Corporate Integrity Agreement: Broward Health
Broward Health is a public healthcare system that comprises multiple hospitals, clinics, and other healthcare facilities. In recent years, Broward Health has been the subject of several investigations, including a criminal probe by the federal government. As a result of these investigations, Broward Health has entered into a Corporate Integrity Agreement (CIA) with the Department of Health and Human Services (HHS) to strengthen its compliance program and ensure that its operations are conducted with integrity and transparency.
What is a Corporate Integrity Agreement (CIA)?
A Corporate Integrity Agreement is a legal agreement between a healthcare organization and the HHS. CIAs are often entered into when there are allegations of fraud or other wrongdoing, and they are designed to help healthcare organizations establish and maintain an effective compliance program. CIAs typically last for several years and require the organization to implement specific measures to improve its compliance with federal healthcare regulations.
What is Broward Health`s CIA?
Broward Health entered into a five-year CIA with the HHS in 2015. The CIA requires Broward Health to implement a variety of measures to improve its compliance program, including the following:
1. Hiring a Chief Compliance Officer (CCO)
Broward Health is required to hire a CCO who will be responsible for overseeing the compliance program and reporting directly to the CEO and Board of Commissioners. The CCO must have the appropriate qualifications and experience to carry out their responsibilities effectively.
2. Conducting Compliance Training
Broward Health must provide regular compliance training to its employees, contractors, and vendors. The training must cover a variety of topics, including healthcare fraud and abuse laws, the False Claims Act, and HIPAA.
3. Establishing a Hotline
Broward Health must establish a hotline for employees, contractors, and vendors to report suspected violations of federal healthcare laws. The hotline must be confidential and available 24/7.
4. Conducting Audits and Monitoring
Broward Health must conduct regular audits and monitoring of its operations to identify and address potential compliance issues. The CIA requires Broward Health to establish a formal process for conducting audits and monitoring, and to provide regular reports to the CCO and the Board.
5. Engaging an Independent Monitor
Broward Health is required to engage an independent monitor to review and assess its compliance program. The monitor must be an independent third-party with the necessary expertise and experience to evaluate Broward Health`s compliance program.
Why is the CIA Important?
The CIA is important for several reasons. First, it helps to ensure that Broward Health is operating with integrity and transparency. By implementing the measures required by the CIA, Broward Health is demonstrating a commitment to compliance with federal healthcare regulations and to preventing healthcare fraud and abuse.
Second, the CIA helps to protect the public by ensuring that Broward Health is providing high-quality, safe, and effective healthcare services. Compliance with federal healthcare regulations is critical to ensuring that patients receive the care they need and that they are not subjected to unnecessary or harmful treatments.
Finally, the CIA is important because it helps to maintain the trust and confidence of the public in Broward Health. Healthcare organizations that are perceived as being dishonest or unethical can lose the trust of their patients, employees, and the community at large. By demonstrating a commitment to compliance with federal healthcare regulations, Broward Health is working to build and maintain the trust and confidence of its stakeholders.
Conclusion
Broward Health`s Corporate Integrity Agreement with the Department of Health and Human Services is an important step in ensuring that Broward Health is operating with integrity and transparency. By implementing the measures required by the CIA, Broward Health is demonstrating a commitment to compliance with federal healthcare regulations and to preventing healthcare fraud and abuse. The CIA is critical to ensuring that patients receive high-quality, safe, and effective healthcare services and to maintaining the trust and confidence of the public in Broward Health.
