Corporate Integrity Agreements

Overview

The purpose of a Corporate Integrity Agreement (CIA) is to promote adherence with the requirements of New York State’s Medicaid program by the Medicaid provider and the provider's officers, directors, employees, and contractors.

CIAs are part of an enforcement action that are an alternative to termination of the provider’s Medicaid contract or exclusion from the Medicaid program. If a provider has committed an act that could have caused that provider to be excluded from the Medicaid program, the regulatory agencies through coordination with OMIG's Bureau of Compliance, may consider allowing the provider to remain in the Medicaid program on the condition that the provider enter into a CIA with OMIG and comply with the CIA's terms.

The CIA's requirements create a structure reinforcing operation by the provider at an acceptable standard. All CIAs include a standard set of requirements related to the development of an effective compliance program. A CIA may include additional requirements specific to the provider and to the provider’s covered conduct. The term “covered conduct” is the provider’s specific conduct that resulted in the need for a CIA.

CIAs run for a five-year period with the requirement for the provider to engage an Independent Review Organization (IRO) for the term of the CIA. The IRO must be acceptable to OMIG and the provider pays the IRO for their services.  However, the IRO is required to act independently from the provider and on the direction of OMIG.

At any point of the CIA, a material breach of the terms could lead to the provider’s exclusion from the Medicaid program.

At the close of the CIA, deliverables must demonstrate that the provider has an effective compliance program in place and is meeting the requirements of the Medicaid program.

Provider Name CIA Effective Date Status Provider Type
Ralex Services, Inc., d/b/a Glen Island Center for Nursing and Rehabilitation 04/01/2016 Active Long Term Care
Elant, Inc. 03/02/2016 Active Long Term Care
Elant at Brandywine, Inc. 03/02/2016 Active Long Term Care
Elant at Fishkill, Inc. 03/02/2016 Transferred Long Term Care
Yertle Operations, LLC (Fishkill) 04/27/2017 Active Long Term Care
Sapphire Nursing at Wappingers, LLC 04/27/2017 Active Long Term Care
Glen Arden, Inc. 03/02/2016 Active Long Term Care
Elant at Goshen, Inc. 03/02/2016 Transferred Long Term Care
Goshen Operations, LLC 09/01/2017 Active Long Term Care
Elant at Newburgh, Inc. d/b/a Elant at Meadow Hill 03/02/2016 Transferred Long Term Care
Newburgh Operations, LLC 09/01/2017 Active Long Term Care

STATUS KEY:

Active: CIA is currently in effect.

Expired: CIA has expired by the terms of CIA or a subsequent agreement and is no longer in effect.

Suspended: CIA has not been terminated or expired, but is not being actively enforced.  During the period of suspension, the CIA can be reactivated at any time by OMIG, in its sole discretion.

Terminated: Termination of the CIA by OMIG following:

  1. A termination by OMIG in OMIG’s sole judgment following a final decision that has the effect of excluding the Provider from the Medicaid program in New York State when such decision is related to an exclusionary proceeding outside the terms of this CIA.
  2. The CIA being terminated by OMIG, as a result of a Material Breach of the CIA by the Provider, as such Material Breach is reasonably determined by OMIG in its sole judgment.
  3. Notwithstanding 1 and 2 above the CIA may be terminated in OMIG’s sole discretion.

Transferred: As the CIA shall be binding on the successors, assigns and transferees of the Provider, the CIA has been transferred to new owners or purchasers.