Corporate Integrity Agreement and Healthcare Contract Management

Corporate Integrity Agreement for Healthcare Contract Management

"The description provided by the Inspector General is as follows: A Corporate Integrity Agreement (CIA) is a document that outlines the obligations an entity agrees to as part of a civil settlement.  Contract Guardian can help healthcare organizations stay in compliance with the agreement.  "

Thom Davidson

Corporate Integrity Agreement Details

An entity agrees to the CIA obligations in exchange for the OIG's agreement that it won't seek to exclude entity from participation in Medicare, Medicaid or other Federal health care programs. The CIAs have common elements, but each one is tailored to address the specific facts of the case and CIAs are often drafted to recognize the elements of a pre-existing compliance program.

A number of obligations are associated with a CIA.

  • Requirement to appoint a compliance officer and have them employed for the duration of the agreement. In addition, they will need to report directly to the CEO. 
  • Code of Conduct document and distribution.
  • Management Certifications - monitoring and overseeing activities.
  • Written Standards: Code of Conduct | Policies and Procedures
  • Training and Education
  • Anti-Kickback Statute and Stark Law
  • Records Retention and Access, etc.

"As you can see by the partial list above, the requirements can be quite extensive as well as daunting to manage and implement.   Contract Guardian provides many of the tools for defining, documenting, enforcing, and reporting."

Contract Guardian Compliance

Contract Guardian Helps Address Responsibilities Associated with CIA

Compliance Obligations:

  • Contract Guardian can define the role of Compliance Officer as part of the Contract Management Security.
  • The workflow and policy management components assist in the developing and implementing policies, procedures and practices.
  • Reporting (typically quarterly) can be provided via the report writer as well as being able to download any transaction to Excel for other analysis and reports.
  • One can define and store the Code of Conduct in Contract Guardian.  In addition, you can automate the distribution to all covered persons.  This is generally a annual requirement.  CG will not only automated the process, it will document the distribution in the journal.
  • Management Certifications, Standards, Record Retention and more can be facilitated via Contract Guardian.

Learn more by visiting The office of Inspector General.