CPMA terms, Exam sections Coverage,
rated A+
Certificate of compliance agreement - ✔✔-Require the provider to certify that it will continue to operate
its existing compliance programs and to report to OIG for a lesser period of time (usually 3 years)
Corporate integrity agreements - ✔✔-A condition of not seeking exclusion from participation when an
entity seeks to settle CIVIL health care fraud cases. Typically last 5 years.
Circumstances that the OIG would consider relative to CIA:
1. Whether the provider self disclosed alleged conduct;
2. The monetary damage to federal healthcare programs;
3. Whether the case involves succesor liability;
4. Whether the provider is still participating in the federal healthcare programs or in the line of business
that gave rise to the fraudulent conduct;
5. Whether the alleged conduct is capable of repetition;
6. The age ofthe conduct;
7. Whether the provider has an effective compliance program and would agree to limited compliance or
integrity measures and would ANUALLY certify such compliance to the OIG; and
8. Other circumstances, as appropriate.
Independent review organization - ✔✔-Acts as 3rd party medical review source that provides objective,
unbiased audits and reports. Hired by tge auditee's legal counsel working on behalf of the OIG.
Fraud - ✔✔-Making false statements or misrepresenting facts to obtain undeserved payment or benefit
from a federal health care program.
rated A+
Certificate of compliance agreement - ✔✔-Require the provider to certify that it will continue to operate
its existing compliance programs and to report to OIG for a lesser period of time (usually 3 years)
Corporate integrity agreements - ✔✔-A condition of not seeking exclusion from participation when an
entity seeks to settle CIVIL health care fraud cases. Typically last 5 years.
Circumstances that the OIG would consider relative to CIA:
1. Whether the provider self disclosed alleged conduct;
2. The monetary damage to federal healthcare programs;
3. Whether the case involves succesor liability;
4. Whether the provider is still participating in the federal healthcare programs or in the line of business
that gave rise to the fraudulent conduct;
5. Whether the alleged conduct is capable of repetition;
6. The age ofthe conduct;
7. Whether the provider has an effective compliance program and would agree to limited compliance or
integrity measures and would ANUALLY certify such compliance to the OIG; and
8. Other circumstances, as appropriate.
Independent review organization - ✔✔-Acts as 3rd party medical review source that provides objective,
unbiased audits and reports. Hired by tge auditee's legal counsel working on behalf of the OIG.
Fraud - ✔✔-Making false statements or misrepresenting facts to obtain undeserved payment or benefit
from a federal health care program.
