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Question 1
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The federal Civil Monetary Penalties Law (CMPL, 42 U.S.C. § 1320a-7a) authorizes OIG to impose penalties for which of the following?

A
B
C
D
to track
2026 Statistics

Key Facts: CIFHA Exam

92%

First-Attempt Pass Rate

AIHC (within 4 weeks of course completion)

100

Free Practice Questions

OpenExamPrep 2026

3 months

Exam Window After Course

AIHC info packet

6

Annual CEUs for Renewal

AIHC Renewals

Open-Note

Exam Format

AIHC

Online Proctored

Delivery

AIHC

The AIHC CIFHA exam is an online, professionally proctored, open-note certification taken within 3 months of completing AIHC's Conducting Internal Investigations course. Topics span the False Claims Act, Anti-Kickback Statute, Stark Law, OIG compliance, RAT-STATS sampling, EHR fraud detection, HIPAA, and forensic interviewing. AIHC reports a 92% first-attempt pass rate within 4 weeks of course completion.

Sample CIFHA Practice Questions

Try these sample questions to test your CIFHA exam readiness. Each question includes a detailed explanation. Start the interactive quiz above for the full 100+ question experience with AI tutoring.

1Under the False Claims Act (31 U.S.C. § 3729), which of the following best defines the 'knowingly' standard?
A.Only actual knowledge that a claim is false
B.Actual knowledge, deliberate ignorance, or reckless disregard of the truth or falsity of the information
C.Negligence or failure to exercise reasonable care
D.Intent to defraud the government plus actual knowledge
Explanation: 31 U.S.C. § 3729(b)(1) defines 'knowingly' to mean (i) actual knowledge, (ii) deliberate ignorance of the truth or falsity, or (iii) reckless disregard of the truth or falsity. The statute expressly states that no proof of specific intent to defraud is required.
2In Universal Health Services v. United States ex rel. Escobar, the Supreme Court clarified that 'materiality' under the FCA means the misrepresentation must:
A.Be intentionally made by an officer of the entity
B.Have a natural tendency to influence, or be capable of influencing, the payment decision
C.Result in actual loss to the government
D.Be expressly identified as a condition of payment in the contract
Explanation: The Supreme Court adopted the statutory definition of materiality at 31 U.S.C. § 3729(b)(4): a misrepresentation is material if it has a natural tendency to influence, or is capable of influencing, the payment or receipt of money or property. Escobar emphasized that materiality is rigorous and demanding.
3A whistleblower files a qui tam suit and the government intervenes and successfully prosecutes the case. Under 31 U.S.C. § 3730(d), what share of the recovery may the relator receive?
A.10% to 15%
B.15% to 25%
C.25% to 30%
D.30% to 40%
Explanation: When the government intervenes in a qui tam action under § 3730(d)(1), the relator is entitled to between 15% and 25% of the proceeds, depending on the contribution to the prosecution. If the government does not intervene and the relator litigates alone, the share rises to 25%–30% under § 3730(d)(2).
4The federal Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)) is violated when remuneration is offered or paid:
A.Only when the sole purpose is to induce referrals of federal health-care program business
B.If even one purpose of the remuneration is to induce referrals payable by a federal health-care program
C.Only when the remuneration exceeds fair market value by more than 25%
D.Only when the recipient is a licensed physician
Explanation: Federal courts have consistently adopted the 'one purpose rule' (United States v. Greber, 760 F.2d 68 (3d Cir. 1985)). If even one purpose of the payment is to induce referrals reimbursable by a federal health-care program, the statute is violated, even if the arrangement also serves legitimate purposes.
5Which of the following is NOT one of the standard categories of conduct prohibited by the federal Anti-Kickback Statute?
A.Knowingly and willfully soliciting remuneration to induce referrals
B.Knowingly and willfully offering remuneration to induce referrals
C.Negligently overpaying for services with no intent to induce referrals
D.Knowingly and willfully receiving remuneration in return for arranging items reimbursable by a federal program
Explanation: AKS is an intent-based criminal statute that requires conduct to be done 'knowingly and willfully.' Negligent overpayment, without the requisite mental state, does not violate AKS, although it may violate Stark or trigger overpayment liability.
