The national Health Care Fraud and Abuse Control Program which is jointly managed by the U.S. Attorney General and the Secretary of the Department of Health and Human Services authorizes the Office of the Inspector General of the United States (OIG) to enter into Corporate Integrity Agreements (CIA) with hospitals and physicians who have been investigated and found in violation of a variety of civil false claims statutes. The OIG examines information submitted by providers to determine whether their compliance processes are appropriate and can identify problems and create a method for corrective action. When the OIG determines action is necessary they impose sanctions in the form of stipulated penalties or exclusions however, when a provider or entity enters into a CIA the OIG agrees not to seek their exclusion from participation in Medicare, Medicaid, or other Federal health care programs.
Every CIA has many of the same stipulations but each one addresses the specific issues identified. A quality-of-care CIA typically lasts 5 years and includes requirements to:
- hire a compliance officer/appoint a compliance committee;
- develop written standards and policies;
- implement a comprehensive employee training program;
- retain an independent review organization (IRO) 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. ①
The OIG website contains copies of current Corporate Integrity Agreements (CIA) and Certification of Compliance Agreements. http://oig.hhs.gov/fraud/cia/cia_list.asp
According to the Fiscal Year 2015 Work Plan, the OIG estimated that the government would recover more than $4.9 billion due to their investigations plus an estimated additional savings of approximately $15.7 billion for FY 2014. In the report it was also noted that 4,017 individuals and entities were excluded from participation in Federal health care programs; 971 criminal actions were taken against individuals or entities; and 533 civil actions were taken. The civil actions include false claims and unjust-enrichment lawsuits filed in Federal district court, CMP settlements, and administrative recoveries related to provider self-disclosure matters. The funding and authority for the OIG investigations and reviews are supported under the Patient Protection and Affordable Care Act of 2010 and the American Recovery and Reinvestment Act of 2009. ②
Source:
- http://oig.hhs.gov/compliance/corporate-integrity-agreements/index.asp
- Work Plan Fiscal Year 2015; OIG U.S. Department of Health and Human Services, October 20, 2014.
Cardiovascular Peer Review, LLC
Cardiovascular Peer Review LLC (CPR) is an Independent Review Organization specializing in cardiovascular services with the mission to provide an unbiased external review service to fulfill the needs of hospitals and physicians who need to comply with the oversight requirement of a Corporate Integrity Agreement (CIA) or similar reviews as mandated by the U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) or other regulatory body.