Healthcare is spending a lot of time thinking about ways to strengthen organizational compliance and prevent the imposition of a CIA whenever possible. A team of content experts from HCCS, A HealthStream Company, recently attended the Health Care Compliance Association’s 2018 Enforcement Conference, where some sessions focused on the changing approach to CIAs.
Anatomy of a Corporate Integrity Agreement
When discussing the government’s changing approach to Corporate Integrity Agreements (CIAs), The Office of Inspector General (OIG) discussed its Risk Spectrum at length. The OIG determines where every defendant is on the Risk Spectrum based on information it gathers during a healthcare fraud case.
The OIG uses this Risk Spectrum based on these criteria:
1. The nature and circumstances of the conduct
2. The conduct during the government investigation
3. The steps to ameliorate or mitigate an issue from the time they learned of the conduct
4. The history of the entity's compliance
If the provider is considered highest risk, then the OIG will exclude it from the federal healthcare programs for a specific length of time. No program payout will be made to an excluded person/entity during the exclusion period. One speaker referred to being excluded from the federal healthcare programs as a financial death sentence.
Currently, the OIG posts a provider's details as well as the actual CIA document on their website. As of October 2018, the OIG posts details about those who refuse a CIA (search High Risk – Heightened Scrutiny). When a provider refuses a CIA, the OIG will do unilateral monitoring—monitor the provider absent a CIA.
One thing that was mentioned in more than one session was that Compliance Officers are often happy when their organization gets a CIA because the Compliance Officer can then use the CIA as leverage to get the resources and attention needed from senior management. The speakers mentioned that some organizations get rid of all compliance staff once a CIA ends. They both stressed the importance of maintaining the culture of integrity after a CIA ends.
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