CHPC: Study Guide Exam with All
Correct Answers 2026 Updated.
A compliance professional is trying to determine if attorney client privilege should be requested.
The compliance professional's policy should require attorney-client privilege to be established in
which of the following situations:
a. Violation of employee that occurred outside of the organization, and not within the roles and
responsibilities this employee has to the organization.
b. Illegal or unethical business practices by a Chief Executive Officer or other Executive
Management.
c. Overpayment from Medicare of $300,000 that was the result of a billing error. - Answer b.
Illegal or unethical business practices by a Chief Executive Officer or other Executive
Management.
Which of these steps should not be taken when assisting in a code of conduct violation
investigation?
a. Follow the company policy to fairly discipline the involved parties.
b. Document and report your findings.
c. Treat every person involved with dignity and respect.
d. Limit your interview to as few people as possible. - Answer d. Limit your interview to as
few people as possible.
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 members
who are the subject of the investigation. In the best interest of the attorney-client privilege,
which action would you take?
a. Conduct employee background checks.
b. Counsel obtains employee's dispositions.
c. Destroy documents or 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.
Reference: Healthcare Compliance Professional's Manual
Which government department is comprised of thousands of employees who enforce the
nation's federal criminal laws and help develop and implement criminal law policies?
,a. Office of Inspector General (OIG)
b. Centers for Medicare & Medicaid Services (CMS)
c. Healthcare Lawyers Association (HLA)
d. Department of Justice - Answer d. Department of Justice
Explanation: OIG combats fraud, waste, and abuse in Medicare, Medicaid and HHS Programs;
CMS administers the nation's major healthcare programs including Medicare, Medicaid, and
CHIP to eliminate fraud, waste, and abuse; HLA is an edu organization (not a government
department).
Reference: Practice Question from AAPC CPCO Chapter 1.
A potential violation was identified by Compliance, what should be done first?
a. Meet with in-house legal counsel
b. Perform an internal investigation
c. Modify the source of the wrong doing
c. Create an investigative team - Answer b. Perform an internal investigation
Explanation: Validate that there is in fact a violation, then you can proceed to next steps by
stopping wrongdoing and getting legal involvement.
Appropriate progressive discipline policies associated with a compliance program should be:
a. Defined by role
b. Enforced consistently
c. Applied to physicians
d. Reported to the government - Answer b. Enforced consistently
According to the Federal Sentencing Guidelines, which of the following factors could increase
the punishment of an organization?
a. Obstruction of justice
B. Violation of the direct court order
c. Prior history of violations
d. All of the above - Answer d. All of the above
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.
An organization identifies a potential issue when reviewing personal services and management
contracts. Which of the following should the compliance professional consider in analyzing the
issue?
a. Deficit Reduction Act (DRA)
b. Conditions of Participation (CoP)
c. IRS tax-exempt guidelines
d. Anti-Kickback (AKS) Safe Harbors - Answer d. Anti-Kickback (AKS) Safe Harbors
Before a government investigation occurs, what should be reviewed carefully?
a. Government investigator credentials.
b. The search warrant to ensure only identified documents are searched.
c. All of the above.
d. None of the above. - Answer b. The search warrant to ensure only identified documents
are searched.
True or False: Obligations to the Employing Organization, during an investigation, it is important
to keep all identities discreet as much as possible to prevent and to protect the person who is
being investigated and to protect the reputation of the entity. - Answer True (to prevent any
damage).
Organizations have the opportunity to reduce their culpability in accordance with the Federal
Sentencing Guidelines by:
a. Establishing mandatory audits.
b. Effectively dealing with any offense after it has occurred.
c. Developing a code of conduct and educating senior management.
d. Voluntarily disclosing overpayments. - Answer b. Effectively dealing with any offense after
it has occurred.
When non-compliance is substantiated, disciplinary action should be administered:
a. Within 30 days.
b. If intent is proven.
c. In a consistent manner.
d. After completion of corrective action. - Answer c. In a consistent manner.
