Certified Professional Compliance Officer - CPCO Certification Exam

CPCO

The AAPC's Certified Professional Compliance Officer (CPCO) credential addresses the ever-growing compliance requirements of government laws, regulations, rules, and guidelines. Medical practices need staff who can develop, organize, manage, and direct the functions of a compliance department.

By passing the CPCO exam, employers recognize you possess an understanding of the key requirements necessary to effectively develop, implement, and monitor a healthcare compliance program for your practice based on governmental regulatory guidelines — including internal compliance reviews, audits, risk assessments, and staff education and training.

How Much Does a CPCO Earn?

The CPCO is a healthcare compliance credential that can take your career to the next level. According to AAPC’s 2022 Medical Coding Salary Survey, medical coding professional average $54,797 in annual compensation. But you can earn 47% more with your CPCO. In fact, the national average salary for CPCOs is $80,550 per year.

CPCOs will have demonstrated knowledge of:

  • The Office of Inspector General’s (OIG) compliance guidance for individual and small group physician practices, clinical laboratories, and third-party billing companies
  • Compliance program effectiveness
  • Key healthcare fraud and abuse laws — including the False Claims Act, Stark Laws, and Anti-kickback Statute, including the associated penalties
  • How ACA will affect medical practices
  • Other laws and regulations — including HIPAA, Emergency Medical Treatment and Labor Act (EMTALA), Occupational Safety and Health Administration (OSHA), and Clinical Laboratory Improvement Amendment (CLIA)
  • Handling investigations, including self-disclosure protocols
  • Requirements under Corporate Integrity Agreements (CIAs) and Certificate of Compliance Agreements (CCAs)
  • Current investigative activities, such as Recovery Audit Contractors (RACs), Unified Program Integrity Contractors (UPICs), Medicaid fraud control units (MFCUs)
  • Various risk areas — including items such as gifts/gratuities, conflicts of interest, use of advance beneficiary notices, teaching physicians’ guidelines, and incident-to services

The CPCO Certification Exam

  • 100 multiple choice questions (proctored)
  • 4 hours to finish the exam

The CPCO certification exam thoroughly covers:

5 questions

  • History of healthcare laws in the United States
  • Past healthcare industry investigations
  • Federal Sentencing Guidelines
  • Implementation of Compliance Program Guidance
  • Key agencies involved in healthcare compliance
  • Current statistics related to CERT reports and National Healthcare Expenditures
  • OIG five-principle strategy

Physicians and Small Group Practices

22 questions

  • General guidance information
  • The seven "steps"
    • Standards of conduct and operational policies
    • Oversight requirements
    • Compliance training
    • Monitoring and auditing
    • Communications
    • Disciplinary actions
    • Responding to detected offenses

Third Party Billing Companies and Clinical Laboratories

3 questions

  • Lab orders and billing
  • Balanced Budget Act of 1997 and diagnoses
  • Use of outside billing companies

3 questions

  • Supplemental hospital guidance

19 questions

  • Physician compliance program guidance risks
  • Documentation
  • Conflict of interest
  • Gifts/gratuities
  • Medical necessity
  • Advance Beneficiary Notices
  • Incident to
  • Overpayments/credit balances
  • Certificates of Medical Necessity
  • Certifications for Home Health & Therapy services
  • Billing of non-covered services as if covered
  • Teaching physicians
  • Gainsharing arrangements
  • Joint Ventures
  • Limiting charges for PAR and Non-PAR practices
  • Professional Courtesy/Discounts/Adjustments
  • Rental of office space
  • Unlawful advertising
  • State escheat laws

12 questions

  • Difference between fraud and abuse
  • Civil Monetary Penalties
  • False Claims Act
  • Anti-kickback Statute
  • Stark Laws
  • Fraud Enforcement and Recovery Act (FERA)
  • Patient Protection and Affordable Care Act (PPACA/Health Reform)

24 questions

  • HIPAA
  • EMTALA
  • CLIA
  • OSHA
  • RICO (Racketeer Influenced and Corrupt Organizations Act)
  • Mail/Wire fraud

9 questions

  • Subpoenas and search warrants
  • Use of legal counsel
  • Self-disclosure protocol
  • Qui tam/whistleblowers
  • Corporate Integrity Agreements (CIAs)
  • Certification of Compliance Agreements (CCAs)
  • Excluded Parties (OIG and GSA)
  • RACs, UPICS, MICs, PSCs, and MFCUs

3 questions

  • Federal regulations/citations/references
  • Office of Inspector General
  • Centers for Medicare & Medicaid Services
  • Medicaid & Workers Compensation

Approved References for Use During the CPCO Exam

Reference materials are not required for the CPCO exam, but you may refer to the following items, so long as they are printed directly from the official websites. Notes are allowed only on the printed side of documents.

Note:

Electronic devices with an on/off switch (cell phones, smart phones, tablets, etc.) are not allowed into the examination room. Failure to comply with this policy may result in disqualification of your exam.

Non-Approved CPCO Exam References

Due to the advantages of additional information and/or ease of use, the following books cannot be used during the exam:

  • Study Guides and Practice Exams
  • Any published references by HCCA

Recommended Resources for Preparation

Healthcare Compliance Certification Requirements

The CPCO exam requires an understanding of a wide variety of compliance topics and issues. CPCO candidates should undertake CPCO Online Training and/or have two years’ experience working with compliance programs.

Prior to the CPCO exam, you should be extremely familiar with key elements required for compliance programs, including the daily operational aspects. You should also be familiar with key laws and regulations impacting compliance programs, physician practices, and policies used to address potential fraud and abuse, including associated penalties and fines. Additionally, you should know where to go and how to research information to identify correct practices to mitigate compliance risks.

Individuals with limited compliance experience will need to become familiar with the different topics addressed on the exam. You can find these topics outlined on the exam breakdown tab of this page.

Be aware that this is a challenging, high-level examination which is not meant for individuals with limited or no compliance experience or training.

Additional Requirements

  • Maintain annual AAPC membership
    • If you haven’t become an AAPC member, you must do so prior to scheduling your CPCO certification exam.
    • Renewing members must have a current membership at the time of exam application and/or when exam results are released. 
  • CPCOs are required to complete 36 Continuing Education Units (CEU's) every two years. For CEU requirements, please see our CEU Information page.

Note:

An overall score of 70% or higher is required to pass the certification exam. If you don’t pass, the areas of study/categories with a score of 65% or less will be provided for your preparation to retest. The areas of study reported reflect scores based on the number of questions in each category/section of the exam.

All AAPC certification exams exclusively measure proficiencies relating to the one credential named in the exam. To earn additional medical coding credentials will require you to pass additional certification exams.

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