Fraud and abuse settlements in the healthcare industry are continuing to be reached at a record pace, and there are no signs that things will be slowing down in the near future. A critical role of healthcare compliance officers is to educate their organizations’ leadership and boards on the risks of not being compliant with all of the confusing rules and regulations in today’s marketplace. Non-compliance can lead to fines and penalties associated with the STARK II regulations, the federal Anti-Kickback Statute, the False Claims Act, and other mandates. Another aspect of the government’s reaction to an identified provider’s non-compliant behavior and action is the establishment of a corporate integrity agreement (CIA) between the provider and the U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) as the framework for a probationary period.
The OIG negotiates CIAs with healthcare providers as part of its settlement of federal healthcare program investigations. Providers or entities agree to the obligations, and in exchange, OIG agrees not to seek their exclusion from participation in Medicare, Medicaid, or other federal healthcare programs.
As a chief compliance officer who has taken two organizations through the process of arranging CIAs, I thought it would be valuable to outline the standard obligations required and suggest how a compliance officer might use them to benefit his or her educational efforts.
CIAs have many components that follow closely the elements of a model voluntary compliance program. In addition, there are specific obligations that may be associated with the particular violation(s) that led to the settlement of the investigation. A typical CIA lasts five years and usually includes the following requirements that a provider:
Compliance officers should be aware of and consistently communicating to their colleagues the significant expense and time commitment that is usually associated with the implementation of a CIA, and the ongoing management required. For example, the retention of an independent review organization can carry with it a surprisingly high price tag.
Keep in mind also that many recent CIAs require numerous individuals to certify to the OIG the accuracy and completeness of the content of implementation and annual reports. Traditionally, this potentially stressful obligation was placed only upon the compliance officer and the CEO, but today many CIAs require certification statements from the CFO, senior leadership, all board members, billing leadership, physician leadership, etc. This change marks a great opportunity for compliance officers to educate their audiences on the importance of avoiding a CIA. Here is an example of the type of content included in a CIA certification:
“I have been trained on and understand the compliance requirements and responsibilities as they relate to (insert name of department), an area under my supervision. My job responsibilities include ensuring compliance with regard to the (insert name of department) with all applicable federal healthcare program requirements, obligations of the corporate integrity agreement, and xxxx policies, and I have taken steps to promote such compliance. To the best of my knowledge, except as otherwise described herein, the (insert name of department) of xxxx is in compliance with all applicable federal healthcare program requirements and the obligations of the corporate integrity agreement. I understand that this certification is being provided to and relied upon by the United States.”
Sharing this information probably will get the attention of those who are not very interested in your compliance program.
I would also advise that organizations consider utilizing elements of the standard CIA, such as how to manage physician arrangements and focus arrangements, as an opportunity to establish best practices. Most CIAs that include an obligation to oversee contract arrangements provide very prescriptive steps to help assure compliance with STARK II and the Anti-Kickback Statute.
Many organizations are rightfully fearful of the expense and time associated with a CIA. Today’s compliance officers should continually utilize the threat of a CIA as a major component of their ongoing compliance education efforts to validate that their compliance program has all necessary resources to protect their organization from risk of fraud and abuse.
Given the vast quantity of information published by the federal government, Medicare Administrative Contractors (MACs), consultants, and others, it can be easy to lose track
Recent updates to the Health Insurance Portability and Accountability Act (HIPAA) represent the most significant shift in healthcare privacy and security requirements in over a
Please log in to your account to comment on this article.
Uncover essential coding insights with nationally recognized coding authority Kay Piper, RHIA, CDIP, CCS. Through ICD10monitor’s interactive, on‑demand webcast series, Kay walks you through the AHA’s 2026 ICD‑10‑CM/PCS Quarterly Coding Clinics, translating each update into practical, easy‑to‑apply guidance designed to sharpen precision, ensure compliance, and strengthen day‑to‑day decision‑making. Available shortly after each official release.
Uncover critical guidance on the ICD-10-CM/PCS code updates. Kay Piper reviews and explains ICD-10-CM/PCS coding guidelines in the AHA’s fourth quarter 2026 ICD-10-CM/PCS Coding Clinic in an easy to access on-demand webcast.
Uncover critical guidance on the ICD-10-CM/PCS code updates. Kay Piper reviews and explains ICD-10-CM/PCS coding guidelines in the AHA’s third quarter 2026 ICD-10-CM/PCS Coding Clinic in an easy to access on-demand webcast.
Uncover critical guidance on the ICD-10-CM/PCS code updates. Kay Piper reviews and explains ICD-10-CM/PCS coding guidelines in the AHA’s second quarter 2026 ICD-10-CM/PCS Coding Clinic in an easy to access on-demand webcast.
Federal auditors are intensifying their focus on inpatient psychiatric facilities, using advanced data analytics to spotlight outliers and pursue high‑dollar repayments. In this high‑impact webcast, Michael Calahan, PA, MBA, Compliance Officer and V.P., Hospital & Physician Compliance, breaks down what regulators are really targeting in IPF-PPS admissions, documentation, treatment and discharge planning. Attendees will learn practical steps to tighten processes, avoid common audit triggers and protect reimbursement and reduce the risk of multimillion-dollar repayment demands.
In this timely session, Stacey Shillito, CDIP, CPMA, CCS, CCS-P, CPEDC, COPC, breaks down the complexities of Medical Decision Making (MDM) documentation so providers can confidently capture the true complexity of their care. Attendees will learn practical, efficient strategies to ensure documentation aligns with current E/M guidelines, supports accurate coding, and reduces audit risk, all without adding to charting time.
Join Ronald Hirsch, MD, FACP, CHCQM for The PEPPER Returns – Risk and Opportunity at Your Fingertips, a practical webcast that demystifies the PEPPER and shows you how to turn complex claims data into actionable insights. Dr. Hirsch will explain how to interpret key measures, identify compliance risks, uncover missed revenue opportunities, and understand new updates in the PEPPER, all to help your organization stay ahead of audits and use this powerful data proactively.
Stay ahead of the 2026-2027 audit surge with “Top 10 Audit Targets for 2026-2027 for Hospitals & Physicians: Protect Your Revenue,” a high-impact webcast led by Michael Calahan, PA, MBA. This concise session gives hospitals and physicians clear insight into the most likely federal audit targets, such as E/M services, split/shared and critical care, observation and admissions, device credits, and Two-Midnight Rule changes, and shows how to tighten documentation, coding, and internal processes to reduce denials, recoupments, and penalties. Attendees walk away with practical best practices to protect revenue, strengthen compliance, and better prepare their teams for inevitable audits.
Happy National Doctor’s Day! Learn how to get a complimentary webcast on ‘Decoding Social Admissions’ as a token of our heartfelt appreciation! Click here to learn more →
CYBER WEEK IS HERE! Don’t miss your chance to get 20% off now until Dec. 1 with code CYBER25
CYBER WEEK IS HERE! Don’t miss your chance to get 20% off now until Dec. 2 with code CYBER24
