Case Studies: Corporate Integrity Agreement Experience
Large Hospital System in Five-Year Corporate Integrity
Agreement
We were retained by one of the largest hospital systems in the Western
United States that had entered into a five-year corporate integrity
agreement (CIA) with the Office of Inspector General as part of a global
settlement agreement with the U.S. Department of Justice resulting
from a qui tam (whistleblower) action for allegedly submitting false
claims for reimbursement to federal healthcare programs. Pursuant to
the terms of its CIA, the health system retained us to serve as its
Independent Review Organization in order to perform certain agreed-upon
procedures to assist the health system evaluate its compliance with
the terms of the CIA. We presented its findings to the health system’s
management who in turn submitted our findings with its annual report
to the OIG pursuant to the terms of the CIA.
Hospital Laboratory Billing Review
We were engaged as the Independent Review Organization by a hospital
to perform an analysis of certain laboratory billings and to assess
the effectiveness of the institution’s compliance efforts in relation
to the terms of its Corporate Integrity Agreement (CIA). The CIA
was mandated by the Office of Inspector General pursuant to the discovery
of certain billing and reimbursement violations. We conducted an
analysis of a random sample of laboratory claims to determine the
accuracy of the provider’s claims.
