About Corporate Integrity Agreements
OIG negotiates corporate integrity agreements (CIA) with health care entities as part of the settlement of Federal health care program investigations arising under a variety of civil false claims statutes.
Use the CIA search page to browse, search and filter on both active and closed agreements, as well as entities under Heightened Scrutiny. Agreement listings are removed 10 years after their effective date and Heightened Scrutiny entries are removed after 10 years.
What are CIAs?
CIAs may be used as part of a negotiated resolution involving alleged fraud against the Federal health care programs. CIAs aim to strengthen an entity’s compliance program and promote compliance so that future issues can be prevented or identified, reported, and corrected. OIG does not seek a CIA in every case. For more information see: 1128(b)(7) Exclusion Criteria.
What's in a CIA?
Agreements have many common elements, but each one addresses the specific facts at issue and includes requirements to:
- hire a compliance officer and appoint a compliance committee;
- develop written standards and policies;
- implement a comprehensive employee training program;
- retain an independent review organization to conduct reviews;
- establish a confidential disclosure program;
- restrict employment of ineligible persons;
- report overpayments, reportable events, and ongoing investigations and legal proceedings; and
- provide an implementation report and annual reports to OIG on the status of the entity's compliance activities.
Breach and default provisions are also included and allow OIG to impose certain monetary penalties (referred to as Stipulated Penalties) for the failure to comply with the CIA. A material breach of the CIA constitutes an independent basis for the entity's exclusion from participation in the Federal health care programs. Information regarding OIG's enforcement actions under CIAs is available here.
What's the duration of an agreement?
A CIA lasts 5 years.
About Quality-of-Care Agreements
Quality-of-Care CIAs specifically address situations where the alleged fraud or abuse has impacted the quality of patient care and require providers to take specific actions to improve and monitor the quality of care they provide.
The goal is to ensure that healthcare providers maintain high standards of patient care and prevent future instances of substandard care.
A key component of these CIAs is the involvement of independent quality experts. These experts serve as independent monitors. They review the provider's delivery of care and evaluate the provider's ability to prevent, detect, and respond to patient care problems.
Interested in becoming an Independent Quality Monitor?
If you or your organization is interested being an independent quality monitor, please see the OIG's Federal Register Notice for Potential Monitors for Quality-of-Care Corporate integrity Agreements.