i”Corporate Integrity Agreements”. Order of business| Reports and publications | Office of the Inspector General | Department of Health and Human Services. Available at: oig.hhs.gov/compliance/corporate-integrity-agreements/index.asp. The DHHS Office of Inspector General (OIG) negotiates Corporate Integrity Agreements (CIA) with healthcare providers and other agencies as part of the settlement of Federal Health Program investigations resulting from a large number of civil laws on incorrect claims. The CIA describes the obligations that a company accepts, in exchange for the agreement of the OIG, that it will not seek to exclude the company from participation in Medicare, Medicaid or other health programs of the Confederation. ISAs have common elements, but each is tailored to the specific facts of the case, and ICAs are often designed to identify elements of an already existing compliance program. The first CIA was executed by the OIG for HHA in 1994. Previous ICAs were more focused on training and certifying staff participation in the IGO. Over the next decade, the OIG began adding “integrity rules” requiring the supplier/company to put in place an effective compliance program that reflected the practices outlined in the guidelines. The guidelines required seven steps to ensure minimal compliance. In addition, the OIG has added requirements that allow for the inspection and verification of compliance programs and require an annual report from the supplier/unit to the OIG on its CIA compliance efforts. 5. Use ASCI as a training tool.
Look for continuous improvements that will make your business stronger at the end of its lifespan. The OIG invites independent oversight bodies to respect the standards of independence and objectivity set out in the General Government Auditing Standards (July 2007 revision) (herein referred to as the “Yellow Book”). The Yellow Book contains both ethical principles and general standards applicable to all types of IRO audits carried out under Enterprise Investment Agreements (AIAs) and forms the basis of the OIG`s requirements for the independence and objectivity of the IRO. CIAs require that each IRO used by the supplier present a certification, that the IRO has assessed its professional independence and objectivity in accordance with GAO standards with regard to the verification carried out for the supplier. The ICAs also give the OIG the discretion to refuse a supplier`s choice of IRO or to require a supplier to maintain a new IRO if the IGO finds that the IRO does not meet these standards. It is therefore advisable to obtain, when selecting an IRO, a written certificate from potential IROs attesting that they meet these standards. The Corporate Integrity Agreement (CIA) determines the time allowed for the selection and communication of the IRO to the OIG. Most agreements provide that this will be done within 60 to 90 days of the CIA`s entry into force. Some CIAs require an independent organization to verify and monitor compliance with the CIA`s terms and conditions. Most ASCI require damage checks to identify errors and their underlying causes.  The government authority may verify compliance through on-site visits.  If a company violates the agreement, the Agency can sanction it and if the problems cannot be resolved, the supplier can be excluded.
 The IGO has negotiated, in appropriate circumstances, a Conformity Certification Agreement (CCA) with healthcare providers and other bodies instead of a Comprehensive Investment Firm Agreement (CIA). The terms of a CSF always imply an obligation for the company to maintain its existing compliance program.. . . .