By Navigant Consulting
Recent Corporate Integrity Agreements (CIAs) from the Office of Inspector General of the Department of Health and Human Services (OIG) have included unique obligations requiring Board of Directors and Senior Management to be held accountable for compliance, while increasing the scope and sophistication of reviews performed by Independent Review Organizations (IROs). These emerging CIA trends are most evident in recent pharmaceutical and medical device company settlements.
We consider the evolving requirements of the OIG and propose actions that can be implemented to maintain a Compliance Program that meets or exceeds current OIG requirements.