Legal
OIG Releases Updated Corporate Integrity Agreement Template with Enhanced Compliance Requirements
On April 30, 2026, the HHS Office of Inspector General unveiled a revised Corporate Integrity Agreement template at the Health Care Compliance Association's annual conference, using the Kinex Medical Company CIA as the model. The updated template retains core compliance program elements while introducing enhanced compliance obligations for health care organizations entering into settlement agreements with OIG. CIAs are typically imposed on providers and health plans that resolve fraud and abuse allegations, requiring heightened compliance measures for three to five years. The new template will apply to future CIA settlements and affects any Medicaid managed care organization facing potential OIG enforcement actions.
Why it mattersMedicaid MCOs entering into OIG settlement agreements will face stricter compliance monitoring, reporting, and oversight requirements under the new CIA framework, increasing administrative costs and operational complexity during the agreement period.