Making the best of corporate integrity agreements

Corporate integrity agreements (CIAs) imposed by the Office of Inspector General (OIG) of HHS have increased dramatically in the past five years. Healthcare organizations that enter into a CIA face burdensome monitoring and reporting requirements. However, it may be possible to lessen these burdens by negotiating modifications to the CIA's requirements. Organizations that have compliance programs in place can negotiate with the OIG to integrate elements of their existing compliance programs into the CIA. The organization also should attempt to negotiate limiting the scope of the monitoring to include only the area that was originally investigated. In addition, it may be valuable to negotiate insertion of a clause in the CIA allowing the organization to request renegotiation of the terms and duration of certain elements of the agreement after the first year, if conditions are met. An organized CIA negotiation process may be valuable in obtaining a reduced scope of the procedures required by the CIA and preparing the organization to meet its obligations.