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HHS Office of Inspector General

Fraud Prevention & Detection

Corporate Integrity Agreements


Corporate Integrity Agreement Documents

Corporate Integrity Agreement Frequently Asked Questions


General Information

The Office of Inspector General (OIG) often negotiates compliance obligations with health care providers and other entities as part of the settlement of Federal health care program investigations arising under a variety of civil false claims statutes. A provider or entity consents to these obligations as part of the civil settlement and in exchange for the OIG's agreement not to seek an exclusion of that health care provider or entity from participation in Medicare, Medicaid and other Federal health care programs. False claims submitted in violation of the False Claims Act or Civil Monetary Penalties Law give rise to the OIG’s permissive exclusion authority under 42 U.S.C.1320a-7(b)(7). Providers who settle these cases often deny that they were liable or that they committed the alleged conduct.

The typical term of a comprehensive corporate integrity agreement (CIA) is five years. These compliance measures seek to ensure the integrity of Federal health care program claims submitted by the provider. The more comprehensive integrity agreements include requirements to:

(1) Hire a compliance officer/appoint a compliance committee;

(2) Develop written standards and policies;

(3) Implement a comprehensive employee training program;

(4) Retain an Independent Review Organization to review claims submitted to Federal health care programs;

(5) Establish a confidential disclosure program;

(6) Restrict employment of ineligible persons;

(7) Report overpayments, reportable events and ongoing investigations/legal proceedings; and

(8) Provide an implementation report and annual reports to the OIG on the status of the entity's compliance activities.

While many CIAs have common elements, each agreement addresses, in part, the specific facts of the conduct at issue. CIAs often attempt to accommodate and recognize many of the elements of pre-existing voluntary compliance programs.

In addition to CIAs, the OIG also may negotiate a Certification of Compliance Agreement (CCA) with health care providers and other entities, in lieu of a comprehensive CIA, under appropriate circumstances. The relevant considerations for whether an entity may be permitted to enter into a CCA instead of a comprehensive CIA include those set forth in the November 20, 2001 Open Letter to Health Care Providers. The terms of a CCA include a requirement that the entity maintain its existing compliance program, as described in a Declaration that is attached to the CCA. In addition, the entity is required to agree to certain compliance obligations that mirror those found in a comprehensive CIA, including reporting overpayments, reportable events, and ongoing investigations and legal proceedings to the OIG, and providing annual reports regarding the entity’s compliance activities to the OIG during the term of the CCA.

To view the list of health care providers and entities who are currently subject to CIAs, CCAs and settlement agreements with integrity provisions, click here.

To view the full text of an active CIA or CCA, simply double click on the name of the entity listed in the CIA list.

Please note that settlement agreements with integrity provisions are not electronically available through this web site. Rather, copies of such settlement agreements may be obtained through a filing a Freedom of Information Act (FOIA) request with the United States Department of Justice. Information on filing FOIA requests with the Department of Justice may be obtained through its web site, found at and selecting the FOIA section. This FOIA request should be as specific as possible.


Corporate Integrity Agreement Frequently Asked Questions




Frequently Asked Questions Related to OIG Corporate Integrity Agreements


Frequently Asked Questions Related to the Independence of an IRO PDF

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