AAPC-CPCO Certified Professional Compliance Officer - Set 1 - Part 3

Correct Answer: Independent External Accreditation Review

OIG's seven elements are written policies and procedures, compliance leadership and oversight, training and education, communication and disclosure, enforcing standards, risk assessment, and responding to detected offenses. Independent external accreditation review is not among them. Option a is incorrect because it names Element 5, covering consequences and incentives for meeting standards, so it is a true element and the wrong choice for a NOT question. Option b is incorrect because the framework lists it as Element 6, which pairs periodic risk review with auditing and monitoring; being a genuine element, it is not the exception. Option d is incorrect because it is Element 3 in the OIG list, so it belongs among the seven elements and cannot be the exception asked for.

Correct Answer: The CEO or the board

Under GCPG Element 2, the compliance officer should report directly to the CEO or the board, and should not lead or report to the legal or financial functions, which protects independence. Option b is incorrect because billing, coding, and claim submission are operations the compliance officer should stay separate from, so reporting to that manager would create a conflict. Option c is incorrect because this role heads the financial function, so a reporting line there would compromise the separation the guidance expects from financial leadership. Option d is incorrect because the general counsel leads the legal function, and the compliance officer should neither lead nor report to legal or financial functions.

Correct Answer: Authority to review all of them

The GCPG states that the compliance officer should have the authority to review all documents, data, and other information relevant to the organization's compliance activities, including patient records, billing records, and records of arrangements with other parties. Option a is incorrect because the guidance describes the compliance officer as reporting to the CEO or the board, and it assigns no role in appointing the CEO. Option b is incorrect because the guidance has the compliance officer chair the Compliance Committee, and the board is a separate body to which the officer reports. Option d is incorrect because OIG guidance ties board reporting to the compliance officer's duty to report to the board, and gives no authority over setting board agendas.

Correct Answer: Counsel or law enforcement

OIG guidance states that some reports, such as those involving substantial legal violations, may be referred to counsel or law enforcement, while the compliance officer reviews some concerns and sends others to departments like Human Resources. Option a is incorrect because the committee receives regular information about concerns and investigations in the compliance officer's communications, but it is not the referral point for substantial legal violations. Option b is incorrect because facility compliance officers at multiple locations are described as designees who receive concerns, so they are not the escalation route for serious legal violations. Option c is incorrect because the guidance gives Human Resources as an example of another leader or department that may receive ordinary concerns, not reports of substantial legal violations.

Correct Answer: It deters personnel from coming forward with concerns

The Compliance Committee should ensure the entity does not deter individuals from coming forward, for example by requiring that concerns first go to a manager or supervisor. Independent reporting paths exist so reports cannot be diverted. Option b is incorrect because logging applies to all disclosures however they are made, so the instruction does not change that duty; the issue is discouraging reports at the outset. Option c is incorrect because anonymous paths are a separate requirement, an independent route outside business functions, and a manager-first rule does not itself eliminate that route. Option d is incorrect because confidentiality concerns how the reporter's identity is protected after a report is made, whereas this instruction acts before any report reaches the compliance officer.

Correct Answer: The compliance officer

OIG guidance on Element 5 assigns the compliance officer the task of monitoring investigations and resulting discipline, so that consequences for noncompliance are applied consistently across all levels of personnel. Option a is incorrect because human resources is named only as an example of a function that may help decide appropriate consequences, not as the monitor of investigations and discipline. Option c is incorrect because the Compliance Committee builds the audit schedule into the compliance work plan and ensures the entity takes steps to prevent recurrence, not monitoring discipline for consistency. Option d is incorrect because managers and supervisors are expected to impose consequences for noncompliant behavior appropriately and consistently, which is a different duty from monitoring investigations and discipline.

Correct Answer: The root cause of the conduct

The compliance officer should gather information throughout the investigation and work with appropriate individuals to determine the root cause of the conduct, so the entity can make the changes required to address it. Option a is incorrect because enforcing disciplinary policies is one listed corrective action, yet it addresses the responsible individuals and does not explain why the conduct happened in the first place. Option b is incorrect because engaging external counsel is a decision about investigative resources and support, not the analysis that tells the entity which changes will stop the conduct from resuming. Option d is incorrect because a witness log belongs to the contemporaneous record of the investigation, which documents the process rather than identifying what underlying problem allowed the conduct to occur.

Correct Answer: I and III

A small entity that cannot support a compliance officer may designate a compliance contact, and small entities should assess their compliance risks at least once a year. Statements I and III match the small-entity adaptations; II and IV contradict them. Option b is incorrect because it includes statement II, yet the guidance says a small entity's program should still encompass the seven elements despite its constraints; only the structure is adapted. Option c is incorrect because it pairs two inaccurate statements: elements are not dropped for small entities, and the compliance contact is kept away from legal services responsibilities. Option d is incorrect because statement IV reverses the guidance, which says the compliance contact should have no responsibility for performing or supervising legal services; this choice also leaves out the true statement I.

Correct Answer: Delay disciplinary mechanisms until a violation is detected

OIG guidance says small entities should have enforcement and disciplinary mechanisms in place before violations occur. Waiting until a violation is detected contradicts that expectation, so it is the one approach an entity should not take. Option a is incorrect because OIG guidance states entities may want to consider incentives for compliance performance and innovation as part of enforcing standards. Option c is incorrect because OIG guidance calls for flexible mechanisms that let personnel ask questions and disclose mistakes while still enforcing the entity's commitment to compliance. Option d is incorrect because OIG guidance says entities might communicate that failing to report violations of policies or legal requirements may lead to discipline, so this is a suggested approach.

Correct Answer: They are a significant drain on the programs

OIG guidance states that innocent billing errors are a significant drain on the Federal health care programs. For that reason, all parties are asked to cooperate to reduce the overall error rate, even though no penalties apply. Option a is incorrect because that administrative remedy has exactly the same standard of proof as the False Claims Act, so innocent errors fall outside its reach. Option b is incorrect because criminal penalties require criminal intent to defraud proved beyond a reasonable doubt, which an innocent error lacks, so the penalty route does not apply. Option d is incorrect because that Act reaches only actual knowledge, reckless disregard or deliberate ignorance of falsity and does not encompass mistakes, errors or negligence.