Compliance Integrity Agreement
iiiDepartment of health and social services. „A roadmap for new laws against physician fraud and abuse.“ | Routing Reports and publications | Office of the Inspector General | U.S. Department of Health and Human Services. Available at: oig.hhs.gov/compliance/physician-education/01laws.asp. The Office of the Inspector General has sometimes negotiated a Compliance Certification Agreement (CCA) with healthcare providers and other institutions in appropriate circumstances instead of a Comprehensive Corporate Integrity Agreement (CIA). The terms of a CCA always include the requirement that the company maintain its existing compliance program. The organization must accept a declaration regarding its compliance program attached to the CCA. The elements of the compliance program that must be completed reflect those contained in the OIG`s compliance guides for the business sector. The Company is also required to accept certain compliance obligations equivalent to those of a full CIA, including: (1) reporting to the Office of the Inspector General of overpayments, reportable events, and ongoing investigations and legal proceedings; and (2) provide annual reports on the Corporation`s compliance activities to the Office of the Inspector General during the term of the CCA. DHHS`s Office of the Inspector General (OIG) negotiates Corporate Integrity Agreements (AIAs) with health care providers and other entities as part of the settlement of investigations into federal health programs under various civil laws. The CIA describes the obligations that a company accepts in exchange for approval from the Office of the Inspector General that it will not seek to exclude the company from participation in Medicare, Medicaid, or other federal health programs. CIAs have common elements, but each is tailored to the specific facts of the case, and ACIs are often designed to recognize elements of an already existing compliance program.
BKD can help you train your compliance committee, employees, management, board members and physicians on compliance issues. Examples of training include fraud and abuse, current industry developments, the effectiveness of compliance programs, board leadership and corporate responsibility, as well as coding and billing issues. The expertise in strategic management as a compliance consulting firm in the healthcare sector makes us uniquely qualified to be a compliance expert for the Board of Directors. Our health consultants have acted as independent compliance experts for boards of directors of CIA health organizations. We support boards of directors in their oversight of compliance programs and in meeting CIA obligations. Some ICAs require an independent organization to verify and monitor compliance with the conditions of the ICA. Most CCAs require claims checks to identify errors and underlying causes. [1] The government agency may verify compliance through site visits. [1] If a company breaks the agreement, the agency can impose a fine and if the problems cannot be resolved, the supplier can be blocked. [6] Business integrity agreements have many common elements, but each takes into account specific facts and often seeks to review and recognize many of the elements of existing voluntary compliance programs, including, but not limited to: When the government finds illegal practices or finds actual misconduct (p.B.
fraud of a federal health program), a civil law comparison may be between the U.S. government and a supplier to resolve allegations of fraud and abuse or other criminal offenses arising under applicable laws. A government regulation usually comes with a civil fine and a set of conditions that set out the specific legal obligations and requirements that the supplier must meet. Depending on the nature of the allegations and the findings of the investigation, the OIG may, in its sole discretion, choose to enter into an agreement with a supplier accused of misconduct and negotiate a number of legal obligations that the supplier must comply with, such as, .B a Corporate Integrity Agreement (CIA) or an Integrity Agreement (IA). The Business Integrity Agreement (CIA) specifies the period of time allowed for the selection and reporting of the IRO to the Office of the Inspector General. Most agreements provide for this to happen within 60 to 90 days of the DATE the CIA goes into effect. A Corporate Integrity Agreement (CIA) is a document that describes the obligations that a company operating in the U.S. health care sector enters into with a federal agency or state government as part of a civil settlement.
At the federal level, the Office of the Inspector General of the Department of Health and Human Services and the Department of Justice are usually involved, and at the state level, the Attorney General and state offices involved in Medicaid or Medicare are involved. [1] We can measure the effectiveness of your healthcare organization`s enterprise compliance program, conduct risk assessments, perform organizational SWOT analysis, and make recommendations to your organization to improve your compliance program. BKD has developed specific tools to help organizations evaluate the effectiveness of their programs. These tools include questionnaires, checklists, surveys and other forms designed to identify compliance gaps and gaps. ICA can be used to address quality of care[2] or business integrity issues. [1] BKD National Health Care Group supports healthcare organizations with enterprise compliance services since healthcare fraud and abuse became a major issue. Our consultants teach compliance at conferences and seminars, write articles published in national journals, and advise organizations across the country. We`ve also developed innovative compliance tools and approaches to help businesses stay away from hot water. Each service can be tailored to your specific needs. CIS requires practitioners to implement certain elements of the compliance program. engage an independent third party, known as an IRO, or an independent review body, to conduct quarterly audits; and submit regular reports in accordance with the terms of the contract. ACEs also include violation and default provisions under which the Office of the Inspector General can impose sanctions for non-compliance with CIA conditions.
In addition, an organization is generally required to submit a written report to the Office of the Inspector General shortly after the completion of an CIA in order to keep the Office of the Inspector General informed of the status of its implementation of CIA requirements. This report is often referred to as an implementation report. After that, the organization must submit an annual report to the Office of the Inspector General on compliance with CIA requirements for each reporting period. Choosing the right IRO is a crucial decision. The company must not only ensure that the IRO can meet the requirements set out in the CIA, but also that the IRO is one with which it can successfully cooperate. Choosing the wrong IRO can lead to five very painful years that require more corporate personnel dedicated to CIA compliance and ultimately cost the company more money. The scope of work is defined by the Corporate Integrity Agreement and depends on the substantive issues contained in the original agreement with the U.S. government. Most agreements cover one or more areas, for example agreements.
B with referral sources, marketing practices, claims processes and cost reporting. .