The first CIA was executed by the OIG for HHA in 1994. Previous ICAs were more focused on training and certifying staff participation in the IGO. Over the next decade, the OIG began adding “integrity rules” requiring the supplier/company to put in place an effective compliance program that reflected the practices outlined in the guidelines. The guidelines required seven steps to ensure minimal compliance. In addition, the OIG has added requirements that allow for the inspection and verification of compliance programs and require an annual report from the supplier/unit to the OIG on its CIA compliance efforts. This article contains public service information from the U.S. Department of Health document: “Corporate Integrity Agreements Snapshot” (PDF). Retrieved April 14, 2018. The OIG will regularly carry out unannounced on-site visits to any service provider currently governed by a corporate integrity agreement. This must ensure that the government, by observing first-hand, the physician or organization complies with all necessary policies and standards. Depending on the size of the organization involved, the visit can last from two days to two weeks. During the visit, the IGO will visit the facility, review all documents and conduct interviews with staff.
The OIG official will then discuss the results with the company`s compliance officer. Some CIAs require an independent organization to verify and monitor compliance with the CIA`s terms and conditions. Most ASCI require damage checks to identify errors and their underlying causes.  The government authority may verify compliance through on-site visits.  If a company violates the agreement, the Agency can sanction it and if the problems cannot be resolved, the supplier can be excluded.  A corporate integrity agreement is a legally binding agreement between the Department of Health and Human Services and a private health care provider that settles a federal case for fraud to a federal health program such as Medicare or Medicaid. Through this agreement, physicians can continue to process and accept Medicare and Medicaid claims as long as they comply with the specific guidelines set out in the agreement. This agreement is only used in civil cases involving Medicare and Medicaid fraud, not in criminal cases with similar charges….