Which is a core element of a CIA?

• A. Eliminate all third-party contractors
• B. Require external accreditation for all staff
• C. Provide free consumer education programs
• D. Hire a compliance officer and appoint a compliance committee

Answer: (D)

In a Corporate Integrity Agreement, strong governance and leadership over the compliance program are essential. Having a dedicated compliance officer to run day-to-day activities—policies, training, risk assessments, monitoring, investigations, and reporting—to the organization’s leadership ensures accountability and effective oversight. A compliance committee provides independent oversight, reviews progress, approves resources, and reinforces board-level accountability. This combination creates the structure needed for the CIA to function and for the organization to detect and address issues promptly.

The other options don’t establish that governance backbone. Eliminating all third-party contractors isn’t a practical or required CIA feature; vendor management and due diligence are addressed through risk controls, not wholesale elimination. Requiring external accreditation for all staff isn’t a standard CIA obligation, though ongoing education may be part of a broader program. Providing free consumer education programs is commendable for patient relations, but it isn’t a core CIA requirement.

Therefore, hiring a compliance officer and appointing a compliance committee best aligns with the governance framework the CIA establishes.