[4] Example CCA www.oig.hhs.gov/fraud/cia/agreements/Physician_Specialists_in_Anesthesia_PC_06282004.pdf A CIA is when the OIG negotiates an agreement as part of a civil agreement with the health care provider or health organization under the Federal Civil Law False Claims Act. The alleged perpetrators agree to meet certain terms of the contract in exchange for not being excluded from participation in federal programs. According to the OIG, the typical CIA lasts about 5 years and contains the following conditions[1]: This article contains public domain material from the U.S. Department of Health and Human Services document: Corporate Integrity Agreements Snapshot (PDF). Called April 14, 2018. CIA can be used to address issues of quality of care[2] or corporate integrity. [1] Strategic Management`s expertise as a healthcare compliance consulting firm allows us to be a compliance expert for the board of directors. Our health care consultants have served as an independent expert on the compliance of health organizations under a CIA. We help boards oversee compliance programs and meet CIA obligations. The assessment of prescribed penalties and exclusion for substantial breaches are governed by certain dispute resolution provisions. Dispute resolution provisions are explicitly referred to as contractual remedies, although these provisions refer to certain appeal procedures. Specifically, the supplier has the right to be heard before an ALJ and to file a complaint with the Department Appeals Board (DAB) under the terms of the CIA.

The dispute resolution provisions do not apply all the remedies. In addition, dispute resolution rules generally include supplier confirmation that a decision of the ALJ or ATM is not in dispute, as would be the case under the claim or settlement. Therefore, suppliers should seek legal assistance to assist in compliance with dispute resolution rules and to end their distinction with other regulatory rules. Choosing a correct IRO that meets the supplier`s requirements is a critical decision-making process that should not be taken lightly. All the problems that the OIG finds with the IRO will not invent well the organization and could deteriorate relations with the federal government. A CIA with an organization urged the OIG to question the integrity and commitment of the organization to compliance. This is fuelled by the requirement that an IRO be used as a guarantor of the organization`s compliance with the terms of the agreement. It is therefore important for the supplier to choose a company that has a strong and credible balance sheet as an IRO, which has specific sectoral expertise in its field of activity, is free of conflicts of interest or appearance, and assigns the right type of professional personnel to carry out CIA mandates. The CIA is an important tool in the Arsenal OIG to solve a fraud charge and settle a False Claims Act case without excluding the supplier or entity. The CIA should never be taken lightly by a supplier or organization concerned, given that there are several requirements described in the CIA, as well as the requirement for surveillance and reporting to the OIG. A CIA can be a useful resource for a health organization to improve its compliance if it is properly implemented and respected by the health organization.

As part of the CIA between HHS OIG and WellCare Health Plans, Inc., effective April 26, 2011, this managed care organization is required to name a compliance link to each of its seven major sites, which must be independent of the company`s legal department. In addition, some personnel (“certification officers”) are required to monitor and supervise activities under their jurisdiction and to submit an annually certificate certifying that the territory under their control complies with federal health program requirements and CIA requirements, and are not aware of any violations.