In recent years, the Office of Inspector General (OIG) has “adapted” Enterprise Investment Agreements (CIAs) to target and prevent misconduct that served as the basis for an organization`s or individual`s agreement with the federal government. Some of these specialized ICAs are highlighted below: Enterprise Investment Agreements (ASCI) negotiated and concluded by the Office of Inspector General (OIG) have certain standard compliance requirements. In accordance with the United States Sentencing Commission`s Federal Sentencing Guidelines Manual, CIAs generally address the seven essential elements of an effective compliance program. Typically, each CIA begins with a statement describing why the healthcare facility is entering into the agreement. The statement confirms the supplier`s desire to adhere to high standards of business ethics and to demand the same from all its employees, managers, agents, contractors, etc. It also reaffirms the provider`s commitment to meeting the requirements for participation in Medicare, Medicaid and all other health programs of the Confederation. Then the duration and extent of the CIA is defined, usually five years. The scope contains detailed guidance on individuals and entities subject to CIA conditions. These are usually senior managers, directors, staff, contractors and representatives of the organization.
During the CIA`s tenure, the organization must comply with CIA terms or risk breaking the contract and being subject to CIA-listed fines, as well as an extension of the duration of the exclusion from participation in federal and state health programs. For entities entering a CIA, it is important to ensure that the scope and breadth of the agreement is clearly defined and specifically defined. In most cases, compliance and requirement checks are fairly straight forthcoming as long as the parameters for what constitutes an “error” are defined in advance. However, in some cases, ASCI are designed in response to alleged problems or misconduct that require program evaluations and controls rather than claims audits. Before entering into a final agreement with the CIA, it is advisable to have an expert who helps you ensure that the CIA`s terms are clear and that the scope and objectives of the IRO are also clearly defined. In recent years, the OIG CIAs has concluded with many healthcare organizations, including pharmaceutical manufacturers, hospitals, doctors` offices, clinical laboratories, nursing homes, home health services and medical equipment and providers of sustainable pharmacies. . . .