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What is the Difference between Corporate Integrity Agreements and Certificates of Compliance Agreements?
Healthcare fraud investigations by the Office of Inspector General (OIG) often result in the OIG engaging in a Corporate Integrity Agreement (CIA) with the subject of the investigation. What about Certificates of Compliance Agreements (CCA)? This article will explain the difference between a CIA and CCA and the common components found in the agreements.
A CIA is when the OIG negotiates a deal as part of a civil agreement with the healthcare provider or healthcare organization under the federal civil false claims act. The alleged wrongdoers consent to adhere to certain conditions under the agreement in exchange for not being excluded from participating in federal programs. According to the OIG, the typical CIA lasts approximately 5 years and contains the following conditions [1]:
- hire a compliance officer/appoint a compliance committee;
- develop written standards and policies;
- implement a comprehensive employee training program;
- retain an independent review organization to conduct annual reviews;
- establish a confidential disclosure program;
- restrict employment of ineligible persons;
- report overpayments, reportable events, and ongoing investigations/legal proceedings; and
- provide an implementation report and annual reports to OIG on the status of the entity's compliance activities.
You can find all of the recent CIAs or you can search for CIAs alphabetically by the name of the provider or entity that entered into the agreement.[2] OIG also engages in Quality of Care CIAs when fraud allegations impact patient harm.[3]
So what is the difference between a CIA and CCA? According to the OIG:
The terms of a CCA include a requirement that the entity maintain its existing compliance program, as described in a Declaration that is attached to the CCA. In addition, the entity is required to agree to certain compliance obligations that mirror those found in a comprehensive CIA, including:
(1) reporting overpayments, reportable events, and ongoing investigations and legal proceedings to the OIG; and
(2)providing annual reports regarding the entity's compliance activities to OIG during the term of the CCA.
Examples of CCAs can be found on the OIG site along with the CIAs.[4,5] More information on CCAs and CIAs can be found here: http://oig.hhs.gov/compliance/corporate-integrity-agreements/index.asp. It is recommended that investigators and auditors become aware of the various providers and entities that entered into any of these agreements with the OIG as well as the allegations that led to the settlements.
If you need assistance with researching settlements with the OIG, please do not hesitate to contact us at info@hcfraudshield.com.
[1] About CIAs
[2] Searching for CIAs
[3] Quality of Care CIAs
[4] Example CCA
[5] Example CIA
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