2016 was a year of change for the Department of Health and Human Service's Office of Inspector General's (OIG) approach to corporate integrity agreements (CIA). The OIG began to use its new model CIA format and applied its "risk spectrum" model in deciding whether to seek CIAs to resolve health care fraud investigations. In addition, new CIAs involving medical device makers addressed key sales, marketing, and product education and training issues. Companies should continue to review recent CIAs in their industry sector for guidance on compliance safeguards relating to key activities.
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