Walking Through a Corporate Integrity Agreement [CIAS Part III]

Talking with the Toothcop

In the first episode of this series, we talked about what a corporate integrity agreement is. In the second episode, we covered focusing on compliance. In this episode of Talking with the Toothcop, we are going to walk through an actual corporate integrity agreement. If you’re caught in the OIG’s crosshairs, this is just one example of what you might expect.

NOTE: These are NOT confidential and are public documents on the OIG website.

Outline of This Episode

• [2:15] A pediatric corporate integrity agreement
• [9:27] Reach out to us for support
• [12:02] Compliance Bootcamp 2021

A pediatric corporate integrity agreement

This CIA was executed in August 2016 with a three-year term (a CIA is typically a five-year term). The CIA stipulated that the dentist and all employees and contractors (including billing) had to establish a compliance program that included:

• Posting a notice in their office that patients could see—within 60 days of the effective date—that provides the OIG hotline number as a confidential means to report fraud or abuse.
• They had to include three hours of training and education for the practitioner and all covered entities within the first reporting period. That may only be satisfied by taking courses provided by the CMS Medicare Learning Network. It must include a billing, coding, and claims submission course and a medical record documentation course. New employees had to receive three hours of training within 45 days of being hired.
• An independent review organization was hired to conduct a review of the doctor’s coding, billing, and claims submission to CMS.
• Ineligible persons include anyone barred or suspended from participation with federal healthcare programs (this shows the importance of continued exclusions checks). Doctors had to prove that they had checked and tracked that their employees were not on an exclusion list.
• For the purpose of this CIA, an overpayment meant the amount of money a doctor had received in excess of the amount due and payable under any federal healthcare program requirement. If an overpayment was identified, they had to repay it to the appropriate payer within 60 days. They then had to take steps to prevent overpayment from happening again. Any paid claim had to be supported with proper documentation.

This CIA didn’t even flesh out all seven elements of a compliance program. Even if the situation is over, it’s still a public record forever.

Get the help you need—now

Don’t wait until you’re in trouble to get help. Set up a compliance program to protect your practice so you don’t end up on the chopping block. The prevention is worth it. Just because it hasn’t happened doesn’t mean it won’t. If you’d like to schedule a call with me, call our office at 817-755-0035 to speak with Andrea and set up a Zoom call.

Resources & People Mentioned

• Closed Corporate Integrity Agreements
• CMS Medicare Learning Network

Connect With Duane

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