In February and August 2012, the Office of Inspector General (“OIG”) of the Department of Health and Human Services (“HHS”) held roundtable discussions with compliance representatives from 32 companies that had entered into Corporate Integrity Agreements (“CIAs”) with the OIG since 2009. The discussions were designed to provide feedback to the OIG on practical implementation issues associated with CIA requirements. Both roundtables addressed challenges with CIA implementation and offered suggestions for improvement. The OIG summarized the discussions in two summary reports: Report from February 23, 2012, Pharmaceutical Compliance Roundtable, issued on March 26, 2012, and Focus on Compliance: The Next Generation of Corporate Integrity Agreements, issued on October 9, 2012. It also noted areas where companies expressed an intention to continue CIA-based practices even after their CIA expires. These references may be seen as an attempt by OIG to mold best practices for compliance programs industrywide.
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