Thursday, February 4, 2016

Check Out OIG’s Newly Updated List of Corporate Integrity Agreements to Understand Recent Compliance Issues

In keeping up on the latest compliance issues, reporting issues, and the government's view on health care law issues, one of a health care lawyer's regular tasks is to review the latest compliance agreements reached by Office of Inspector General (OIG) for Health and Human Services. 

OIG negotiates corporate integrity agreements (CIA) with health care providers and other entities as part of the settlement of Federal health care program investigations arising under a variety of civil false claims statutes. Providers or entities agree to the obligations, and in exchange, OIG agrees not to seek their exclusion from participation in Medicare, Medicaid, or other Federal health care programs. This is also usually part of an agreement not to pursue or file criminal charges.

We also have clients review them in order for them to understand the government's view on various business practices in health care. If your business is interested, here is the OIG's posted list of corporate integrity agreements.  They are in PDF and can be downloaded and reviewed. 

CIAs have many common elements, but each one addresses the specific facts at issue and often attempts to accommodate and recognize many of the elements of preexisting voluntary compliance programs.

A comprehensive CIA typically lasts 5 years and includes requirements to:
 1. hire a compliance officer/appoint a compliance committee;
 2. develop written standards and policies; 
 3.  implement a comprehensive employee training program; 
 4.  retain an independent review organization to conduct annual reviews; 
 5.  establish a confidential disclosure program; 
 6.  restrict employment of ineligible persons; 
 7.  report overpayments, reportable events, and ongoing investigations/legal proceedings;      and 
 8.  provide an implementation report and annual reports to OIG on the status of the entity's compliance activities.

Keep compliant and make sure that your health care entity does not end up on this list.

Posted by Tracy Green, Esq. 


DISCLAIMER: Green & Associates' articles and blog postings are prepared as a service to the public and are not intended to grant rights or impose obligations. Nothing in this website should be construed as legal advice. Green & Associates' articles and blog postings may contain references or links to statutes, regulations, or other policy materials. The information provided is only intended to be a general summary. It is not intended to take the place of either the written law or regulations. We encourage readers to review the specific statutes, regulations, and other interpretive materials for a full and accurate statement of their contents and contact their attorney for legal advice. The primary purpose of this website is not the commercial advertisement or promotion of a commercial product or service and this website is not an advertisement or solicitation. Anyone viewing this web site in a state where the web site fails to comply with all laws and ethical rules of that state, should disregard this web site.

The information provided on this website is for informational purposes only. It is not intended to create, and does not create, a lawyer-client relationship with Green & Associates, Attorneys at Law. Sending an e-mail to Tracy Green does not contractually obligate them to represent you as your lawyer, or create any type of client relationship. No attorney-client relationship will be formed absent a written engagement or retainer letter agreement signed by both Green & Associates and client and which specifies the scope of the engagement.

Please note that e-mail transmission is not secure unless it is encrypted. E-mail messages sent to Ms. Green should not include confidential or sensitive information.