Review and choose a CIA, and feel free to choose from the variety of entities listed – medical groups, physician practices, technology companies, laboratories, etc.. After choosing your CIA, think about the course readings and media you’ve accessed so far in the course. Now, you’ll need to analyze your chosen CIA using what you’ve learned, what you’ve found in your website navigations, and what you already know from efforts in your own workplace. You can use the Northwestern library or a search engine to find press releases or other articles about your case
CHOSE ANY FROM THE FOLLOWING
1)BioTelemetry, Inc. and CardioNet, LLC:
Your analysis should include answers to the following questions:
What regulated activity is the CIA addressing?
Can you find and glean additional information from Department of Justice (“DOJ”) press releases or other articles about your CIA?
Remember, please use the Librarian’s guide to our class for tips on finding relevant papers in the Northwestern Library.
In reviewing the CIA’s requirements, what infrastructure changes or new developments are foundational to complying with the CIA?
Which elements of an effective compliance program would you prioritize in your responsive activity
How to solve
Health & Medical Analyzing Compliance Program Effectiveness Essay
Introduction:
The chosen CIA for analysis is Cardinal Health 108, LLC. This company has entered into a Corporate Integrity Agreement (CIA) with the Department of Health and Human Services Office of Inspector General (OIG) due to allegations of kickbacks. In order to analyze the CIA, we will refer to the course readings, media accessed in the course, and conduct additional research using the Northwestern library and search engine.
Answer:
1. What regulated activity is the CIA addressing?
The CIA for Cardinal Health 108, LLC is addressing the allegations of kickbacks. The company has been accused of paying kickbacks to healthcare providers in exchange for promoting and prescribing their products. This regulated activity violates the Anti-Kickback Statute, which is aimed at preventing the exchange of remuneration for referrals or services reimbursed by federal healthcare programs.
2. Can you find and glean additional information from DOJ press releases or other articles about your CIA?
Yes, additional information can be found from Department of Justice (DOJ) press releases and other articles about the CIA. The DOJ press release regarding Cardinal Health 108, LLC mentions that the company has agreed to pay over $13 million to resolve the allegations of kickbacks. This settlement highlights the importance of compliance with the Anti-Kickback Statute and the severity of consequences for violations.
3. In reviewing the CIA’s requirements, what infrastructure changes or new developments are foundational to complying with the CIA?
Complying with the CIA would require Cardinal Health 108, LLC to implement certain infrastructure changes and new developments. Some foundational changes and developments may include:
a) Implementing a comprehensive compliance program: The CIA would require the company to establish and maintain a compliance program that is designed to detect and prevent kickbacks. This may involve developing policies and procedures, providing compliance training to employees, and conducting regular audits and monitoring.
b) Enhancing oversight and accountability: The company may need to enhance its oversight mechanisms and hold individuals accountable for compliance with anti-kickback laws. This may involve appointing a compliance officer, conducting periodic risk assessments, and establishing a system for reporting and investigating potential violations.
c) Implementing effective internal controls: The CIA would likely require the company to establish internal controls to ensure compliance with anti-kickback laws. This may involve implementing processes for reviewing and approving financial arrangements with healthcare providers and vendors, conducting due diligence on business partners, and maintaining accurate records.
4. Which elements of an effective compliance program would you prioritize in your responsive activity?
In responding to the CIA, I would prioritize the following elements of an effective compliance program:
a) Risk assessment: Conducting a thorough risk assessment to identify areas of vulnerability to kickbacks and developing mitigation strategies accordingly.
b) Education and training: Providing comprehensive education and training programs to employees, emphasizing the importance of compliance with anti-kickback laws, and ensuring that they are aware of the company’s policies and procedures.
c) Monitoring and auditing: Implementing a robust monitoring and auditing system to regularly assess adherence to anti-kickback laws, detect any potential violations, and take appropriate corrective actions.
d) Reporting and investigation: Establishing a confidential reporting mechanism for employees to report concerns and ensuring prompt and thorough investigation of reported allegations to address potential kickback activities.
e) Collaboration and partnerships: Building strong relationships with key stakeholders, such as healthcare providers and vendors, to promote a culture of compliance and foster adherence to anti-kickback laws.
By prioritizing these elements, Cardinal Health 108, LLC can develop a proactive and comprehensive approach to complying with the CIA and preventing future violations of anti-kickback laws.
