In March 2012, for the first time, OIG invoked a divestiture provision in response to a violation of a CIA. In January 2010, Church Street Health Management ("CSHM"), a dental services provider, entered into a civil settlement with DOJ to resolve fraud allegations. As part of that settlement, CSHM paid $24 million in fines and penalties and entered into a five-year CIA. In February 2012, CSHM filed for bankruptcy, citing the cost of the settlement, CIA compliance, and subsequent litigation as the primary causes. In March 2012, OIG notified the company of numerous material breaches, but CSHM was unable to cure all breaches during the 30-day period allowed. In exchange for CSHM's agreement to divest one of its clinics within 90 days, OIG agreed to not commence an exclusion action.