Make arrangements to have the new NPP distributed to new patients that come to the
hospital
4