The OIG held an August 7, 2012 OIG “roundtable” meeting with representatives of companies that have entered into corporate integrity agreements (CIA) since 2009 to solicit feedback on compliance “best practices” and companies’ efforts to implement CIA requirements. The 32 companies represented included hospitals, ambulance companies, medical device manufacturers, physician practices, laboratories, home health agencies, and skilled nursing facilities. The roundtable featured discussions of the following topics: the definitions of “covered persons” and “relevant covered persons”; CIA code of conduct, compliance policies and procedures, and training and education requirements; the role of the compliance officer and board of directors; internal auditing and audit plans; claims review requirements; and arrangements review requirements. The OIG states that it will consider the group’s feedback when deciding the terms of future CIAs.
