Examining Recent Corporate Integrity Agreement Trends

Law360, New York (January 26, 2016, 12:27 PM EST) -- When it comes to promoting compliance in the health care industry, corporate integrity agreements are one of the most important tools in the U.S. Department of Health and Human Services' Office of the Inspector General's toolbox. First, CIAs impose controls directly on companies or individuals resolving government investigations, ensuring those entities have the integrity to continue receiving reimbursement under federal health care programs. Second, CIAs promote compliance indirectly by providing nonbinding guidance to other entities in similar industry sectors as to what the OIG considers to be effective in terms of compliance program structure and controls. CIAs provide an up-to-date perspective on the OIG's priorities and concerns in a particular industry sector. Companies should stay current on CIA trends as they assess and seek to continuously improve their compliance programs....

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