Corporate Compliance

Self-reporting compliance violations could eliminate CIA

Compliance Monitor, April 23, 2008

Healthcare providers who voluntarily report possible compliance violations will have to submit additional information if they want to avoid corporate integrity agreements (CIA), according to an Open Letter to Health Care Providers from the Inspector General.

To avoid a CIA, a provider must disclose potential violations in good faith, fully cooperate with OIG, and provide requested information in a timely manner.

The Open Letter also sets forth four additional self-disclosure submission requirements:
  • A complete description of the conduct being disclosed
  • A description of the provider's internal investigation or a commitment regarding when it will be completed
  • An estimate of the damages to the federal healthcare programs and the methodology used to calculate that figure or a commitment regarding when the provider will complete such estimate
  • A statement of the laws potentially violated by the conduct

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