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Ensure proper resources when working under a CIA

Compliance Monitor, February 8, 2006

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Working under a corporate integrity agreement (CIA) can be incredibly difficult, requiring additional staff, time, and money, says Bob Wade, a partner at law firm Baker & Daniels, LLP, in South Bend, IN.

A CIA can cost the average-sized hospital (300-500 beds) about $500,000 in the first year of a typical five-year agreement, says Wade. Those costs are mostly due to the additional staff needed to keep up with the deadlines and demands of the CIA. When an organization is put under a CIA, it should make sure that it has the necessary resources to meet the demands of the agreement.

The organization should hire an independent review organization (IRO), which may be a law, billing, or consulting firm, depending on the CIA's subject, says Wade. They should also hire an integrity officer if it doesn't have one already. Additional secretarial staff should also be devoted to the effort.

"When talking with clients under CIAs, probably the biggest struggle [they face] is the lack of support staff," says Wade. There is a lot of paperwork and deadlines to coordinate, so it's critical to ensure that staff can get the job done. This tip is an excerpt from Strategies for Health Care Compliance.

Editor's note: If you have a tip that you would like to share with your compliance peers, please send it to Compliance Monitor Editor Kelly Bilodeau and we'll publish it in a future issue of Compliance Monitor.

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