, True or False: The attorney-client privilege applies to communications made by a client, the
underlying facts of the communication and the legal conclusions involving the facts. - Answer
False. Confidential communication between a client and his or her lawyer for the purpose of
obtaining legal advice or securing legal services. This privilege protects communications of facts,
and not the fact that underlie these communications. For instance, a client provides an attorney
with a host of facts when communicating, but the privilege does not protect these facts from
disclosure - only the communications themselves.
A PI is accused of accepting kickbacks from a sponsor. The allegation is that the study budget
included an item for funds to cover office visits required by the study, but all the office visits
have been billed to insurance as "standard of care." A research compliance professionals should
FIRST notify the:
a. IRB to request initiation of an investigation.
b. Sponsor to inform that funds may have been inappropriately diverted.
c. BOD to request that study-related billing be suspended.
d. Legal office to determine if an investigation should be conducted under privilege. - Answer
d. Legal office to determine if an investigation should be conducted under privilege.
An institutional official receives an OHRP letter requesting an investigation of the creation of an
NIH-funded specimen bank with identifiable private information without IRB approval or
informed consent. The investigation shows that clinical specimens are regularly stored with
medical information from diagnostic tests. Any research performed is done on existing
unidentified specimens. Which of the following is the BEST recommendation?
a. Consult with legal counsel to determine whether OHRP has jurisdiction.
b. Ignore the OHRP letter since the bank was not created for research.
c. Inform OHRP that the bank follows the FDA requirements.
d. Provide OHRP with a summary of the findings and a Corrective Action Plan. - Answer d.
Provide OHRP with a summary of the findings and a Corrective Action Plan.
Note: The HHS-Office for Human Research Protections (OHRP) provides leadership in the
protection of the rights, welfare, and wellbeing of human subjects involved in research
conducted or support by HHS.
Reference: https://www.hhs.gov/ohrp/index.html
Which of the following statements is true regarding Attorney-Client Privilege?
a. It can be applied to employees, former employees, consultants, and public healthcare
providers.
b. It applies to documents that were created prior to an investigation with an attorney.
c. It protects disclosures by a client to an attorney as well as the attorney's advice to the client.
d. It applies to the underlying facts of the communications. - Answer c. It protects disclosures
by a client to an attorney as well as the attorney's advice to the client.
Correct Answers 2026 Updated.
A compliance professional is trying to determine if attorney client privilege should be requested.
The compliance professional's policy should require attorney-client privilege to be established in
which of the following situations:
a. Violation of employee that occurred outside of the organization, and not within the roles and
responsibilities this employee has to the organization.
b. Illegal or unethical business practices by a Chief Executive Officer or other Executive
Management.
c. Overpayment from Medicare of $300,000 that was the result of a billing error. - Answer b.
Illegal or unethical business practices by a Chief Executive Officer or other Executive
Management.
Which of these steps should not be taken when assisting in a code of conduct violation
investigation?
a. Follow the company policy to fairly discipline the involved parties.
b. Document and report your findings.
c. Treat every person involved with dignity and respect.
d. Limit your interview to as few people as possible. - Answer d. Limit your interview to as
few people as possible.
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 members
who are the subject of the investigation. In the best interest of the attorney-client privilege,
which action would you take?
a. Conduct employee background checks.
b. Counsel obtains employee's dispositions.
c. Destroy documents or 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.
Reference: Healthcare Compliance Professional's Manual
Which government department is comprised of thousands of employees who enforce the
nation's federal criminal laws and help develop and implement criminal law policies?
,a. Office of Inspector General (OIG)
b. Centers for Medicare & Medicaid Services (CMS)
c. Healthcare Lawyers Association (HLA)
d. Department of Justice - Answer d. Department of Justice
Explanation: OIG combats fraud, waste, and abuse in Medicare, Medicaid and HHS Programs;
CMS administers the nation's major healthcare programs including Medicare, Medicaid, and
CHIP to eliminate fraud, waste, and abuse; HLA is an edu organization (not a government
department).
Reference: Practice Question from AAPC CPCO Chapter 1.
A potential violation was identified by Compliance, what should be done first?
a. Meet with in-house legal counsel
b. Perform an internal investigation
c. Modify the source of the wrong doing
c. Create an investigative team - Answer b. Perform an internal investigation
Explanation: Validate that there is in fact a violation, then you can proceed to next steps by
stopping wrongdoing and getting legal involvement.
