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Corporate Integrity Agreements

Washington

Good compliance efforts and self-disclosure of misconduct can carry a lot of weight toward lessening the impact on providers under the Department of Health and Human Services' Office of Inspector General corporate integrity agreements, according to a report from the OIG.

The OIG wanted to determine the extent to which health care providers' existing compliance efforts and self-disclosure of misconduct influenced the OIG's decision to require a CIA or modify specific terms. The OIG found that “significant and appropriate modifications” were made to CIAs if health care providers had established compliance programs and made disclosures of misconduct to the government.

If a provider showed good compliance efforts and was cooperative with the government, two significant modifications were made in the CIA, the OIG found: A reduction in the term of the agreement from the usual five-year time period to three years; and a reduction of the role of the independent review organization in those cases in which the provider was able to demonstrate that it had an established system of internal audits.

For a complete copy of the OIG's findings, go to http://os.dhhs.gov/progorg/oig/cia/assessment.htm.

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