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Learn MoreHealthcare 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.
Download the article that summarizes learning from this HCCA Conference.
HealthStream’s learning management system and comprehensive suite of competency management tools empower your healthcare workforce to deliver the best patient care.
View All Learning & PerformanceHealthStream offers performance learning management solutions to help develop your healthcare staff into leaders and reduce turnover.
View All ProductsHealthStream works with healthcare organizations to create engaging and high-quality training videos for your staff and management.
View All ProductsImprove care quality and save money by making informed decisions about your healthcare facility and staff with HealthStream's reporting analytics solution.
View All ProductsHealthStream's proven methods for the improvement and overall engagement of your healthcare staff foster a positive workplace and increase retention rates.
View All ProductsWhen you enact HealthStream's quality compliance solutions, you can do so with the confidence your healthcare organization will meet all standards of care.
View All Quality & ComplianceBe confident in your staff’s ability to reduce risk by providing compliance training that changes behavior.
View All ProductsDevelop next-level people for next-level care by prioritizing quality and safety improvements.
View All ProductsStandardize policy and procedure management with an automated, customized, and centralized system.
View All ProductsEstablish a culture of belonging with education supporting DEI, wellness, engagement, and leadership development.
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View All ProductsLearn about our advanced resuscitation training solutions. Our solutions are designed to help improve patient outcomes.
View All ResuscitationIn all areas of resuscitation, from neonatal to elderly care, clinical deterioration is a risk that can be avoided with the help of HealthStream's training programs.
View All ProductsNurture the skills of your nurses and medical staff to help mold them into effective leaders with development training from HealthStream.
View All ProductsExpand the decision-making skills and effectiveness of your healthcare workforce with HealthStream's clinical development programs and services.
View All Clinical DevelopmentMake sure your clinicians have the support they need to provide competent care with clinical competency training and development from HealthStream.
View All ProductsHealthStream’s learning management system and comprehensive suite of competency management tools empower your healthcare workforce to deliver the best patient care.
View All ProductsThe suite of healthcare onboarding solutions available from HealthStream aids in nurse retention and improved patient outcomes.
View All ProductsGive your healthcare staff the decision support and skills training they need with the online products available from HealthStream.
View All ProductsHealthStream leverages medical professional development in healthcare by providing staff training programs
View All ProductsMake sure your healthcare staff can schedule out appointments and work schedules with ease using HealthStream's line of software solutions.
View All SchedulingHealthcare workforce management is essential. We provide advanced scheduling solutions for organizations to solve issues such as nurse retention
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