In addition to the $10 million payment, Saber agreed to enter into a five-year, integrity agreement (CIA) with the Department of Health and Human Services (HHS) Office of the Inspector General (OIG). As part of the agreement, an independent organization will “verify the medical necessity and adequacy of the therapeutic services charged to Medicare.” Some CLAs ask an independent organization to verify and monitor compliance with CIA conditions. Most CLAs require harm checks to identify errors and their underlying causes.  The government authority can verify compliance through on-site visits.  If a company violates the agreement, the Agency can fine it and, if the problems cannot be resolved, the supplier may be excluded.  A Corporate Integrity Agreement (CIA) is a document that describes the obligations that a U.S. health care company performs with a federal authority or a state government under a civilian regime. At the federal level, the office of the Inspector General of the Department of Health and Justice Services and the Department of Justice are generally involved and, at the state level, the attorney general and state offices participating in Medicaid or Medicare are involved.  Since the purpose of the HHS Office of Inspector General is to investigate fraud and abuse of the Medicare and Medicaid programs, it has the power to initiate settlement negotiations to prevent health care providers from being prosecuted for fraud and abuse. For health care providers involved in an investigation into health fraud, reaching an Enterprise Integrity Agreement (CIA) with the Office of Inspector General (OIG) is often a necessary condition for resolving the problem. In accordance with the provisions of the OIG Corporate Integrity Agreement, health care providers must accept a number of detailed compliance obligations. In exchange, they will have the opportunity to avoid the exclusion of Medicare, Medicaid or other federal health programs, which is a financially devastating outcome for any health organization. The CIA can be used to address issues of quality of care or corporate integrity.
 While compliance is difficult and generally costly to meet, OIG Corporate Integrity Agreements leads organizations to implement an effective public health compliance program that ultimately leads to proper billing practices. These include submitting specific and comprehensive payment requests to federal health programs, appropriate agreements with physicians, and improving the quality of care provided to program recipients. Since the OIG Corporate Integrity Agreement is a contractual agreement between the OIG and a health organization requiring the organization to meet a defined set of compliance obligations, it is important to meet all conditions. Violations of the OIG Corporate Integrity Agreement and non-compliance with obligations under the agreement may result in severe penalties, including the possible exclusion of participation in federal public health programs.