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By Adam Turteltaub
adam.turteltaub@corporatecompliance.org
No one wants to work under a Corporate Integrity Agreement (CIA), but there are lots of good lessons that can be learned from them.
Laura Ellis, Senior Counsel in the Office of Special Counsel to the Inspector General at HHS, and Michael Lampert, a partner in the Boston office of Ropes & Gray will be addressing CIAs in their session at the 2019 Compliance Institute in Boston.
In this podcast they reveal some of the insights they will be sharing at the conference. They focus on three elements now found in all CIAs:
- Board members are required to pass a resolution finding that their compliance program is effective and in compliance with the corporate integrity agreement provisions.
- Senior managers must sign an annual certification that they have been trained on compliance, are aware of the compliance program, have operated their department in a compliant manner, and are not aware of any improper behavior.
- The company undergo an annual compliance risk assessment.
These elements are designed to ensure that compliance cascades through the organization and that the compliance program remains dynamic and aligned with key risks for healthcare providers.
Listen in to learn more about the OIG’s office’s approach, and then join them at the 2019 Compliance Institute.
Nice post!
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