Who has the authority to impose a Corporate Integrity Agreement (CIA)?

The authority to impose a Corporate Integrity Agreement (CIA) lies with the government, specifically through regulatory bodies such as the Office of Inspector General (OIG) of the Department of Health and Human Services (HHS). A CIA is typically put in place as part of a legal settlement with the government following allegations of fraud or misconduct by a healthcare organization. The purpose of a CIA is to ensure that the organization implements compliance measures aimed at preventing future violations.

The government’s involvement is crucial, as it provides oversight and sets forth the requirements that the organization must adhere to in order to resolve compliance issues and maintain eligibility for government-funded healthcare programs. This agreement serves as a tool for promoting accountability and ensuring that the organization engages in best practices regarding healthcare compliance.

While courts can oversee legal proceedings that relate to compliance issues and board of directors may have internal governance roles, the definitive power to create and enforce a CIA rests with governmental authorities, particularly in the context of compliance violations in the healthcare sector.