Corporate Integrity Agreement Support

If your organization is in the process of negotiating, implementing, or managing a Corporate Integrity Agreement (CIA), Strategic Management can provide expertise to help you comply with CIA obligations. We have extensive experience with CIA compliance with federal health care regulations and can help organizations across the health care industry meet important CIA deadlines and requirements.

Corporate Integrity Agreements are documents outlining the obligations that a health care sector company makes with the DHHS Office of Inspector General as part of a civil settlement. The Agreement create a framework within which the company must operate to avoid being barred from participation in federal health care programs. They generally last 5 years, during which time the provider must implement or expand a comprehensive compliance program and mandate establishing processes for managing and reporting “reportable events,” such as overpayments and potential violation of law. Most CIAs require an Independent Review Organization to review and monitor compliance with the terms and conditions of the CIA.

CIA Implementation

Strategic Management assists Compliance Officers with implementation of CIA elements and obligations, and helps manage key deadlines to ensure CIA compliance. This includes drafting and executing compliance policies and procedures, executing required training plans and developing training material, establishing a disclosure program and other required actions according to mandated timelines.

Compliance Expert to the Board

Strategic Management’s expertise as a health care compliance consulting firm makes us uniquely qualified to be a compliance expert to the Board of Directors. Our health care consultants have served as an independent compliance expert to Boards of Directors of health care organizations under a CIA. We assist Boards in their oversight responsibilities of compliance programs and in meeting CIA obligations.

This includes:

  • Conducting compliance program effectiveness assessments;
  • Providing findings and recommendations for program improvements; and
  • Conducting training on Board governance responsibilities, compliance and regulatory.