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General Information
The Office of Inspector General (OIG) often
negotiates compliance obligations with health
care providers and other entities as part
of the settlement of Federal health care
program investigations arising under a variety
of civil false claims statutes. A provider
or entity consents to these obligations
as part of the civil settlement and in exchange
for the OIG'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. False
claims submitted in violation of the False
Claims Act or Civil Monetary Penalties Law
give rise to the OIG’s permissive exclusion
authority under 42 U.S.C.1320a-7(b)(7).
Providers who settle these cases often deny
that they were liable or that they committed
the alleged conduct.
The typical term of a comprehensive corporate
integrity agreement (CIA) is five years
(three years for national project cases).
These compliance measures seek to ensure
the integrity of Federal health care program
claims submitted by the provider. The more
comprehensive integrity agreements include
requirements to:
(1) Hire a compliance officer/appoint a
compliance committee;
(2) Develop written standards and policies;
(3) Implement a comprehensive employee
training program;
(4) Review claims submitted to Federal
health care programs;
(5) Establish a confidential disclosure
program;
(6) Restrict employment of ineligible persons;
and
(7) Submit a variety of reports to the
OIG.
While many CIAs have common elements, each
agreement addresses, in part, the specific
facts of the conduct at issue, and is tailored
to comport with the existing capabilities
of the provider. The integrity agreements
often attempt to accommodate and recognize
many of the elements of pre-existing voluntary
compliance programs.
To view the list of health care providers
and entities who are currently subject to
CIAs and settlement agreements with integrity
provisions, click here.
To view the full text of an
active CIA, simply double click on the name
of the entity listed in the CIA list.
Please note that settlement
agreements with integrity provisions are
not electronically available through this
web site. Rather, copies of such settlement
agreements may be obtained through a filing
a Freedom of Information Act (FOIA) request
with the United States Department of Justice.
Information on filing FOIA requests with
the Department of Justice may be obtained
through its web site, found at www.usdoj.gov
and selecting the FOIA section. This FOIA
request should be as specific as possible.
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