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Leveraging CIAs and IAs as a compliance tool: Analyzing trends to identify and mitigate compliance risks for practitioners

Samantha L. Groden (samantha.groden@dentons.com) is a Senior Managing Associate in the San Francisco office; Stephanie Murtagh (stephanie.murtagh@dentons.com) is a Managing Associate in the Los Angeles office; and Janice Ziegler (janice.ziegler@dentons.com) is a Partner in the Washington, DC, office of Dentons US LLP.

Identifying, monitoring, and addressing potential risk areas is a critical component of an effective compliance program. Indeed, the U.S. Department of Health & Human Services Office of Inspector General (OIG) recommends that healthcare organizations participating in federal healthcare programs conduct periodic risk assessments and engage in internal review processes pursuant to which the organization will identify and prioritize risks, develop and implement internal audit work plans related to identified risk areas, and develop and implement corrective action plans in response to the results of any internal audits performed.[1]

Identifying potential risks requires compliance personnel to understand the organization’s operations and to review and consider numerous sources of information to determine possible compliance challenges that could result in legal, financial, or reputational harm. Understanding government enforcement trends allows healthcare organizations to make informed decisions regarding where to invest their time, energy, and resources.

This article is the second in a series designed to equip compliance personnel with data—derived from recent government enforcement activity—that can help them better understand the government’s current enforcement priorities and, thus, more easily identify and rank potential risks to their organization.

Recent corporate integrity agreements (CIAs) and integrity agreements (IAs) imposed by the OIG,[2] and the associated settlement agreements, provide a wealth of information regarding the agency’s priorities, areas of focus, and compliance expectations.[3] (IAs are similar to CIAs but typically have a shorter term and contain fewer compliance obligations.) By understanding the circumstances under which the OIG has imposed a CIA or IA, federal healthcare program participants can better understand the agency’s enforcement emphasis and identify internal practices that may require closer scrutiny.

Unfortunately, while the OIG maintains a publicly available database of its active CIAs and IAs (and associated materials),[4] the data is not organized in a way that easily allows for quantitative and qualitative analysis. Each article in this series is designed to provide targeted data analysis of recent CIA and IA enforcement activity related to a specific type of provider or supplier. This article focuses on CIAs and IAs recently imposed on individual healthcare practitioners and/or medical practices. For ease, we refer to these CIAs and IAs, collectively, as “Practitioner Integrity Agreements.”

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