How to Prevent the Risk of a Corporate Integrity Agreement

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In the complex landscape of healthcare compliance, avoiding the risk of a Corporate Integrity Agreement (CIA) is paramount for organizations striving to maintain ethical standards and regulatory compliance. A CIA, typically resulting from investigations into fraudulent practices, can significantly impact an organization’s reputation and operational continuity.

Fraudulent claims in the health sector range from falsely billing for several thousand dollars to million-dollar kickback schemes for medical equipment. Although it’s unclear whether the pandemic has fueled these claims, they are at a peak high, with a recent government report indicating the discovery of fraudulent claims worth hundreds of billions of dollars, submitted by over 300 licensed medical professionals.

Being on the CIA list puts any health care organization on the spot for the wrong reasons. Corporate Integrity Agreements or CIAs, are meant to act as part of the settlement of investigations that arise in these kinds of scenarios.

This article delves into CIAs, what they are and what they are used for.

What is a CIA?

The Department of Health and Human Service Office of Inspector General (OIG) negotiates, a Corporate Integrity Agreement (CIA) with healthcare providers. The CIA acts as part of a settlement of federal healthcare program investigations found under false claims statutes.

The OIG promises not to bar the provider or organization from participating in federal healthcare services in return for the arrangement. CIAs need considerable HR and financial resources to implement and oversee.

Pharmaceutical firms, medical equipment companies, hospitals, nursing homes, and long-term care facilities, and medical practices are among the entities and services that may be affected.

How Long do CIAs Last?

Corporate Integrity Agreements last five years and usually require provisions to employ a compliance officer or appoint a compliance committee, establish written compliance standards and policies, track overpayments, reportable activities, and pending investigations or legal proceedings and include an implementation report and annual reports to the OIG on the state of the party’s compliance activities.

Monitoring and Risk Reviews To Avoid CIAs And other Reprimands By Healthcare Regulators

To avoid violating healthcare regulations and landing your organization into a CIA, do the following things to develop an efficient compliance program.

  • Designate a compliance officer and compliance committee. A compliance department helps you to implement your compliance program to ensure you’re working in line with federal healthcare program requirements that apply to you. Carry out a yearly review of its activities to ensure they cover every requirement.

  • Compliance policies and procedures. These are usually written laws that establish a guide to help workers meet the provisions of a federal healthcare program.

  • Develop Transparent Communication. An open communication organization culture improves your organization’s capability to spot and correct noncompliance. Go further and introduce communication methods where employees, shareholders, guests, and patients can voice their concerns anonymously.

  • Avail Training. In addition to academic training, healthcare organizations need to train their workers on the rules that govern administering healthcare. This also includes fine-tuning any additions to the existing healthcare regulations.

  • In-house Surveillance. Surveillance will help you render accurate compliant claims to the authorities. Surveillance includes developing comprehensive yearly audit plans intended to reduce the contingencies that come with inaccurate claims and billing practices. Electronic audit trails can help you in preparing for external audits and compliance examinations. Use automatic compliance tools that create regular reports and send them to the relevant entities. Keep track of workers’ activities, tips, and other non-monetary compensations, and conflict of interest to prevent breaking Anti-Kickback Statute and Stark Law.

  • Boost Processes that make it easy for non-compliance. Develop sufficient remedial actions to deal with non-compliant processes and prevent additional losses to federal healthcare programs.

  • Disclose any Noncompliant Behavior. This includes kickbacks or fraudulent billings that may break criminal, civil, or administrative law. Make reports to the relevant federal or state authorities within 60 days. Timely, voluntary reporting shows your organization’s willingness to operate under the law. OIG considers reporting offenses as a mitigating factor in deciding regulatory sanctions-like penalties, assessments, and exclusion- if the OIG ever has to investigate your organization.

How Healthcare Compliance Consulting helps you avoid CIAs

Healthcare regulatory compliance consultants are usually legal experts who work with healthcare companies to ensure that they are compliant with federal regulations. They counsel senior management and assist in the development of procedures and programs to ensure that the entire company complies with relevant laws and standards.

Their main job is to identify, prioritize compliance issues, and develop plans to deal with them. They’ll also analyze and advise on different practices that attract CIAs, including patient record confidentiality and medical licensing. A compliance consultant works with your organization’s legal, operations and finance teams. They monitor actions to estimate the risk of compliance, spot non-compliance and recommend corrections.

Some healthcare organizations enlist healthcare compliance consulting agencies to help in developing regulatory strategies, interpreting data, and training staff to ensure they understand their responsibilities in complying with regulations. Consultants may also submit a formal response to regulatory agencies when non-compliance occurs.

What to Look for in a Healthcare Regulatory Compliance Consultant

In a sector as sensitive as healthcare, the last thing your organization needs is unreliable advice. Prudent healthcare compliance consulting should assist an organization in avoiding regulatory scrutiny. Here are three top qualities you should look for when consulting with a healthcare regulatory compliance consultancy.

  • Length and Scope of Experience

What kind of consulting expertise does the prospective consultancy have? You should also determine whether their experience matches the kind of compliance consulting your organization needs based on current business risks and industry threats.

  • Ability to Help with Cybersecurity

Health-care data has always been a popular and lucrative target for identity thieves and fraudsters. According to Forbes, as we handle more healthcare services online due to the pandemic, hackers have focused their attention even more on technology, leaving the healthcare industry vulnerable to security threats.

A good consultancy should support your organization to investigate cybersecurity and incident response protocols to keep your data safe.

  • Interpreting Laws

It’s easy to assume that many of the laws in regulatory compliance are straightforward. But this is far from the truth. Compliance advisors should be well-versed in understanding relevant regulations, best business practices, and operational efficiencies, to ensure proper application of relevant laws to an underlying compliance program.

Riddle Compliance

At the core of it, regulatory compliance is about promoting business best practices to keep people safe. Since you can’t juggle all aspects of your business alone, we’re here to help you with regulatory compliance. Contact us today to get pragmatic  healthcare compliance consulting!

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