The federal Office of the Inspector General (OIG) has updated COVID-19 information related to Corporate Integrity Agreement (CIA) deadlines, OIG review deadlines and OIG enforcement activity.
According to OIG, it is trying to minimize burdens on providers and be flexible where possible, taking into account burdens on providers and the safety of patients, health care staff and OIG staff as it plans new work.
Health care organizations that need extensions of OIG deadlines, such as to produce data for an OIG review or to comply with a Corporate Integrity Agreement, are encouraged to ask their OIG contact to work on a reasonable solution, OIG reports. Mail service has been temporarily suspended so OIG is encouraging electronic submission of any materials that would ordinarily have been mailed.
For any conduct during this emergency that may be subject to OIG administrative enforcement, OIG will carefully consider the context and intent of the parties when assessing whether to proceed with any enforcement action.
To further assist health care organizations, OIG is accepting inquiries from the health care community regarding the application of OIG’s administrative enforcement authorities, including the federal anti-kickback statute and civil monetary penalty (CMP) provision prohibiting inducements to beneficiaries.
If you have a question regarding how OIG would view an arrangement that is directly connected to the public health emergency and implicates these authorities, submit your question to OIGComplianceSuggestions@oig.hhs.gov. In your submission, please provide sufficient facts to allow for an understanding of the key parties and terms of the arrangement at issue.
More information, including frequently asked questions and a dedicated COVID-19 portal, see https://oig.hhs.gov/coronavirus/authorities-faq.asp.