Corporate Integrity Agreements and Corporate Compliance Programs
Presented by Lynn Shapiro Snyder and Constance Wilkinson
In a little-noticed decision, the Office of the Inspector General of the Department of Health and Human Services (OIG) forced a company that violated its corporate integrity agreement (CIA) to divest a subsidiary as a condition for the parent to avoid exclusion from federal health care programs. Not only is forced divestiture a relatively new enforcement approach for the OIG, this appears to be the first time the OIG has used forced divestiture as a sanction for violations of a CIA. The move signals the OIG's continuing willingness to achieve program compliance through novel uses of its enforcement authority.
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