CHC Practice Questions (2026) — Free Sample Questions with Answers

Answer: D

Approve the gift cards because Stark covers only physician referrals.: Stark's limits do not end the analysis; the AKS covers non-physician referral sources too.

Approve the gift cards if each stays below the nominal value limit.: The nominal-value concept comes from the beneficiary inducement CMP, which concerns patients, not referral sources.

Approve the gift cards if the hospital's policy also allows them.: Another entity's gift policy cannot make remuneration to referral sources lawful.

Prohibit the gift cards as possible kickbacks under the AKS.: Correct. Stark covers physician referrals, but the AKS applies to anyone who offers remuneration to induce referrals of federal program business; cash-equivalent gifts to referral sources are a classic kickback risk.

Stark is limited to physician referrals; the AKS reaches remuneration to any referral source for federal program business.

Answer: A

Pay above fair market value may be seen as payment for referrals.: Correct. Compensation above fair market value for a referral source fails a core element of the Stark exceptions and AKS safe harbors and suggests the excess rewards referrals; missing time records compound the problem.

Missing time records leave no proof that the duties are performed.: A real gap, but secondary: even with time records, pay above fair market value to a referral source remains the core problem.

The agreement needs an OIG advisory opinion before it can begin.: Advisory opinions are voluntary; they are not a precondition for a directorship agreement.

High referral volume bars the hospital from paying the cardiologist at all.: Referral sources may hold paid arrangements if pay is fair market value for needed services and does not reflect referrals; volume alone is not a bar.

For physician arrangements, compensation must be fair market value for services actually provided and not reflect referrals, under both Stark and the AKS.

Answer: B

Accept the reimbursement department's statement that it is correct.: The department that prepared the report is reviewing its own work.

Engage, through counsel, an outside cost report expert to review it.: Correct. The issue requires technical expertise the staff lack, and the preparing department is not independent; engaging an expert through counsel adds skill and helps preserve privilege.

Train compliance staff on cost reports before starting any review.: Training is a long-term fix and would delay a timely review.

Report the allegation to the MAC as a possible cost report error.: Reporting before the facts are reviewed is premature.

When an issue exceeds in-house expertise, engage independent outside experts, ideally through counsel.

Answer: B

Add a charter clause allowing the committee to veto investigations.: Giving management a veto over investigations undermines independence.

Amend the charter to define the committee as supporting compliance.: Correct. GCPG notes that committee members sometimes mistakenly see their role as overseeing the compliance officer rather than supporting the program; a defined charter fixes the root cause.

Disband the committee and rely only on the board for oversight.: The committee has an important operational role; disbanding it is disproportionate.

Have the CEO chair the committee to resolve such disputes.: The compliance officer should chair the committee; CEO chairing does not define its role.

The compliance committee supports the compliance officer and the program; its charter should say so, and it should not control investigations.

Answer: A

Report the allegation promptly to the board compliance committee chair.: Correct. When the CEO is implicated, the compliance officer uses direct board access so that an independent investigation can be directed by the board, without waiting for a scheduled meeting.

Tell the CEO about the allegation as a courtesy before anyone else.: Alerting the implicated executive first compromises independence and the investigation.

Ask the general counsel to decide whether the board should be told.: The general counsel reports to the CEO; the compliance officer has direct board access for this reason.

Gather evidence quietly and present it at the next board meeting.: Waiting weeks on a credible allegation involving the CEO delays independent oversight.

When senior leadership is implicated, use the compliance officer's direct access to the board promptly.

Answer: A

Quantify affected claims with counsel and weigh disclosure under the OIG SDP.: Correct. Items and services furnished by an excluded person are not payable even when billed by the hospital; the next step is to quantify the overpayment and, with counsel, decide on disclosure through the OIG SDP.

Disclose the employment through the CMS Self-Referral Disclosure Protocol.: The CMS SRDP is for Stark-only issues; employing an excluded person is an OIG matter.

Refund only claims billed under the therapist's own provider number.: Services the therapist furnished are not payable even when billed under the hospital's number.

Record the removal in the HR file and close the compliance matter.: Removal stops future harm but leaves the overpayment and CMP exposure unaddressed.

After removing an excluded person, quantify the affected claims and decide on disclosure through the OIG SDP with counsel.

Answer: D

Publish compliance newsletters more often across the system.: More newsletters are acceptable but do not change what employees hear from their managers.

Add a compliance pledge to the annual training module.: A pledge in training is easy to complete and does not change daily messages.

Post the CEO's compliance letter on the employee intranet.: Tone at the top is already present; the gap is tone at the middle.

Have managers deliver and model compliance messages locally.: Correct. The gap is at the middle-management level; equipping managers to deliver and model compliance messages, and holding them to it, reaches employees where culture is set day to day.

Culture is shaped by immediate managers; build compliance into what managers say and do.

Answer: A

Investigate possible overpayments promptly; return identified ones in 60 days.: Correct. An identified Medicare overpayment must be reported and returned within 60 days (or by the cost report due date, if later), and a timely, good-faith investigation is expected when a possible overpayment is found.

Return every credit balance within 60 days of posting, overpayment or not.: Not every credit balance is an overpayment; the clock runs from identification, not from posting.

Return overpayments only when a payer asks for them in an audit.: The obligation is affirmative; waiting for a payer request can create reverse false claim liability.