Appropriate progressive discipline policies associated with a compliance program should be:
a. Defined by role
b. Enforced consistently
c. Applied to physicians
d. Reported to the government - Answer b. Enforced consistently
According to the Federal Sentencing Guidelines, which of the following factors could increase
the punishment of an organization?
a. Obstruction of justice
B. Violation of the direct court order
c. Prior history of violations
d. All of the above - Answer d. All of the above
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.
An organization identifies a potential issue when reviewing personal services and management
contracts. Which of the following should the compliance professional consider in analyzing the
issue?
a. Deficit Reduction Act (DRA)
b. Conditions of Participation (CoP)
c. IRS tax-exempt guidelines
d. Anti-Kickback (AKS) Safe Harbors - Answer d. Anti-Kickback (AKS) Safe Harbors
Before a government investigation occurs, what should be reviewed carefully?
a. Government investigator credentials.
b. The search warrant to ensure only identified documents are searched.
c. All of the above.
d. None of the above. - Answer b. The search warrant to ensure only identified documents
are searched.
True or False: Obligations to the Employing Organization, during an investigation, it is important
to keep all identities discreet as much as possible to prevent and to protect the person who is
being investigated and to protect the reputation of the entity. - Answer True (to prevent any
damage).
Organizations have the opportunity to reduce their culpability in accordance with the Federal
Sentencing Guidelines by:
a. Establishing mandatory audits.
b. Effectively dealing with any offense after it has occurred.
c. Developing a code of conduct and educating senior management.
d. Voluntarily disclosing overpayments. - Answer b. Effectively dealing with any offense after
it has occurred.
When non-compliance is substantiated, disciplinary action should be administered:
a. Within 30 days.
b. If intent is proven.
c. In a consistent manner.
d. After completion of corrective action. - Answer c. In a consistent manner.
, True or False: The attorney-client privilege applies to communications made by a client, the
underlying facts of the communication and the legal conclusions involving the facts. - Answer
False. Confidential communication between a client and his or her lawyer for the purpose of
obtaining legal advice or securing legal services. This privilege protects communications of facts,
and not the fact that underlie these communications. For instance, a client provides an attorney
with a host of facts when communicating, but the privilege does not protect these facts from
disclosure - only the communications themselves.
A PI is accused of accepting kickbacks from a sponsor. The allegation is that the study budget
included an item for funds to cover office visits required by the study, but all the office visits
have been billed to insurance as "standard of care." A research compliance professionals should
FIRST notify the:
a. IRB to request initiation of an investigation.
b. Sponsor to inform that funds may have been inappropriately diverted.
c. BOD to request that study-related billing be suspended.
d. Legal office to determine if an investigation should be conducted under privilege. - Answer
d. Legal office to determine if an investigation should be conducted under privilege.
An institutional official receives an OHRP letter requesting an investigation of the creation of an
NIH-funded specimen bank with identifiable private information without IRB approval or
informed consent. The investigation shows that clinical specimens are regularly stored with
medical information from diagnostic tests. Any research performed is done on existing
unidentified specimens. Which of the following is the BEST recommendation?
a. Consult with legal counsel to determine whether OHRP has jurisdiction.
b. Ignore the OHRP letter since the bank was not created for research.
c. Inform OHRP that the bank follows the FDA requirements.
d. Provide OHRP with a summary of the findings and a Corrective Action Plan. - Answer d.
Provide OHRP with a summary of the findings and a Corrective Action Plan.
Note: The HHS-Office for Human Research Protections (OHRP) provides leadership in the
protection of the rights, welfare, and wellbeing of human subjects involved in research
conducted or support by HHS.
Reference: https://www.hhs.gov/ohrp/index.html
Which of the following statements is true regarding Attorney-Client Privilege?
a. It can be applied to employees, former employees, consultants, and public healthcare
providers.
b. It applies to documents that were created prior to an investigation with an attorney.
c. It protects disclosures by a client to an attorney as well as the attorney's advice to the client.
d. It applies to the underlying facts of the communications. - Answer c. It protects disclosures
by a client to an attorney as well as the attorney's advice to the client.
