Corporate Integrity Agreement Sample Contracts

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CORPORATE INTEGRITY AGREEMENT BETWEEN THE
Corporate Integrity Agreement • February 10th, 2015
CORPORATE INTEGRITY AGREEMENT‌
Corporate Integrity Agreement • May 5th, 2020
CORPORATE INTEGRITY AGREEMENT BETWEEN THE OFFICE OF INSPECTOR GENERAL OF THE DEPARTMENT OF HEALTH AND HUMAN SERVICES AND COMMUNITY HEALTH SYSTEMS, INC.
Corporate Integrity Agreement • November 20th, 2015 • Quorum Health Corp • Services-general medical & surgical hospitals, nec
CORPORATE INTEGRITY AGREEMENT BETWEEN THE OFFICE OF INSPECTOR GENERAL OF THE DEPARTMENT OF HEALTH AND HUMAN SERVICES AND PROGENITY, INC.
Corporate Integrity Agreement • December 1st, 2020 • Progenity, Inc. • Services-medical laboratories
CORPORATE INTEGRITY AGREEMENT BETWEEN THE
Corporate Integrity Agreement • May 5th, 2020

Extendicare Health Services, Inc. (“EHSI”), and The Progressive Step Corporation (“ProStep”) (hereafter collectively referred to as “Extendicare”) hereby enter into this Corporate Integrity Agreement (CIA) with the Office of Inspector General (OIG) of the United States Department of Health and Human Services (HHS) to promote compliance with the statutes, regulations, and written directives of Medicare, Medicaid, and all other Federal health care programs (as defined in 42

Contract
Corporate Integrity Agreement • May 5th, 2020

EX-10.1 2 evhc8k20171219ex10v1.htm EXHIBIT 10.1 Exhibit 10.1 CORPORATE INTEGRITY AGREEMENT BETWEEN THE OFFICE OF INSPECTOR GENERAL OF THE DEPARTMENT OF HEALTH AND HUMAN SERVICES AND ENVISION HEALTHCARE CORPORATION I.PREAMBLE Envision Healthcare Corporation (Envision) hereby enters into this Corporate Integrity Agreement (CIA) with the Office of Inspector General (OIG) of the United States Department of Health and Human Services (HHS) to promote compliance with the statutes, regulations, and written directives of Medicare, Medicaid, and all other Federal health care programs (as defined in 42 U.S.C. § 1320a-7b(f)) (Federal health care program requirements). Contemporaneously with this CIA, Envision is entering into a Settlement Agreement with the United States. For the purpose of this CIA, “Envision” shall cover the following: Envision Healthcare Corporation and its directly or indirectly owned or controlled subsidiaries and affiliates that contract with hospitals to staff and manage ei

CORPORATE INTEGRITY AGREEMENT
Corporate Integrity Agreement • April 23rd, 2010
CORPORATE INTEGRITY AGREEMENT BETWEEN THE
Corporate Integrity Agreement • March 13th, 2014
CORPORATE INTEGRITY AGREEMENT BETWEEN THE
Corporate Integrity Agreement • July 5th, 2012
Corporate Integrity Agreements: Living Under a
Corporate Integrity Agreement • January 28th, 2018

DOJ Statistics – Qui Tam Actions ▪ Refresher: Qui tam lawsuits are brought by whistleblowers under the False Claims Act and they provide a reward if recovery is received government ▪ From January 2009 to the end of fiscal year 2015, the government recovered $19.4 billion in settlements and judgments related to qui tam suits and paid whistleblower awards of $3 billion during the same period 3

CORPORATE INTEGRITY AGREEMENT BETWEEN THE
Corporate Integrity Agreement • May 22nd, 2015
CORPORATE INTEGRITY AGREEMENT BETWEEN THE
Corporate Integrity Agreement • October 15th, 2019

Maximus, Inc., on behalf of the Maximus Consulting Segment, hereby enters into this Corporate Integrity Agreement (CIA) with the Office of Inspector General (OIG) of the United States Department of Health and Human Services (HHS) to promote compliance with the statutes, regulations, and written directives of Medicare, Medicaid, and all other Federal health care programs (as defined in 42 U.S.C. § 1320a-7b(f)) (Federal health care program requirements). Contemporaneously with this CIA, Maximus is entering into a Settlement Agreement with the United States.