6To qualify for an Anti-Kickback Statute safe harbor, an arrangement must:
A.Substantially comply with the conditions of a relevant safe harbor
B.Comply with at least one Stark Law exception
C.Squarely satisfy every condition of the applicable safe harbor
D.Receive a written advisory opinion from the OIG
Explanation: OIG has stated repeatedly that safe-harbor protection is all-or-nothing. An arrangement must squarely meet every condition of a safe harbor to receive its protection; partial compliance does not provide protection, although it does not automatically mean the arrangement is unlawful.
7A multispecialty clinic enters a personal services arrangement with an outside consultant. To fit the AKS personal services and management contracts safe harbor, the agreement must, among other things:
A.Be terminable for any reason on 30 days' notice
B.Be in writing, signed by the parties, specify the services, have a term of at least one year, and set aggregate compensation in advance at fair market value
C.Be approved by the hospital's medical executive committee
D.Be limited to no more than $25,000 in annual compensation
Explanation: The personal services and management contracts safe harbor (42 C.F.R. § 1001.952(d)) requires a written agreement signed by the parties, specification of all covered services, a term of at least one year, and aggregate compensation set in advance, consistent with fair market value, and not determined in a manner that takes into account the volume or value of referrals.
8The Stark Law (42 U.S.C. § 1395nn) prohibits a physician from referring a Medicare patient for 'designated health services' (DHS) to an entity with which the physician has a financial relationship UNLESS:
A.The arrangement is supported by a fairness opinion
B.The physician believes in good faith that the referral is medically necessary
C.An applicable Stark exception is satisfied
D.The patient consents in writing
Explanation: Stark is a strict-liability civil statute. A prohibited referral is permitted only if the financial relationship squarely fits a statutory or regulatory exception (e.g., in-office ancillary services, employment, rental of office space, fair market value compensation). Intent and patient consent are not relevant.
9Which of the following is a 'designated health service' (DHS) under the Stark Law?
A.Emergency department triage
B.Clinical laboratory services
C.Cosmetic surgery paid out of pocket
D.Dental services not billed to Medicare
Explanation: Stark applies to 11 categories of DHS, including clinical laboratory services; physical therapy, occupational therapy, and outpatient speech-language pathology services; radiology and imaging; radiation therapy; DME and supplies; parenteral and enteral nutrients; prosthetics and orthotics; home health services; outpatient prescription drugs; and inpatient and outpatient hospital services.
10A primary distinction between the federal Anti-Kickback Statute and the Stark Law is that:
A.AKS applies only to hospitals; Stark applies to all entities
B.AKS is a strict-liability civil statute; Stark requires criminal intent
C.AKS requires 'knowingly and willfully' intent and is criminal in nature; Stark imposes strict liability with civil penalties
D.AKS applies only to physician self-referrals; Stark covers any referrer
Explanation: AKS is an intent-based criminal statute (felony) that requires the government to prove the conduct was knowing and willful. Stark is a civil, strict-liability statute focused specifically on physician self-referrals for designated health services payable by Medicare; intent is irrelevant to a Stark violation.

About the CIFHA Exam

The CIFHA is an AIHC-issued credential for internal auditors and compliance professionals who detect and investigate healthcare fraud. The program covers fraud statutes (FCA, AKS, Stark, EKRA, CMPL), OIG compliance and audit programs, RAC/UPIC processes, audit sampling, EHR fraud red flags, evidence handling, and forensic interview methods.

Questions

100 scored questions

Time Limit

Per AIHC candidate materials

Passing Score

Per AIHC candidate materials

Exam Fee

Included in AIHC course tuition (American Institute of Healthcare Compliance (AIHC))

CIFHA Exam Content Outline

~20%

False Claims Act and Fraud Statutes

FCA scienter and materiality, qui tam relator share, Anti-Kickback Statute one-purpose rule and safe harbors, Stark designated health services and exceptions, EKRA, and the Civil Monetary Penalties Law.

