Kusserow on Compliance: OIG announces changes in provisions in corporate integrity agreements

Free Upcoming Webinar! Compliance Accountability: Lessons Learned From Implementing Corporate Integrity Agreements

At the now-concluded Health Care Compliance Association (HCCA) conference, representatives of the HHS Office of Inspector General (OIG) spoke about the changing provisions in the OIG’s Corporate Integrity Agreements (CIAs). They provided an up-to-date perspective on the agency’s priorities and concerns, as well as what they individually believe is necessary for effective oversight and operational controls for health care organizations. Many of the provisions included in new CIAs have been included for many years, but there are also many evolving provisions that have been added. CIAs include a stipulated penalty for each day the organization is out of compliance with deadlines and a $50,000 penalty for each false certification. As with any representations to the government, any false certification may implicate the False Claims Act. Compliance Officers need to understand what CIA requirements are, in order to brief executive leadership and the Board on what is expected of them by the OIG. Failing to meet the obligations under the agreement can result in severe penalties, including possible exclusion of participation in federal health care programs.

Evolving provisions

The upcoming free webinar on Compliance Accountability: Lessons Learned From Implementing Corporate Integrity Agreements will address these evolving provisions in the CIAs and will be a great takeaway for use in educating executive leadership and Boards on what is expected of them in supporting and providing oversight for their Compliance Program. Register today!

Richard P. Kusserow served as DHHS Inspector General for 11 years. He currently is CEO of Strategic Management Services, LLC (SM), a firm that has assisted more than 3,000 organizations and entities with compliance related matters. The SM sister company, CRC, provides a wide range of compliance tools including sanction-screening.

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Copyright © 2017 Strategic Management Services, LLC. Published with permission.