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Navigating an integrity agreement with the OIG: A resource for practitioners

Cornelia Dorfschmid (cdorfschmid@strategicm.com) is Executive Vice President at Strategic Management Services, LLC in Alexandria, VA.

Nicole Caucci (nicole.caucci@oig.hhs.gov) is Deputy Chief, Administrative and Civil Remedies Branch, Office of Counsel to the Inspector General, Department of Health and Human Services, Salt Lake City, UT.

Not every healthcare fraud settlement involves a large corporation with the structure and resources necessary to implement a corporate integrity agreement (CIA). As a result, the U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) developed the integrity agreement (IA) for settlements with individual practitioners. In order to be successful under an IA, it is essential that the practitioner take the time to read and understand thoroughly the specific requirements and deadlines of the agreement, in particular the requirements relating to the quarterly claims review. Practitioners who make a concerted effort to (1) read, understand, and implement the IA requirements, and (2) work closely with the assigned OIG monitor and their independent reviewer during the implementation period of the agreement, will increase their chances of being successful and avoiding the imposition of penalties for noncompliance. The tips provided in this article may be helpful in reducing the learning curve.

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