OIG Enters into Corporate Integrity Agreement with The Christ Hospital

The Office of Inspector General (OIG) for the Department of Health and Human Services and The Christ Hospital of Cincinnati, Ohio (TCH) entered into a Corporate Integrity Agreement (CIA) today. The CIA resolves OIG’s possible exclusion of TCH from participation in Federal health care programs, which, if imposed, would have prohibited Medicare and Medicaid from paying TCH for health care items and services.

“This case exemplifies OIG’s commitment to protecting the integrity of Federal health care programs from the influence of improper kickbacks,” said Daniel R. Levinson, Inspector General of the Department of Health and Human Services. This administrative case was resolved after OIG met directly with TCH’s Board of Trustees. “OIG has maintained throughout negotiations with TCH that independent monitoring was needed to oversee the hospital’s compliance with Federal health care program requirements,” Mr. Levinson added. “Once TCH’s Board of Trustees met with OIG, we were able to successfully negotiate a CIA and close the door on this multi-year investigation.”

On May 24, 2010, OIG notified TCH that OIG was considering excluding TCH based on evidence that TCH improperly rewarded cardiologists for referring patients to TCH in violation of the anti-kickback statute. The facts underlying the potential exclusion formed the basis of the Government’s May 21, 2010, settlement in United States ex rel. Fry v. Health Alliance of Greater Cincinnati, et al., Case No. 1:03-cv-00167 (S.D. Ohio). TCH and The Health Alliance for Greater Cincinnati paid $108 million to resolve False Claims Act liability for the conduct.

Under the terms of the 5-year CIA, TCH is required to implement compliance measures, hire an outside reviewer of its financial relationships with physicians, and be monitored by OIG. The CIA also includes a provision requiring a committee of the Board of Trustees to annually review the company’s compliance program and certify its effectiveness. According to TCH, the hospital agreed to the corporate integrity agreement “to further demonstrate beyond any doubt that the hospital’s leadership is conducting every aspect of its business with the highest ethical standards and in full compliance with all Federal and State laws and regulations.”