CORPORATE INTEGRITY AGREEMENT BETWEEN THE
Corporate Integrity Agreement • May 22nd, 2015
CORPORATE INTEGRITY AGREEMENT BETWEEN THE
Corporate Integrity Agreement • October 11th, 2011
CVS Health (the “Company”) entered into a Corporate Integrity Agreement (“CIA”) with the Office of Inspector General, Department of Health and Human Services (“OIG”) in October 2016 to resolve allegations concerning certain business practices of the...
Corporate Integrity Agreement • October 11th, 2016

This Policy outlines the requirements for Covered Persons as required by the CIA. Specifically, this Policy is designed to ensure that Covered Persons understand the elements of the Anti- Kickback Statute and Stark Law and the obligation to report violations and/or seek guidance when necessary. The Company is committed to complying with all Federal health care program requirements, including but not limited to, the Anti-Kickback Statute and Stark Law.

CORPORATE INTEGRITY AGREEMENT BETWEEN THE
Corporate Integrity Agreement • May 5th, 2020
Corporate Integrity Agreements Can be the Basis for a False Claims Act Case
Corporate Integrity Agreement • October 21st, 2014

Numerous health care providers have been parties to Corporate Integrity Agreements (“CIAs”) over the past several years. Among them are many pharmaceutical companies/manufacturers. Typically these CIAs contain terms requiring, inter alia, the provider to notify HHS OIG of “Reportable Events,” including “overpayments” from health care programs, and to submit to HHS OIG Annual Reports including a certification by the company’s Compliance Officer that it was in compliance with all of the requirements of the CIA.

CORPORATE INTEGRITY AGREEMENT BETWEEN THE
Corporate Integrity Agreement • February 19th, 2020 • Amedisys Inc • Services-home health care services
CORPORATE INTEGRITY AGREEMENT BETWEEN THE‌
Corporate Integrity Agreement • May 8th, 2024
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CORPORATE INTEGRITY AGREEMENT BETWEEN THE‌
Corporate Integrity Agreement • October 21st, 2020
CORPORATE INTEGRITY AGREEMENT BETWEEN THE
Corporate Integrity Agreement • June 6th, 2013

Dallas County Hospital District d/b/a Parkland Health and Hospital System (Parkland) hereby enters into this Corporate Integrity Agreement (CIA) with the Office of Inspector General (OIG) of the United States Department of Health and Human Services (HHS) to promote compliance with the statutes, regulations, and written directives of Medicare, Medicaid, and all other Federal health care programs (as defined in 42 U.S.C.

CORPORATE INTEGRITY AGREEMENT BETWEEN THE OFFICE OF INSPECTOR GENERAL OF THE DEPARTMENT OF HEALTH AND HUMAN SERVICES AND
Corporate Integrity Agreement • May 7th, 2019 • Jazz Pharmaceuticals PLC • Pharmaceutical preparations
CORPORATE INTEGRITY AGREEMENT BETWEEN THE‌
Corporate Integrity Agreement • June 3rd, 2024
CORPORATE INTEGRITY AGREEMENT BETWEEN THE
Corporate Integrity Agreement • March 5th, 2014
CORPORATE INTEGRITY AGREEMENT BETWEEN THE
Corporate Integrity Agreement • August 29th, 2023
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Corporate Integrity Agreement • May 27th, 2021

On June 30, 2020, Novartis Corporation entered into a Corporate Integrity Agreement (CIA) with the Office of the Inspector General (OIG) of the United States Department of Health and Human Services (HHS).

CORPORATE INTEGRITY AGREEMENT BETWEEN THE
Corporate Integrity Agreement • May 7th, 2018
CORPORATE INTEGRITY AGREEMENT‌
Corporate Integrity Agreement • March 7th, 2016
Corporate Integrity Agreement Design and Enforcement: How to Mitigate Liability
Corporate Integrity Agreement • October 12th, 2015

The materials and views expressed in this presentation are the views of the presenters and not necessarily the views of the North Shore‐LIJ Health System, Dignity Health or the OIG.

CORPORATE INTEGRITY AGREEMENT BETWEEN THE‌
Corporate Integrity Agreement • July 13th, 2020
CORPORATE INTEGRITY AGREEMENT BETWEEN THE
Corporate Integrity Agreement • July 19th, 2018
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