Corporate Integrity Agreement (CIA) is a legal agreement between the US Department of Justice (DOJ) and a company. It is a tool used by the DOJ to monitor and enforce compliance with federal healthcare laws and regulations. Universal Health Services, Inc. (UHS), one of the largest healthcare providers in the US, entered into a CIA with the DOJ in 2017. The CIA is a result of a settlement agreement between UHS and the DOJ over allegations of fraudulent billing and inadequate care of patients.
The UHS CIA is a five-year agreement that requires the company to make significant changes in its corporate governance, compliance, and quality of care. The CIA provides for an independent monitor to oversee UHS`s compliance with the agreement and report to the DOJ. The monitor will review UHS`s policies, procedures, and practices related to patient care, billing practices, and other compliance issues. The monitor will also examine UHS`s financial transactions to ensure that the company is not engaging in any fraudulent activities.
One of the key provisions of the UHS CIA is the requirement to implement an effective compliance program. This program should provide education and training to all employees of UHS, including senior management, on federal healthcare laws and regulations. The compliance program should also establish procedures for detecting and reporting fraud and abuse, and for responding to compliance issues.
Another important provision of the UHS CIA is the requirement to improve the quality of care provided to patients. The CIA requires UHS to hire an independent quality assurance expert to review and evaluate the company`s policies and procedures related to patient care. The expert will provide recommendations to UHS on how to improve the quality of care provided to patients.
The UHS CIA also requires the company to engage an independent review organization to review and evaluate its billing practices. The review organization will examine UHS`s billing records to ensure that the company is not submitting false or fraudulent claims to the government.
In conclusion, the UHS Corporate Integrity Agreement is a significant step towards ensuring that the company operates in compliance with federal healthcare laws and regulations. The CIA requires UHS to make significant changes in its corporate governance, compliance, and quality of care. The agreement provides for an independent monitor to oversee UHS`s compliance with the agreement and report to the DOJ. The UHS CIA is an important tool for the DOJ to monitor and enforce compliance with federal healthcare laws and regulations and to hold healthcare providers accountable for their actions. As a healthcare provider, it is essential to understand the implications of a CIA and take proactive steps to ensure compliance with federal laws and regulations.