HEALTH CARE COMPLIANCE 1 (HEALTH INFORMATION MANAGEMENT)
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Chapter_7_-_CIA-1.pptxChapter 7
Corporate Integrity Agreements
How agencies discover non-compliance events
Function of “corporate integrity agreements”
Criteria for offering a CIA to a provider
Key provisions of a typical CIA
Dealing with “ineligible persons”
Handling a “reportable event”
Penalties for failure to carry out a CIA
Role of an “independent review organization”
Learning Objectives
A Corporate Integrity Agreement (CIA) is a tool used by the OIG to enforce fraud and abuse laws.
It is negotiated as part of a settlement between the OIG and a provider who has committed fraudulent acts.
Introduction
The OIG agrees not to seek the provider’s exclusion from federal health care programs.
If the provider then breaches the CIA, the OIG will impose penalties and program exclusion on the provider.
Introduction
Disgruntled employees
Physicians and patients
Contractors, vendors, or competitors
False Claims Act qui tam lawsuits
Medicare fiscal intermediaries and carriers
Medicare Strike Force, Senior Medicare Patrol
Recovery Audit Contractors
Self-reporting by health care organizations
Sources of Information on Provider Non-Compliance
Provider self-disclosed the misconduct
Amount of monetary damage to federal programs
Provider still participating in federal programs
Issue of successor liability is present
Alleged misconduct might be repeated
Age of the alleged misconduct
Provider has an effective compliance program
OIG Criteria for Offering a CIA
5-year term
OIG monitors implementation of each CIA
Include 7 elements of traditional compliance program
No employment of or contract with ineligible persons (excluded from federal programs)
Notify OIG of criminal or fraudulent activities
Prompt repayment of overpayments
Common Provisions of a CIA (I)
Changes to business units or locations
Annual reports on status of implementation
OIG right to inspect documents, conduct on-site reviews, and interview employees and agents
Maintain records and documents for 6 years
Stipulated penalty of $2,500/day for CIA breaches
Common Provisions of a CIA (II)
8
Appendix on independent review organizations (IRO)
Appendix on annual claims reviews to be performed by an IRO
Common Provisions of a CIA (III)
9
Preamble
Term and scope of the CIA
Corporate integrity obligations
Compliance Officer and Committee
Written standards
Training and education
Review procedures
Text Review of a Typical CIA (I)
Disclosure program
Ineligible persons
Notification of government investigation or legal proceedings
Repayment of overpayments
Reportable events
Changes to business units or locations
Text Review of a Typical CIA (II)
Implementation and annual reports
OIG inspection, audit, and review rights
Document and record retention
Disclosures
Breach and default provisions
Appendices
Independent Review Organization
Claims review
Text Review of a Typical CIA (III)
