Compliance Program Development and Implementation Flashcards

Which element is considered the foundation of an effective compliance program according to the OIG Compliance Program Guidance?

Answer: Written policies and procedures

Written policies and procedures form the foundation because they document expected conduct and provide the basis for all other program elements.

When developing a compliance risk assessment, which methodology is most appropriate for prioritizing identified risks?

Answer: Likelihood-times-impact scoring matrix

A likelihood-times-impact matrix allows organizations to prioritize risks by combining probability of occurrence with potential severity of harm.

A compliance officer discovers that a business unit is bypassing the hotline and handling complaints internally without documentation. What is the primary concern?

Answer: Loss of anonymity and potential retaliation against reporters

Internal handling without documentation risks retaliation against reporters and eliminates the confidentiality protections that encourage reporting.

Under the U.S. Federal Sentencing Guidelines, which factor most significantly reduces an organization's culpability score after a compliance violation?

Answer: Self-reporting the offense before investigation

Self-reporting prior to a government investigation is the most significant mitigating factor and can substantially reduce an organization's culpability score.

Which approach best ensures that compliance training is effective rather than merely completed?

Answer: Testing comprehension and tracking behavioral outcomes

Measuring comprehension through testing and tracking changes in behavior ensures training produces actual compliance improvements, not just completion records.

A company's compliance committee meets quarterly but rarely escalates issues to the board. What governance gap does this represent?

Answer: Inadequate board-level oversight and accountability

When issues are not escalated to the board, directors cannot exercise meaningful oversight, creating a critical governance gap in compliance accountability.

Which principle guides the appropriate scope of a compliance investigation when an allegation involves a senior executive?

Answer: Independent investigators should be used to avoid conflicts of interest

When allegations involve senior leaders, independence is essential to ensure credibility and avoid conflicts of interest that could compromise the investigation's integrity.