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By using guidelines in CIAs for other healthcare entities similar to yours, you can mimic compliant program requirements.
The OIG is actively investigating potential regulatory violations at healthcare entities.
The Bipartisan Budget Act of 2015 mandated that federal agencies adjust civil monetary penalty amounts for inflation.
In September 2015, Sally Yates, an attorney for the DOJ wrote a memo stating that individuals were to be held accountable in corporate wrongdoing cases.
CIAs are designed to improve processes so that violations don’t occur again.
In September 2015, we first heard of the Yates memo and were warned that the DOJ was going to take individual accountability in corporate wrongdoing seriously. We have seen fines against individual physicians, but now we know hospital executives can no longer ignore the risks.
CIAs are fairly uniform; however, most include specific requirements tailored to the violation(s) that led to the settlement. CIAs typically run 3-5 years.
The purpose of a CIA is to strengthen an organization’s compliance program with policies and procedures approved by the government.
After building a case for why the organization needs the physician and role in question, prepare for the negotiation conversation. Anticipate where there will be pushback and where compromises can occur. Then, be sure to organize and document everything, this will save you a headache at a later date.
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