Nacogdoches Memorial Hospital, located in Texas, entered into a five-year Corporate Integrity Agreement (CIA) and settlement agreement with the HHS Office of Inspector General (OIG) in order to ensure compliance with all federal health care programs. The CIA includes obligations for the establishment of a compliance program, risk assessment and disclosure processes, and requirements for government notification of any investigations into allegations of fraudulent activity ( Corporate Integrity Agreement, February 9, 2016).
Compliance program. Under the CIA, the hospital will establish a compliance program that includes a compliance officer and committee. The officer must report to the hospital’s chief executive officer (CEO) and have no responsibilities that cause the officer to act as legal counsel to the hospital. The officer will implement policies and procedures to ensure compliance with the CIA. The hospital board of directors will be responsible for compliance oversight, and review the compliance officer and committee’s performance. The board will also submit any reviewed documents to the OIG. This particular CIA requires the appointment of a certified cardiologist to serve as the cardiac catheterization laboratory’s medical director. This director will periodically report to the compliance officer about the laboratory’s management and oversight.
Implementation and reporting. The hospital must provide a training plan for ensuring that all employees and other individuals covered by the CIA are adequately trained on the compliance program and all CIA requirements. The hospital must develop an annual risk assessment and internal review process for claims submitted to the Medicare and Medicaid program. The hospital must establish a disclosure program that allows employees to anonymously report any legal violations, and the compliance officer must make a good faith inquiry into all allegations.
The government must be notified within 30 days of discovery of any ongoing investigation or legal proceeding brought by the government regarding allegations of fraudulent or criminal activity. If the hospital discovers any overpayments from federal health care programs, the excess amount must be returned within 60 days of discovery. The hospital must also take steps to prevent the overpayment from recurring.