Corporate integrity agreement

Corporate Integrity Agreement (CIA) is a legal document issued by the United States Department of Health and Human Services (HHS) Office of Inspector General (OIG). It is designed to promote compliance with the laws, regulations, and standards that govern the healthcare industry.

Overview

A Corporate Integrity Agreement is a tool used by the OIG to ensure that healthcare providers comply with federal laws. It is often used as part of a settlement agreement in cases where the OIG has identified potential violations of the False Claims Act or other federal healthcare laws.

The CIA typically requires the healthcare provider to implement a comprehensive compliance program that includes written standards of conduct, designated compliance officer and committee, comprehensive employee training, confidential disclosure program, and ongoing monitoring and auditing. The provider is also required to report any overpayments, reportable events, and ongoing investigations or legal proceedings to the OIG.

Purpose

The primary purpose of a CIA is to ensure that the healthcare provider complies with all applicable federal healthcare laws and regulations. This is achieved by requiring the provider to implement a comprehensive compliance program and to take specific actions to prevent future violations.

Components

A typical CIA includes several key components:

• Written Standards and Policies: The provider must develop and implement written standards and policies that clearly describe the expected conduct of all employees and the provider's commitment to compliance with all federal healthcare laws.

• Compliance Officer and Committee: The provider must designate a compliance officer and a compliance committee who are responsible for implementing and overseeing the compliance program.

• Training and Education: The provider must provide comprehensive training and education on the compliance program to all employees.

• Confidential Disclosure Program: The provider must establish a confidential disclosure program that allows employees to report any suspected violations without fear of retaliation.

• Ongoing Monitoring and Auditing: The provider must conduct regular audits to monitor compliance with the program and to identify any potential violations.

• Reporting Obligations: The provider must report any overpayments, reportable events, and ongoing investigations or legal proceedings to the OIG.

Enforcement

The OIG is responsible for enforcing the terms of the CIA. If the provider fails to comply with the terms of the agreement, the OIG may impose monetary penalties or exclude the provider from participating in federal healthcare programs.

See also

• Healthcare compliance
• False Claims Act
• United States Department of Health and Human Services
• Office of Inspector General