Corporate Integrity Agreements (CIAs) generally focus on one or more categories of violations: claims review, focus arrangements, quality of care, and covered functions review. 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.
All CIAs require:
- Establishment of a compliance officer and compliance committee
- Imposition of compliance duties for the Board of Directors
- Adoption of a code of conduct and applicable policies and procedures
- Training and education on the code of conduct, policies, and procedures within the first 90 to 120 days as well as annually thereafter
- Internal reviews in addition to reviews by an Independent Review Organization (IRO) that organizations hire as a third party opinion
- Screening for ineligible persons, i.e. those excluded from federal health programs and those who have convictions that entail mandatory exclusion
- Reporting to the OIG of ongoing investigations or legal proceedings, any alleged fraudulent behavior, repayment of overpayments in accordance with the ACA, as well as any other compliance breach or any change in the location or structure of the organization
The OIG publishes all of the CIAs it issues on its website.
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