Corporate Integrity Agreement Representation
A Corporate Integrity Agreement (CIA) is a document outlining the obligations a corporate provider agrees to as part of a civil settlement. CIAs are an effective enforcement tool used by the U.S. Department of Health and Human Services, Office of Inspector General (HHS-OIG), and the Department of Justice (DOJ) to fight healthcare fraud, waste, and abuse. The government often uses CIAs to address quality of care and program integrity issues.
If your organization enters into a CIA with the U.S. government, Consolidated Compliance can assist you in effectively meeting the obligations of the settlement. The term of a CIA is typically five years and includes such requirements as hiring a compliance officer, appointing a compliance committee, implementing (and documenting) a training program, developing written standards and policies, establishing a confidential disclosure program, restricting employment of ineligible persons, and reporting overpayments, reportable events, and any ongoing investigations. In addition, CIAs require the hiring of an Independent Review Organization (IRO) to review and monitor compliance with the terms and conditions of the CIA.
Every CIA contains breach and default provisions that are triggered for the failure to comply with any of the obligations set forth in the Agreement. Monetary penalties (Stipulated Penalties) can be imposed when a breach occurs. Consolidated Compliance can help reduce the concern of Stipulated Penalties by helping your organization ensure that the requirements of the CIA are met timely and thoroughly.
