What is the OIGs policy regarding the reporting of Federal health care program overpayments by providers under Corporate Integrity Agreements (CIAs)?
Providers under CIAs must promptly notify the appropriate payor of all identified overpayments and must promptly repay the overpayment amount in a manner consistent with the payor’s policies. Although all identified overpayments should be refunded to the appropriate payor, a provider under a CIA does not need to report to the OIG all identified overpayments at the time it reports such amounts to the payor. Rather, the provider must report to the OIG the yearly aggregate overpayment amount in its annual report. Further, the provider must report to the OIG within 30 days all “reportable events” as defined by the CIA. “Reportable Event” generally means anything that involves: (i) a substantial overpayment; (ii) a matter that a reasonable person would consider a potential violation of criminal, civil, or administrative laws applicable to any Federal health care program for which penalties or exclusion may be authorized; or (iii) the filing of a bankruptcy petition. A reportable event may b
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