CIAs: Roadmap to a Compliance Officer’s Annual Work Plan?

Corporate Integrity Agreements (CIAs), which certain healthcare organizations enter into with the Office of Inspector General (OIG) of the U.S. Department of Health and Human Services (HHS), are typically part and parcel of a settlement agreement with government agencies to resolve allegations of wrongdoing or violations of law and to avoid exclusion from federal healthcare programs. Currently there are several hundred CIAs, including several “Quality CIAs” listed on the HHS OIG website.¹ Managing a compliance program under a CIA is one of the most significant challenges that a compliance officer can face. However, aside from the stresses and additional workload that CIAs typically trigger, CIAs can also serve as a catalyst for business improvements, provide suggestions for better controls, and bring positive changes to the corporate culture.

About the Author

Dr. Cornelia M. Dorfschmid has over 30 years of private and government sector experience in health care compliance consulting, the majority of which was in management and executive capacities. She is a recognized expert in the areas of claims auditing, overpayment analysis and risk management and corporate health care compliance.