Corporate Integrity Agreements / OIG's frequently asked questions on CIAs

Why This Topic Matters

Providers subject to a CIA must understand OIG’s expectations so they can prepare annual reports, structure billing reviews, and document review results in a way that aligns with their agreement and avoids compliance problems. The FAQ format makes it especially relevant for teams responsible for audits, repayments, and independent review organization oversight.

Article Sections

1. OIG FAQ overview and reporting expectations

   Introduces the FAQ guidance and frames the general reporting expectations for providers operating under corporate integrity agreements. It covers the relationship between CIA terms and OIG’s broader guidance.

2. Overpayments, material violations, and reporting to OIG

   Addresses how providers under CIAs should handle identified overpayments, material deficiencies, and related annual reporting issues. It also discusses how underpayments may factor into payer discussions.

3. Independent review organization independence and selection

   Discusses how independence is evaluated for review entities and the limits on OIG involvement in selecting outside vendors or consultants. It also touches on concerns that may arise during annual report review.

4. Billing review methods, sampling, and documentation

   Summarizes OIG guidance on billing review structure, sample selection, statistical validity, and the documentation expected in annual submissions. It includes discussion of review findings, sample populations, and reporting format.

5. RAT-STATS and statistical sampling guidance

   Covers OIG’s statistical sampling software and the steps used to support CIA billing reviews. The section discusses random selection, variable appraisal, sample size estimation, and related submission materials.

6. Sampling unit evaluation and review outcomes

   Explains how reviewers assess sampled items, handle missing supporting documentation, and treat underpayments during the review process. It also addresses alternate records and threshold-related issues.

7. CIA billing review provisions and changes in payment methodology

   Discusses how providers should approach billing review provisions when federal payment methods change. It references the need to coordinate with OIG when older CIA language may no longer fit current reimbursement systems.