Report overpayments within 30 days and return them within 90 days.: These are invented timeframes; the rule is report and return within 60 days of identification.

Overpayments: investigate promptly in good faith, then report and return within 60 days of identification.

Answer: C

Raise the passing score on the current definition-based test.: A higher score on recall questions still does not test whether staff recognize reportable conduct.

Require employees to retake the current test until they score perfectly.: Repeating the same recall test reinforces memorization, not judgment.

Rewrite the test with realistic scenarios that require reporting judgment.: Correct. Definition questions show recall, not whether staff can recognize and act on a real situation; scenario questions measure the judgment that the hotline data show is missing.

Drop the post-test, since every employee already passes it.: Removing evaluation leaves no measure of understanding at all.

Assess understanding with scenario-based questions that test the decisions employees actually face.

Answer: D

Close the matter because the anonymous caller cannot give more details.: A specific allegation can be investigated without the caller; closing it fails the duty to respond.

Ask the hotline vendor to disclose the caller's identity to compliance.: Breaking the anonymity the system promised would undermine every future report.

Tell the nurse manager about the allegation and request a written reply.: Alerting the subject before evidence is gathered risks altered records and hints at the source.

Review training records and interview staff broadly, naming no source.: Correct. Starting with records and using broad, routine-looking interviews lets the allegation be tested while protecting the reporter's anonymity as far as practical.

Protect anonymity by investigating through records and broad interviews, and do not tip off the subject first.

Answer: D

Wait for all appeal decisions before taking any internal action.: Appeals concern the denied claims; they do not suspend the duty to look into similar unreviewed claims.

Refund all inpatient claims from the same period to avoid penalties.: A blanket refund before any review is disproportionate and unquantified.

Treat the denials as a billing matter outside the compliance program.: External audit results are a core input to compliance monitoring and overpayment obligations.

Assess whether the denial reason affects similar claims not yet reviewed.: Correct. An external audit finding is credible information that similar claims may be overpaid; the overpayment rule requires a timely, good-faith inquiry into the wider population, not just the sampled claims.

External audit findings trigger a look-through to similar claims under the 60-day overpayment rule, whatever happens on appeal.

Answer: A

Have counsel engage an independent auditor so the work is privileged.: Correct. When potential liability exists, an independent auditor engaged at the direction of counsel gives objective results and preserves attorney-client privilege and work product while the organization decides on disclosure.

Have internal coders review the claims quickly before records change.: Speed matters, but internal coders may lack independence and their work is not protected by privilege.

Ask the cardiology group to perform a self-audit and certify the results.: The group under suspicion cannot objectively audit itself.

Add a cardiology review to next year's routine compliance audit plan.: A credible allegation of upcoding calls for prompt review, not a routine audit months away.

When an audit may reveal liability, use an independent reviewer under counsel's direction to keep it objective and privileged.

Answer: D

Hire now, since the exclusion term has already ended.: Reinstatement is not automatic when the term ends; eligibility returns only with OIG's written approval.

Hire now, since the applicant holds an active license.: Licensure and exclusion are separate; an active license does not lift an exclusion.

Hire once the applicant files a reinstatement request with the OIG.: Filing the request is a necessary step, but eligibility returns only when OIG grants reinstatement, not when the request is filed.

Defer the hire until the OIG grants reinstatement in writing.: Correct. Reinstatement is not automatic once an exclusion period ends; the person must apply and receive written notice from OIG that reinstatement is granted, so the applicant remains excluded until then.

An exclusion lasts until OIG grants reinstatement in writing; the end of the term, an active license or a pending request does not restore eligibility.

Answer: C

Notify the patient and HHS, since any misdirected PHI is a reportable breach.: Not every impermissible disclosure is reportable; an exception or a documented low-probability assessment can rebut the presumption.

Notify the patient but skip the assessment, since only one patient is involved.: The number affected does not remove the need for, or the result of, the risk assessment.

Assess and document whether a breach exception or low risk applies.: Correct. An impermissible disclosure is presumed a breach unless an exception applies or a documented four-factor assessment shows a low probability of compromise. A good-faith belief that the recipient could not reasonably have retained the information is an exception under 45 CFR 164.402(1)(iii), and the written confirmation of unopened deletion supports it; the analysis must be documented.

Treat the event as not a breach, since the recipient is also a covered entity.: The recipient's status is a factor, not an automatic exclusion; the conclusion still requires a documented exception analysis or risk assessment.

Presume a breach unless a regulatory exception applies or a documented four-factor risk assessment shows a low probability of compromise; document the conclusion either way.

Answer: B

The OIG Provider Self-Disclosure Protocol.: The OIG SDP does not accept matters that raise liability only under the Stark Law.

The CMS Self-Referral Disclosure Protocol.: Correct. Stark-only matters go to CMS through the SRDP; the OIG Self-Disclosure Protocol accepts self-referral matters only when they also raise potential AKS liability.

An OIG advisory opinion on the past lease.: Advisory opinions address proposed or existing arrangements prospectively; they are not a disclosure route for past violations.

A referral to DOJ as a criminal Stark case.: Stark is a civil, strict-liability law; it is not a criminal statute.

Stark-only: CMS SRDP. Conduct that also raises potential AKS liability: OIG Self-Disclosure Protocol.