What You Need to Know About Corporate Integrity Agreements (CIAs)

Posted on
November 22, 2016

The purpose of a CIA is to strengthen an organization’s compliance program with policies and procedures approved by the government.

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When a hospital or other healthcare entity violates the False Claims Act, there are consequences. Often these include entering into a Corporate Integrity Agreement (CIA) with the U.S. Office of the Inspector General (OIG). The purpose of a CIA is to strengthen an organization’s compliance program with policies and procedures approved by the government. The OIG must have confidence that the organization is taking steps to prevent new violations.

What is a Corporate Integrity Agreement?

A CIA is a tool used by the OIG to address violations at healthcare organizations through policies and procedures designed to enforce compliance with regulations. A CIA is usually coupled with a civil settlement between the provider and the government to avoid exclusion from federal health programs.

Who is subject to a CIA?

CIAs have been issued for all types of healthcare entities ranging from hospitals and health systems to physician practice groups, individual physicians, post-acute facilities, dialysis companies, pharmaceutical manufacturers, durable medical equipment suppliers, and many more.

Historically, the OIG always issued a CIA when violations occurred. However, in recent cases where the OIG is confident that the violation(s) will not reoccur, a CIA has not been put into place. Because the OIG can assess a violators’ capacity to change noncompliant behaviors, they can identify organizations who are low risk for repeat violations. To determine whether or not an organization should enter into a CIA, the OIG looks at many factors, including how long ago the violations occurred, whether there was a pattern of misconduct, the compliance procedures in place, and other elements. If an organization self discloses their violations, the OIG may not require a CIA because self disclosure is evidence of an effective compliance program.

Learn more about CIAs here.

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