OIG negotiates corporate integrity agreements (CIA) with health care providers and other entities as part of the settlement of Federal health care program investigations arising under a variety of civil false claims statutes. Providers or entities agree to the obligations, and in exchange, OIG agrees not to seek their exclusion from participation in Medicare, Medicaid, or other Federal health care programs. This is also usually part of an agreement not to pursue or file criminal charges.
We also have clients review them in order for them to understand the government's view on various business practices in health care. If your business is interested, here is the OIG's posted list of corporate integrity agreements. They are in PDF and can be downloaded and reviewed.
CIAs have many common elements, but each one addresses the specific facts at issue and often attempts to accommodate and recognize many of the elements of preexisting voluntary compliance programs.
A comprehensive CIA typically lasts 5 years and includes requirements to:
1. hire a compliance officer/appoint a compliance committee;
2. develop written standards and policies;
3. implement a comprehensive employee training program;
4. retain an independent review organization to conduct annual reviews;
5. establish a confidential disclosure program;
6. restrict employment of ineligible persons;
7. report overpayments, reportable events, and ongoing investigations/legal proceedings; and
8. provide an implementation report and annual reports to OIG on the status of the entity's compliance activities.
Keep compliant and make sure that your health care entity does not end up on this list.
Posted by Tracy Green, Esq.
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