Are OIG Corporate Integrity Agreements Enforced?

Thomas Herrmann | March 2017

Recent OIG Activity Highlights the Importance of Making Sure All Obligations of a CIA are Carried Out

For over 20 years, the Office of Inspector General (OIG) in the U.S. Department of Health and Human Services (HHS) has entered into corporate integrity agreements (CIAs) with health care corporations, providers, and other health care-related entities. In most instances, a CIA is part of a “global settlement” of outstanding criminal, civil, and administrative charges faced by a health care organization. A CIA is essentially a contract pursuant to which a health care organization agrees to assume specified compliance obligations in exchange for the OIG’s commitment to not exclude it from participatio

About the Author

Thomas Herrmann advises health care clients on compliance and regulatory matters, with a focus on development and management of effective health care compliance programs. Mr. Herrmann is a recognized expert on issues related to the federal Anti-Kickback Statute, Stark Law and the False Claims Act.