As a general rule, when your health organization is in contact with the DOJ, it must enter into a contract with an independent auditing body (IRO) to allow for independent verification that your organization is complying with CIA requirements. BKD serves as an IRO for organizations by combining knowledge and expertise in corporate integrity agreements, compliance operations, and coding and billing audits to deliver cost-effective and proven results that meet CIA requirements. BKD consultants have developed tools to help health care providers develop an effective and personalized compliance program. Our approach includes guidelines for OIG model compliance programs and regulatory developments. We can audit your compliance document, recommend improvements and design the revised compliance plan to reflect OIG compliance guidelines and other recommended provisions. If your company has committed a compliance breach and needs to enter into a Corporate Integrity Agreement (CIA), we can help you design compliance organization structures and compliance processes to reduce the risk of recurring violations and meet CIA requirements. A CIA is usually entered into in connection with a civil agreement between the U.S. government and a health care provider or health organization under the False Claims Act, or when an organization has been convicted of defrauding the Centers for Medicare and Medicaid Services (CMS) or any other federal health program. The CIA is negotiated and monitored through the office of the Attorney General of the Department of Health and Human Services.
The agreements must be consistent with the 1995 federal guidelines, while reflecting the size and size of the supplier, as well as the concrete assertions that have been made to the CIA. This chapter describes the legal context created to protect federal health programs from fraud and abuse, and the creation of coercive measures and penalties for violations of the law. It also describes the essential elements of the transaction agreements and the requirements of the CIA, including the role of independent monitoring bodies (OVOS) that ensure compliance with the terms of the agreement. The OIG indicated that it would continue to include specific provisions in the ciAs to address the risks associated with the misconduct that led to a company agreement with the federal government to reduce future exposure to federal health programs and beneficiaries. The annual report describes all changes to the structure of the supplier`s compliance program and the level of resources allocated to the program. In addition, the annual report (1) contains a description of all audits, audits or analyses of the supplier`s compliance program; 2) the supplier`s response to these audits, audits or analyses; and a summary report on any overpayments repaid during the period. In addition, a supplier manager must certify that the supplier is complying with its obligations under the CIA`s corporate integrity provisions. In recent years, the Department of Justice (DOJ) has developed a standard format and conditions for its civil transaction agreements that address issues related to false or incorrect claims about federal health programs. To the extent that a health care provider or provider voluntarily transmits inappropriate behaviour in relation to Federal health programs to DOJ or the Office of Inspector General (OIG), a civil case can be resolved with a significantly less than what would normally be the case.