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Sep. 25, 2024

How Corporate Integrity Agreements Strengthen Compliance Programs at Healthcare Entities

  • David Hill
    Anti-Corruption Report
If a healthcare provider is investigated by the U.S. federal government, it may find itself negotiating a corporate integrity agreement (CIA) with the Department of Health and Human Services’ Office of the Inspector General (OIG). Generally, a healthcare entity enters into a CIA as part of a civil settlement, when it might otherwise be at risk of being excluded from a federal healthcare program such as Medicare or Medicaid. CIAs are similar to deferred prosecution agreements but have their own peculiarities. A panel during the Corporate Compliance Enforcement Conference, held by the Society of Corporate Compliance and Ethics, discussed recent shifts in OIG’s expectations for CIAs. This article distills the speakers’ insights. See “Implications of the Updates to the Pharmaceutical Research and Manufacturers of America Code” (Sep. 29, 2021).

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