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Corporate Integrity Agreement Gone Wrong: OIG Excludes Entity Found Non-Compliant with CIA

April 4, 2014 | Comments Off on Corporate Integrity Agreement Gone Wrong: OIG Excludes Entity Found Non-Compliant with CIA
Posted by Beth Christian

On April 3rd, the OIG issued a press release announcing that it was excluding CSHM, LLC (“CSHM”), a pediatric dental management chain, from participation in the Medicare and Medicaid programs for a period of five years.  CSHM operates a national chain of pediatric dental facilities known as Small Smiles Dental Centers, which primarily serves Medicaid recipients. CSHM’s corporate predecessor had executed a Corporate Integrity Agreement in 2010.

The OIG found that CSHM had materially breached its obligations under the CIA. According to the OIG’s press release, CSHM failed to report serious quality-of-care reportable events, take corrective action, or make appropriate notifications of those events to the State dental boards as required by the CIA. The OIG press release also indicated that CSHM failed to implement and maintain significant quality-related policies and procedures, comply with internal quality and compliance review requirements, properly maintain a log of compliance disclosures, and perform training as required by the CIA.  The OIG also noted that CSHM submitted a false certification from its Compliance Officer regarding its compliance with CIA obligations.

The action taken by the OIG serves as an important reminder to providers operating under a CIA that signing a Corporate Integrity Agreement is only the first step in a series of compliance obligations that must be met while the CIA is in effect. Providers that fail to comply with such obligations do so at their peril and risk Medicare/Medicaid exclusion.


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