Practice Management Alert

A strong compliance plan and compliance education programs can help you prevent the many time- and money-consuming stipulations of a corporate integrity agreement.
 
What is it? A corporate integrity agreement is a contract between a medical provider and the government that strives to enforce billing compliance. If an HHS Office of Inspector General (OIG) investigation reveals non-compliant billing, the OIG can enforce a corporate integrity agreement. The investigation could be spurred by random government auditing, an internal whistleblower who tips off the OIG, or a red flag caused by suspicious billing patterns. Based on the investigation, the government reaches a settlement that includes paying a fine and establishing an integrity agreement "to put safeguards in place" to prevent billing violations, says Robert A. Pelaia, JD, CPC, director of compliance at the University of Florida.

What's included: The exact components of every corporate integrity agreement vary, but they usually require you to participate in audits, assign a compliance officer and establish a compliance hotline to report non-compliant activity. The agreement may also require an outside auditor to periodically review both your billing compliance activities and your compliance with the terms of the integrity agreement, Pelaia says. And most integrity agreements include stipulated fines for violating the contract terms, he adds.

How to avoid one: A strong compliance plan is the best way to steer clear of the OIG. Review and update your plan regularly to ensure your billing office operates within the legal limits. For tips on billing compliance education sessions, see "5 Steps Add Spice to Compliance Education Sessions".