Which statement describes a Corporate Integrity Agreement?

• A. A privacy policy
• B. A contract with suppliers
• C. A performance improvement plan
• D. The agreement that spells out integrity measures required of a provider that has engaged in serious misconduct but is being allowed to continue participating in the healthcare programs

Answer: (D)

Corporate Integrity Agreements are formal, binding arrangements with a government enforcement agency that require a provider to implement specific integrity and compliance measures in order to continue participating in federal healthcare programs after serious misconduct. They’re negotiated as part of settlements and outline concrete requirements such as a comprehensive compliance program, assignment of a compliance officer, ongoing training, periodic audits or monitoring, and regular reporting to the agency. This describes the scenario where a provider has engaged in serious misconduct but is still allowed to participate in healthcare programs, under overseen conditions. It’s different from a privacy policy, which governs patient data privacy; a contract with suppliers, which is a business agreement with vendors; or a performance improvement plan, which is an internal effort to improve performance and isn’t tied to government oversight of program participation.