CHCO case studies
CHCO · Put your knowledge to work in context.
The Certified Healthcare Compliance Officer (CHCO) is a professional credential for people who carry day-to-day responsibility for a healthcare organization's compliance and ethics program - compliance officers and analysts, billing and revenue-cycle managers, privacy and security staff, internal auditors, and clinicians moving into administrative oversight. It signals that the holder understands both the legal framework regulators enforce and the practical machinery of running a program: governance and board reporting, risk assessment, policy development, auditing and monitoring, education, and responding to a government inquiry when one arrives. The CHCO case studies are 5 cases and about 4,692 words.
1The CCO Who Reports to the CFO: Rebuilding Elements Two Through Seven
You are the newly hired chief compliance officer at a three-hospital, 620-bed nonprofit system. In your first week you learn that the previous CCO resigned 11 months ago and the function was absorbed by the CFO; the compliance committee last met 14 months ago; the board gets a 20-minute compliance update each December; the hotline is answered by an outside vendor, but no one logs or trends the calls; policies were last revised in 2019 and still cite pre-2015 billing rules; and the internal audit plan is set by Finance.
878 words, about 4 min2Above-Market Lease, Free Nurses, and an EHR Subsidy for a Referring Oncology Group
The CEO of a 210-bed community hospital wants to grow oncology volume. The hospital proposes to lease 4,000 square feet in a medical office building owned by an independent 12-physician oncology group at 42 per square foot; the hospital's own market estimate, prepared without an appraisal, is 26–$29.
952 words, about 5 min3Three Incidents in One Afternoon: Breach Clocks That Have Already Started
On Friday, June 6, the privacy officer of a 200-provider multi-specialty group learns three things in one afternoon. (1) A physician reported that her unencrypted laptop was stolen from her locked car on May 29; it held a spreadsheet of 3,400 patients with names, dates of birth, diagnoses, and insurance numbers, which she had copied to the desktop to work from home.
941 words, about 5 min4A 65% E/M Error Rate and a Memo That Says 'No Refund Required'
An internal audit of 40 established-patient visits billed by five orthopedic surgeons found that 26 (65%) were billed 99214 or 99215 while the documentation supported 99213; 7 of 12 claims with modifier 25 lacked a separately identifiable service; and one surgeon's notes were near-identical across three dates. The practice is hospital-owned, bills professional services under the hospital's tax ID, and Medicare is 44% of visits.
964 words, about 5 min5Subpoena, CID, a Reimaged Laptop, and a CEO Who Wants to Call the FBI
On a Tuesday morning, a regional home health agency receives a subpoena from the U.S. Attorney and a civil investigative demand from HHS-OIG requesting 2019–2024 records for Medicare home health episodes, plus a request for interviews.
957 words, about 5 min