Corporate Integrity Agreement Reviews

The annual report describes all changes to the structure of the supplier`s compliance program and the level of resources allocated to the program. In addition, the annual report (1) contains a description of all audits, audits or analyses of the supplier`s compliance program; 2) the supplier`s response to these audits, audits or analyses; and a summary report on any overpayments repaid during the period. In addition, a supplier manager must certify that the supplier is complying with its obligations under the CIA`s corporate integrity provisions. i »Corporate Integrity Agreements. Work plan Reports and publications Inspector General U.S. Department of Health and Human Services. Available at: oig.hhs.gov/compliance/corporate-integrity-agreements/index.asp. In recent years, the Office of Inspector General (OIG) has « adapted » Corporate Integrity Agreements (CIAS) to target and prevent misconduct that has served as the basis for billing an organization or individual with the federal government. Some of these specialized ICAs are highlighted below: Although cumbersome and generally costly to comply with, OIG Corporate Integrity Agreements leads organizations to implement an effective public health compliance program, which ultimately leads to correct billing practices. These include submitting specific and comprehensive payment requests to federal health programs, appropriate agreements with physicians, and improving the quality of care provided to program recipients. Since the OIG Corporate Integrity Agreement is a contractual agreement between the OIG and a health organization requiring the organization to meet a defined set of compliance obligations, it is important to meet all conditions. Violations of the OIG Corporate Integrity Agreement and non-compliance with obligations under the agreement may result in severe penalties, including the possible exclusion of participation in federal public health programs. A first annual report should normally be submitted within 60 days of the first anniversary of the agreement`s entry into force. The « effective date » is generally defined in the agreement as a given date or the date on which the transaction agreement with the company integrity provisions was fully executed.

The supplier should carefully review the agreement to determine the exact date on which its annual report is due. Other annual reports to be submitted under the CIA must be submitted on each anniversary of the date of the original report. As a general rule, there are both on-site components and offsite components for the work of an IRO. On site, it is important to work to know first-hand how the business works. However, in cases where the necessary documents can be made available to the IRO in an appropriate and effective manner without consulting the supplier`s website, most of the IRO`s work can be done off-site. As a general rule, in a five-year CIA, where the GCG requires the maintenance of an IRO, it is stipulated that the IRO conducts a system or arrangement review for the first and fourth year.