We are pleased to welcome a guest today on the blog - Harold Malkin, a former Assistant U.S. Attorney who specialized in the resolution of civil healthcare fraud cases involving individual providers, medical practices and institutional providers in the Western District of Washington in Seattle for over 15 years. In this article, Harold will highlight some important information regarding the permissive and mandatory exclusion authority of the Office of Inspector General (OIG) as well as some things to consider if you find yourself in settlement discussions with OIG.Read More
There are many people who can share their perspectives on negotiating a Corporate Integrity Agreement, all with a variety of backgrounds and experiences.Read More
There are many misunderstandings in the compliance world on how CIAs are used and whether or not the OIG is obligated to enter into one. The OIG does not have to enter into a Corporate Integrity Agreement, nor does a provider have an automatic right to one.Read More
A CIA is a serious weapon available to the OIG to resolve allegations of fraud and abuse. Let's take a look back at some of the history of Corporate Integrity Agreements and how they are used.Read More
As we all know, Corporate Integrity Agreements (CIA’s) are an excellent resource to a compliance officer when trying to stay ahead of the ever-changing compliance landscape. CIA’s provide a wealth of information as to what the Office of Inspector General (OIG) believes should be elements of an effective compliance program. They can also help clarify roles and responsibilities of the board or senior leadership in a healthcare organization. It is highly recommended that you monitor CIAs posted on the OIG site on a periodic basis to see if the model CIA has been updated or changed.Read More
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