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View All ProductsMitigate risk and elevate your quality of care. Improving both clinical and business outcomes starts with a smarter, more integrated approach to regulatory training, continuing education and quality management.
Learn MoreThis blog post excerpts an article by Debbie Newsholme CCEP, CHC, Director, Content Development, HCCS–a HealthStream Company, in the Q3 2015 issue of PX Advisor, our quarterly magazine designed to bring you thought leadership and best practices for improving the patient experience.
Even the most seasoned compliance officer cringes upon hearing or reading the words Corporate Integrity Agreement (CIA), because that officer knows that a CIA will be disruptive to the organization. A CIA requires significant attention, data collection, legal defense, negotiation, new systems, new policies, oversight, and enforcement, possibly for many years. Healthcare facilities of all types, including hospitals, pharmaceutical manufacturers, long-term care, physician groups, and more have all seen increases in CIAs. Yet, these organizations often struggle with what to do if a recipient of one.
What Is a Corporate Integrity Agreement?
A CIA, according to the Department of Health and Human Services (HHS) Office of Inspector General (OIG), is a “document that outlines the obligations an entity agrees to as part of a civil settlement with the Federal government. A healthcare entity agrees to the CIA obligations in exchange for the OIG’s agreement that it won’t seek to exclude the entity from participation in Medicare, Medicaid, or other Federal health care programs.” CIAs have many common features, but each one contains facts specific to the individual case.
How Does an Organization Receive a Corporate Integrity Agreement?
CIAs can have numerous causes. For example, an entity or provider may have a pattern in its billing processes that raises a red flag with an auditor, either internal or external. Issues are also identified through data mining or data analytics. Auditors look for claims or other types of billing that fall outside the norm (i.e., “outliers”). An occasional anomaly could be explained as a simple error, but continued trends may signal fraudulent activity. If abnormalities are found in the billing or claims submission processes, investigations must be called in to detect the cause and fix the broken steps immediately. Other types of problems (e.g., Anti-Kickback or Stark violations) may be reported to the OIG or the Centers for Medicare and Medicaid Services (CMS) through the appropriate self-disclosure protocol if they are discovered internally. Reporting violations that are discovered internally can be an advantage in negotiating whether or not a CIA is appropriate. Whether a violation is discovered internally or externally, the result of an OIG investigation may be a CIA. Healthcare organizations or providers can also end up with a CIA through Qui Tam, or whistleblower lawsuits. The whistleblower (who may be someone within the organization, a former employee, or a patient) files suit on behalf of the United States government under the False Claims Act. Under the False Claims Act, the attorney general or Department of Justice attorney investigates the allegations and determines whether the U.S. government will join the lawsuit. If fraud is uncovered, the OIG may enter into a CIA with the organization. “Quality of Care” CIAs occur when a False Claims Act settlement resolves allegations of fraud that emanate from the quality of patient care. These CIAs usually require providers to engage an independent monitor, who evaluates the provider’s ability to discover, assess, and improve patient care.
Training – A CIA Mandatory Requirement
CIA settlement agreements include money that must be paid to the government, as well as training. The CIA contains a section that defines which group(s) within the organization must be trained and the types of training that must occur. Often, staff must complete initial CIA training within 90 to 120 days after the CIA is signed. This does not leave much time for organizations to select or produce training to meet the requirements. The organization must identify the individuals, groups, or departments requiring training and the types and length of training required. “General” training typically requires two to three hours and applies to all members of the workforce, including board members and volunteers. “Specific” training may also be required for individuals within a business unit or function where the issues occurred. It may target individuals performing functions related to billing and coding, documentation of services, patient access to care or care-management activities, patient care, etc. The total time requirement for learners to spend in training is typically four to six hours annually.
This article also includes two case studies explaining the organizational training required by two CIAs.
HealthStream’s learning management system and healthcare training solutions support medical training initiatives and allow for the best patient care.
View All Learning & PerformanceHealthStream offers performance learning management solutions to help develop your healthcare staff into leaders and reduce turnover.
View All ProductsHealthStream works with healthcare organizations to create engaging and high-quality training videos for your staff and management.
View All ProductsImprove care quality and save money by making informed decisions about your healthcare facility and staff with HealthStream's reporting analytics solution.
View All ProductsHealthStream's proven methods for the improvement and overall engagement of your healthcare staff foster a positive workplace and increase retention rates.
View All ProductsWhen you enact HealthStream's quality compliance solutions, you can do so with the confidence your healthcare organization will meet all standards of care.
View All Quality & ComplianceBe confident in your staff’s ability to reduce risk by providing compliance training that changes behavior.
View All ProductsDevelop next-level people for next-level care by prioritizing quality and safety improvements.
View All ProductsEstablish a culture of belonging with education supporting DEI, wellness, engagement, and leadership development.
View All ProductsUtilize patient access solutions and advanced reimbursement solutions to manage clinical denials and improve your organization’s reimbursement strategy.
View All ReimbursementExpand the decision-making skills and effectiveness of your healthcare workforce with HealthStream's clinical development programs and services.
View All Clinical DevelopmentLearn about our advanced resuscitation training solutions. Our solutions are designed to help improve patient outcomes.
View All ProductsOur competency development solutions personalize learning for clinicians to bridge the gap between theory and practice for your nurse residents.
View All ProductsEnhance maternal & child nursing care with solutions focused on improving the quality of care for mothers, infants, and children.
View All ProductsAddress staffing orientation challenges to easily achieve and maintain certification with our emergency and acute care training solutions.
View All ProductsAs a premier provider of healthcare education, we are committed to promoting safer, more successful surgical and sedation outcomes for each and every patient.
View All ProductsOur solutions are designed to cater to the needs of patients, healthcare professionals, and organizations dealing with illnesses or chronic conditions.
View All ProductsMake sure your healthcare staff can schedule out appointments and work schedules with ease using HealthStream's line of software solutions.
View All SchedulingHealthcare workforce management is essential. We provide advanced scheduling solutions for organizations to solve issues such as nurse retention
View All ProductsComprehensive, industry-leading provider onboarding and credentialing software that validate health outcomes and support provider assessment.
View All CredentialingOur affordable CVO credentialing services establish patient safety by enabling primary source verification for your healthcare organization.
View All ProductsIntegrate with Epic to validate and add new providers directly to your provider master file.
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