Corporate Integrity Agreement F.A.Q.
What is a corporate integrity agreement? (CIA)?
A Corporate Integrity Agreement (CIA) is a document that typically spells out activities and methods to follow to ensure statutory and regulatory compliance standards are met and reported appropriately.
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Is this an unusual or surprising development for UMDNJ?
No. We have expected this for several years. The signing of a CIA is usually anticipated by institutions that have settled charges in connection with civil violations of Medicare and other Federal healthcare programs and have avoided the costs of defending themselves against those charges. In fact, hundreds of CIAs exist, including at other universities.
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So the CIA is a result of the old problems that led to the federal monitorship and the Deferred Prosecution Agreement, and not anything new?
Yes, this is directly related to the problems that were discovered here several years ago and led to the Deferred Prosecution Agreement and the federal monitor. We have dramatically transformed the manner in which we conduct business at UMDNJ as a result of those problems, and we are proud of the enormous progress we have made. The CIA is another step in this very lengthy process of getting our house thoroughly in order. When we entered into the Deferred Prosecution Agreement in 2005, we understood that a CIA like this would follow as another important step in the process to ensure that we are fully compliant with all laws and regulations.
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Who are the parties in this agreement?
The CIA is between UMDNJ and the Office of Inspector General (OIG) of the United States Department of Health and Human Services.
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What does the CIA require UMDNJ to do?
The CIA spells out certain requirements for conducting and monitoring our compliance and for periodic reporting about it to the OIG. Included among them is the requirement that training be provided to virtually all members of the UMDNJ community to ensure full regulatory and legal compliance and adherence to the UMDNJ Code of Conduct.
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How will the CIA affect individuals at UMDNJ?
Many employees will be required to complete approximately one hour of training annually to ensure an understanding of the CIA and of our compliance programs. Other employees will be required to complete additional training, up to five hours annually, such as those employees whose responsibilities involve coding and submission of healthcare claims, documentation of medical records and the submission and preparation of cost reports and contracts.
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Does the CIA mean that we will once again be implementing different procedures to ensure compliance?
We do not anticipate the need for making significant changes. We are proud of what we’ve accomplished in the past few years and are confident that the many significant changes we’ve already implemented to ensure full compliance are consistent with the provisions of the CIA. The compliance program we have in place is at least as stringent, if not more so, than any typically found at a major university or academic medical system. Under the CIA, UMDNJ has many monitoring and reporting requirements to meet. We may find it appropriate to modify our Compliance Program, but at a minimum, UMDNJ must ensure that it complies with the integrity obligations spelled out in the CIA.
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In addition to beefing up its compliance efforts, what else has UMDNJ done in recent years to change its culture and to ensure business is conducted ethically and in the appropriate environment?
UMDNJ has implemented a number of major changes and reforms to change the culture and its way of operating. Among them: a new senior management was recruited; a robust and transparent ethics, investigatory and auditing infrastructure was put in place; a zero tolerance policy for wrongdoing or unethical behavior was instituted; a confidential hotline through which employees can report wrongdoing was implemented, and purchasing procedures were overhauled.
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What types of personnel changes were made to help change the culture?
Employees who were found to have engaged in wrongdoing have been dismissed. They represent a relatively small number of the approximately 15,000 employees.
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Will the CIA require that more people be hired to manage compliance activities?
Under the agreement, we are required to retain an “Independent Review Organization” (IRO) to assist in assessing the level of our compliance in certain areas. We do not anticipate hiring additional staff.
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How long will the CIA remain in affect?
The CIA agreement covers a period of five years.
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What will happen if UMDNJ does not meet its obligations as spelled out in this CIA?
UMDNJ would likely be subject to monetary penalties for failure to adhere to its obligations.
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