What is a corporate integrity agreement? Find one that mentions either a Stark or Anti-Kickback violation. Which provider was cited? What was their penalty?
Performing the Role of a Compliance Officer Team Project
You are the very first compliance officer at a hospital system comprised of four hospitals and seven physician offices. The hospital system has a non-profit status. The
chairman of the board wants to know more about your role and what you will be accomplished for the hospital system. More importantly, he is very concerned about
possible liability both enterprise-wide and personal in nature. The Chairman also serves as the chief surgeon of the hospital system. Other members of the board
include the COO, CEO, Attorney, an anesthesiologist, an oncologist, an accountant and a nurse manager.
Answer the following:
1. What is a corporate integrity agreement? Find one that mentions either a Stark or Anti-Kickback violation. Which provider was cited? What was their penalty?
2. Can the board of directors be held personally liable for Stark and/or Anti-Trust violations? What do they need to know to avoid personal exposure? Where can they
learn more about their potential legal liability?
3. Create a list of sources for future use: the CFR section, a law review article, links to federal websites, stakeholder associations for hospitals, one hospital website
that describes their compliance program, a white paper or journal article and a news article