Corporate Integrity Agreements Require a Compliance Expert to be Engaged to Perform a Compliance Program Effectiveness Review
See how our compliance experts helped a hospital navigate a Corporate Integrity Agreement, ensuring timely evaluations and sustained program effectiveness.
Challenge
Following allegations of false claims activity, the Hospital enters into a five-year Corporate Integrity Agreement (CIA) with the Office of Inspector General (OIG). The Hospital’s Board is required to engage an external compliance expert to evaluate the effectiveness of the Hospital’s compliance program following Years 2, 3, and 5.
Solution
Coker’s compliance experts are engaged to serve as the Hospital’s compliance experts. Following Year 1 of the CIA, Coker’s experts perform a Compliance Program Effectiveness Review as required under the CIA ensuring a timely report to attach to its Year 2 annual report.
Approach
- Step 1Understand Allegations and Assess Risks
Coker receives information from the Hospital to ensure it understands the allegations giving rise to the CIA and the unique risks to the Hospital. - Step 2Initiate Compliance Review with RFIs and Surveys
Following the Hospital’s submission to the OIG of its Year 1 Report, Coker begins the process of performing the Compliance Program Effectiveness Review. The process begins with providing the Hospital with a Request for Information. As the review is document-intensive, the Hospital is allowed several weeks to upload the responsive information. During that time, Coker sends a 10-question survey to all providers and staff to receive feedback regarding perceived risks within the organization. - Step 3Conduct In-Depth Review and Stakeholder Interviews
Following the initial documentation review, a second RFI is sent to the Hospital to follow up on missing documentation and to delve deeper into certain compliance matters discussed and identified during Year 1. During this phase, Coker traces activity to ensure the compliance program is operating as intended. Interviews are conducted with key stakeholders, including Board members, senior executives, and other key personnel. Any findings requiring prompt intervention by the Hospital are communicated so that such issues can be addressed immediately. - Step 4Deliver Findings and Finalize Compliance Report
A draft report is written with the findings of the program review, including any follow-up completed by the Hospital based upon findings during the review. The draft report is reviewed with the Compliance Officer. Any relevant updates are incorporated, and the report is finalized along with Coker’s impressions on the Hospital’s Compliance Program Effectiveness. The Hospital then attaches the report to its Year 2 Annual Report.
Conclusion
Corporate Integrity Agreements are lengthy and require many processes to be established within the Hospital. Hiring an external Compliance Expert to perform a Compliance Program Effectiveness Review ensures the Hospital’s efforts are recognized, gaps continue to be addressed, and a timely report is completed as required under the CIA.
Results At a Glance
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