On October 9, 2012, HHS-OIG released a summary report of its August 7, 2012 roundtable concerning corporate integrity agreements (CIAs). Representatives from 32 companies that have entered into CIAs since 2009 attended the roundtable, the purpose of which was to solicit feedback from the representatives regarding their compliance “best practices” and their efforts to implement the requirements of their CIAs. According to the summary report, the “OIG will consider the feedback when deciding what terms to include in future CIAs.”
Among the topics discussed at the roundtable were: (1) the definitions of “covered persons” and “relevant covered persons” and CIA requirements relating to a code of conduct, compliance policies and procedures, and training and education; (2) the role of the compliance officer, the board of directors and internal auditing; (3) claims review requirements; and (4) arrangements review requirements. The October 9 summary will be the only report issued concerning the roundtable and can be accessed by clicking here.