~18%

OIG Compliance and Enforcement

OIG Work Plan, General Compliance Program Guidance, Self-Disclosure Protocol, Corporate Integrity Agreements, LEIE exclusion screening, and the seven elements of an effective compliance program.

~16%

Coding and Billing Fraud

Upcoding, unbundling, NCCI edits, modifier 25/59, EHR cloning and copy-paste, two-midnight rule, telehealth post-PHE fraud, DME/hospice/home-health red flags, and never events.

~12%

Audit Methodology

Fraud-risk assessment, IIA standards, work-paper structure, the 5-Cs finding format, RAC appeal stages, and forensic audit response.

~12%

Data Analytics and Fraud Detection

RAT-STATS, sampling design, probe samples, extrapolation, peer benchmarking, Benford's Law, and triangulation.

~12%

Evidence and Investigation

Cognitive vs. Reid interviewing, Upjohn/Garrity warnings, digital chain of custody, CIDs, grand-jury subpoenas, parallel proceedings, and peer-review privilege limits.

~10%

HIPAA Privacy and Security

Minimum-necessary, audit-control standards, breach risk assessment, and law-enforcement disclosures under 45 CFR Part 164.

How to Pass the CIFHA Exam

What You Need to Know

  • Passing score: Per AIHC candidate materials
  • Exam length: 100 questions
  • Time limit: Per AIHC candidate materials
  • Exam fee: Included in AIHC course tuition

Keys to Passing

  • Complete 500+ practice questions
  • Score 80%+ consistently before scheduling
  • Focus on highest-weighted sections
  • Use our AI tutor for tough concepts

CIFHA Study Tips from Top Performers

1Memorize the FCA scienter standard (actual knowledge, deliberate ignorance, reckless disregard) and the Escobar materiality standard verbatim
2Learn the AKS 'one-purpose rule' and the elements of major safe harbors (employment, personal services, space/equipment rental)
3Understand the difference between AKS (criminal, intent-based) and Stark (civil, strict liability) and when SDP vs. SRDP applies
4Know the 5-level Medicare appeals process (redetermination, reconsideration, ALJ, Council, federal court) and the 120-day redetermination clock
5Practice OIG sampling concepts in RAT-STATS: 90% confidence at 25% precision, point estimate vs. lower bound, probe vs. statistically valid samples
6Drill EHR fraud red flags (cloning, copy-paste, audit-log gaps) and modifier 25/59 audit logic

Frequently Asked Questions

What is the AIHC CIFHA credential?

CIFHA stands for Certified Internal Forensic Healthcare Auditor. It is issued by the American Institute of Healthcare Compliance (AIHC) and certifies competency in internal forensic auditing for healthcare fraud detection and investigation.

How is the CIFHA exam delivered?

The CIFHA exam is delivered online, professionally proctored, and open-note. Candidates schedule the exam remotely with an AIHC-approved proctor and complete it within 3 months of finishing AIHC's Conducting Internal Investigations course.

Does AIHC publish a CIFHA passing score and question count?

AIHC does not publicly list a fixed numeric passing score or exact question count for the CIFHA on its public website; current details are provided in the candidate materials and AIHC info packet. Always verify directly with AIHC before testing.

What is the CIFHA pass rate?

AIHC reports a 92% first-attempt pass rate when candidates take the exam within 4 weeks of completing the course.

How many CIFHA exam attempts are included?

One exam attempt is included in the AIHC course tuition if taken within 3 months of completing the course. Up to 2 additional attempts may be purchased within 1 year of course enrollment if needed.

What are the CIFHA renewal requirements?

AIHC credentials, including CIFHA, are typically renewed annually with 6 CEUs (4 Core and 2 Ethics). See AIHC's Renewals page for current requirements.

What topics should I focus on for CIFHA prep?

Focus on the False Claims Act (knowingly, materiality, qui tam), Anti-Kickback Statute one-purpose rule and safe harbors, Stark designated health services and exceptions, OIG Self-Disclosure Protocol, Corporate Integrity Agreements, RAC/UPIC audits and appeals, RAT-STATS sampling, EHR fraud (cloning, upcoding, unbundling), HIPAA privacy/security, and forensic interview and evidence-handling techniques.