Corporate integrity agreements: making the best of a tough situation

Healthcare providers increasingly are entering into corporate integrity agreements as part of settlements with the Federal government in fraud-and-abuse cases. Providers pursue these settlements to avoid the costs of defending themselves against fraud charges. However, the costs relating to the long-term compliance activity mandated in the settlement's corporate integrity agreement also can be substantial. These costs include significant staff resources that must be devoted to compliance efforts demanded by the agreement and the required engagement of consultants to monitor the organization's compliance. Healthcare financial managers should be familiar with the elements of a typical corporate integrity agreement and understand strategies for negotiating such an agreement. Effective negotiations can help minimize the organization's costs of compliance with the agreement and facilitate its ongoing implementation of the agreement.