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CHC (CCB): Compliance Program Administration

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Compliance Program Administration

What this domain tests

Administration is the machinery: governance, structure, authority, resources, and documentation. Know the seven elements framework that underlies most healthcare compliance programs: written standards and procedures; designated compliance officer and compliance committee; effective training and education; effective lines of communication; internal monitoring and auditing; enforcement through well-publicized disciplinary guidelines; and prompt response to detected problems with corrective action.

Understand the compliance officer's role: operational authority, direct access to the governing body, independence from the functions being monitored, and adequate resources. The compliance committee provides oversight and cross-functional representation; it does not replace the officer.

Traps to expect

  • Reporting line: the compliance officer should have a direct line to the governing body or its audit/compliance committee, not solely to the CFO or general counsel. Questions test whether you spot a structurally weakened program.
  • Independence: assigning the compliance officer to also run billing operations creates a conflict.
  • Committee ≠ officer: the committee oversees; the officer executes.
  • Documentation: meetings, risk decisions, and resource requests should be minuted; absence of records is itself a finding.
  • Tone at the top: leadership messaging is an element, but slogans without resources or enforcement do not satisfy it.

Rule of thumb

Ask: Who has authority, who has independence, and can I prove it? A program element exists only if it is documented and resourced.

Worked example

A mid-size clinic's compliance officer reports to the billing manager and also performs coding audits. A question asks the primary structural weakness. The answer is the dual role and reporting line: the officer lacks independence from the audited function and lacks direct governing-body access. The fix is to separate the audit function and re-point the reporting line, not merely to add more training.