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Certified Professional Compliance Officer - CPCO

Healthcare Compliance Certification


Healthcare compliance certification 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. The Patient Protection and Affordable Care Act (PPACA) of 2010 indicates compliance programs will become mandatory as a condition of enrollment in the Federal healthcare programs. The requirement was confirmed by Daniel R. Levinson of the Office of Inspector General in his testimony to the House Committee on Energy and Commerce, Subcommittee on Health on September 22, 2010.

As an individual holding AAPC's Certified Professional Compliance Officer (CPCO) credential, you must be able to demonstrate an understanding of the key requirements needed 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.

We created the CPCO certification to help manage increased scrutiny on Medicare/Medicaid fraud and abuse, the impending requirement for mandatory physician practice compliance programs, and to create opportunities for AAPC members. The CPCO is a healthcare compliance certification that can take your career and to the next level.

CPCOs will have demonstrated knowledge of:

  • The 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 PPACA will affect medical practices
  • Other laws and regulations including HIPAA, EMTALA, and CLIA
  • Handling investigations, including self-disclosure protocols
  • Requirements under Corporate Integrity Agreements (CIAs) and Certificate of Compliance Agreements (CCAs)
  • Current investigative activities (RACs, ZPICs, 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

  • 150 multiple choice questions (proctored)
  • 5 hours and 40 minutes to finish the exam
  • 1 free retake to be used within one year of first attempt
  • $380
  • Open reference (approved references)

The CPCO certification exam thoroughly covers:

7 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

33 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

4 questions

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

4 questions

  • Supplemental hospital guidance

28 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

20 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)

36 questions

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

13 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, ZPICS, MICs, PSCs, and MFCUS

5 questions

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

Approved References for use during Examination

  • Any published references are allowed, except Study Guides and any published references by HCCA
  • Additional Preparation Methods
  • Resources to help prepare for the CPCO examination


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.

Compliance Certification Requirements

While there is no experience requirement, we strongly recommend that the candidate have at least two years experience working with compliance programs and the associated laws and regulations. We recommend the individual also have at least an associate's degree in healthcare. The exam requires an understanding of a wide variety of compliance topics and issues, and practical application of those requirements to scenarios that is often gained through years of experience. Individuals who do not have compliance expertise or who have worked in limited compliance roles will need to become familiar with the different topics addressed on the exam breakdown tab on 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.

Other requirements:

  • Pay examination fee at the time of application submission
  • Maintain current membership with the AAPC
  • Renewing members must have a current membership at the time of application submission as well as when results are sent

Certification Exam Recommendation

The CPCO examination is recommended for individuals who have experience working in a compliance role or in a compliance department. The individual should be extremely familiar with the key elements required for compliance programs as well as the day-to-day operational aspects of compliance programs. Individuals should also be very familiar with the key laws and regulations impacting compliance programs, physician practices, and those used to address potential fraud and abuse, including their associated penalties and fines. Individuals should also know where to go and how to research information to identify correct practices to mitigate compliance risks.

Maintaining Certification

Membership is required to be renewed annually and 36 Continuing Education Units (CEUs) must be submitted every two years for verification and authentication of expertise. For CEU requirements please see our CEU Information page.

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