5 Challenges When Entering into a CIA: A Quick Guide

A Corporate Integrity Agreement (CIA) is issued by the Office of the Inspector General (OIG) to improve the quality of health care and to promote compliance with regulations. CIAs combat fraud committed by health care organizations and are issued when a health care organization acknowledges improper or fraudulent actions.

Essentially, organizations under a CIA have entered into a settlement with the government that they will uphold the details of the agreement in exchange that the OIG not exclude them from Medicare, Medicaid, or other Federal health care programs.

Most organizations entering into a CIA are faced with the decision to either shut their doors or buckle up for a potentially bumpy 5-year process to get the organization back on track. Since the OIG reserves the right to impose additional sanctions should the organization breach the CIA, it is vital that organizations understand these 5 key challenges upon entering a CIA to ensure smooth and successful fulfillment of the agreement.

1. Speedy Implementation

The average implementation period of a CIA has a window of only 120 days, so your team will need to act fast. If you quickly take initiative to start the CIA, your organization will be more successful working within the agreement’s parameters.

2. Who is Involved?

There are two main groups to consider:

“Covered Persons” is a term to identify which individuals and entities are subject to CIA requirements

• Tip: You must also maintain a screening regime for Covered Persons against the HHS/OIG List of Excluded Individuals/Entities (LEIE)

“Relevant Covered Persons” or “Arrangement Covered Persons” represents the individuals whose job responsibilities relate more specifically to the CIA’s focus.

While these “Persons” are normally straightforward, that’s not always the case. For instance, if you work with a wide number of contractors, subcontractors, and vendors without a formal structure, the identification of “Covered Persons” can get complicated very quickly.

3. Training

Initial and annual training are typically a must and may be competency-based. The goal is to make sure that Covered Persons reach a specific level of knowledge in a defined area, and can then prove what they have learned as a result of the training. Make sure the education you provide your stakeholders speaks to them.

4. Signatures

You’re going to need some autographs.

First, certain employees will sign certifications stating that they understand the requirements of the CIA and how their job responsibilities fit, and that they are fulfilling those requirements.

Second, every Board member will sign a resolution statement attesting that the organization is meeting the obligations of the CIA, and also carrying out a compliance program of their own.

5. Tracking and Reporting

Tracking and reporting will be vital to be compliant with the agreement. Paper and spreadsheets are not going to cut it. Ensure that you have a system in place that will meet the demands of internal and external monitoring, which may include risk assessments and corrective action plans.