Corporate Integrity Agreements - Better to have than not.
Mark L. Rosen, Esquire
The Department of Health and Human Services may negotiate a corporate integrity agreement (CIA) as part of the settlement of Federal health care program investigations arising under federal statutes. Normally, a provider consents to these obligations in exchange for the the government's agreement not to seek an exclusion of that health care provider or entity from participation in Medicare, Medicaid and other Federal health care programs. Doctors who settle these cases often deny that they were liable or that they committed the alleged conduct.
The typical length of a CIA is five years. These compliance measures seek to ensure the validity of Federal health care program claims submitted by the provider. Hiring a compliance officer, appointing a compliance committee, developing written standards and policies, and implementing a comprehensive employee training program are all hallmarks of a good CIA. While many CIAs have boiler plate language, each agreement must address the specific circumstances of the matters at issue.
What is the lesson here? Each medical office should already have a CIA in place even before one is forced upon it. By implementing a thoughtful CIA, the problems and practices which may inadvertently lead to a violation of federal law can be preempted. And in the event of an investigation, you can prove to the government your "good faith" through the safeguards implemented in your CIA.