Corporate integrity agreement

Last updated March 21, 2019

A corporate integrity agreement (CIA) is a document outlining the obligations that a company involved in health care in the United States makes with a federal government agency or a state government as part of a civil settlement. On the federal level the Office of Inspector General of the Department of Health and Human Services and the Department of Justice are usually involved, and on the state level, the state attorney general and the state offices involved in Medicaid or Medicare are involved.^[1]

Health care in the United States is provided by many distinct organizations. Health care facilities are largely owned and operated by private sector businesses. 58% of US community hospitals are non-profit, 21% are government owned, and 21% are for-profit. According to the World Health Organization (WHO), the United States spent $9,403 on health care per capita, and 17.1% on health care as percentage of its GDP in 2014. Healthcare coverage is provided through a combination of private health insurance and public health coverage. The United States does not have a universal healthcare program, unlike other advanced industrialized countries.

In law, a settlement is a resolution between disputing parties about a legal case, reached either before or after court action begins. The term "settlement" also has other meanings in the context of law. Structured settlements provide for future periodic payments, instead of a one time cash payment.

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CIA can be used to address quality of care ^[2] or corporate integrity issues.^[1]

Health care quality is a level of value provided by any health care resource, as determined by some measurement. As with quality in other fields, it is an assessment of whether something is good enough and whether it is suitable for its purpose. The goal of health care is to provide medical resources of high quality to all who need them; that is, to ensure good quality of life, to cure illnesses when possible, to extend life expectancy, and so on. Researchers use a variety of quality measures to attempt to determine health care quality, including counts of a therapy's reduction or lessening of diseases identified by medical diagnosis, a decrease in the number of risk factors which people have following preventive care, or a survey of health indicators in a population who are accessing certain kinds of care.

Corporate governance is the collection of mechanisms, processes and relations by which corporations are controlled and operated. Governance structures and principles identify the distribution of rights and responsibilities among different participants in the corporation and include the rules and procedures for making decisions in corporate affairs. Corporate governance is necessary because of the possibility of conflicts of interests between stakeholders, primarily between shareholders and upper management or among shareholders.

CIAs create a framework within which the company must operate in order to avoid being barred from participation in federal health care programs.^[1] States use CIAs as part of their anti-fraud efforts.^[3]^[4]^:9

CIAs generally last 5 years. During this time the provider is usually required to implement or expand a comprehensive employee training program, a confidential disclosure program, written standards and policies, and designate a compliance officer and committee if these things are not already done.^[5] CIAs also mandate establishing processes for managing and reporting “reportable events.” Reportable events include overpayments, ongoing investigations or legal proceedings, potential violation of criminal, civil, or administrative laws applicable to any Federal health care program for which penalties or exclusion may be authorized, and employing or contracting with an ineligible person.^[1]

Some CIAs require an independent organization to review and monitor compliance with the terms and conditions of the CIA. Most CIAs require claims reviews to identify errors and their underlying causes.^[1] The government agency may check compliance through site visits.^[1] If a company breaks the agreement, the agency can fine them and if issues cannot be resolved the provider may be barred.^[6]

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References

This article incorporates public domain material from the United States Department of Health and Human Services document "Corporate Integrity Agreements Snapshot" .Retrieved on 14 April 2018.

The United States Department of Health & Human Services (HHS), also known as the Health Department, is a cabinet-level department of the U.S. federal government with the goal of protecting the health of all Americans and providing essential human services. Its motto is "Improving the health, safety, and well-being of America". Before the separate federal Department of Education was created in 1979, it was called the Department of Health, Education, and Welfare (HEW).

1 2 3 4 5 6 "Corporate Integrity Agreement FAQ". Office of Inspector General, Department of Health and Human Services. Retrieved 14 April 2018.
↑ "Quality of Care: Corporate Integrity Agreements". Office of Inspector General, Department of Health and Human Services. Retrieved 14 April 2018.
↑ "Press release: Attorney General's Office Agrees To Settlement And Corporate Integrity Agreement With Keene Medical Products On Medicaid Fraud Investigation". Vermont Office of the Attorney General. 9 February 2016. Archived from the original on 23 December 2016.
↑ "Redacted Corporate Integrity Agreement between the New York State Office of the Medicaid Inspector General and Ralex Services, Inc" (PDF). New York State Office of the Medicaid Inspector General. April 2016. Retrieved 14 April 2018.
↑ "Corporate Integrity Agreements". Office of Inspector General, Department of Health and Human Services. Retrieved 14 April 2018.
↑ "Corporate Integrity Agreement Enforcement". Office of Inspector General, Department of Health and Human Services. Retrieved 14 April 2018.

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[OIGFAQ-1] 1 2 3 4 5 6 "Corporate Integrity Agreement FAQ". Office of Inspector General, Department of Health and Human Services. Retrieved 14 April 2018.

[2] "Quality of Care: Corporate Integrity Agreements". Office of Inspector General, Department of Health and Human Services. Retrieved 14 April 2018.

[3] "Press release: Attorney General's Office Agrees To Settlement And Corporate Integrity Agreement With Keene Medical Products On Medicaid Fraud Investigation". Vermont Office of the Attorney General. 9 February 2016. Archived from the original on 23 December 2016.

[4] "Redacted Corporate Integrity Agreement between the New York State Office of the Medicaid Inspector General and Ralex Services, Inc" (PDF). New York State Office of the Medicaid Inspector General. April 2016. Retrieved 14 April 2018.

[5] "Corporate Integrity Agreements". Office of Inspector General, Department of Health and Human Services. Retrieved 14 April 2018.

[6] "Corporate Integrity Agreement Enforcement". Office of Inspector General, Department of Health and Human Services. Retrieved 14 April 2018.