CVS Caremark Corporate Integrity Agreement: What You Need to Know
In 2008, CVS Caremark, the largest pharmacy health care provider in the United States, entered into a Corporate Integrity Agreement (CIA) with the U.S. Department of Health and Human Services Office of Inspector General. This agreement came after a series of investigations that revealed the company’s non-compliance with several federal laws.
The agreement stipulated that CVS Caremark would undertake several corrective actions to address the issues and reinforce its commitment to corporate integrity and compliance.
What Led to the CIA?
The investigations leading up to the CIA uncovered several issues, including the company’s failure to comply with the Federal False Claims Act, which prohibits the submission of false or fraudulent claims to the government.
The investigations also revealed that CVS Caremark had operated several non-compliant programs, including a prescription drug discount program that violated state and federal anti-kickback laws. Additionally, the company failed to adequately protect the privacy of its customers’ health information, putting them at risk of identity theft and other forms of fraud.
What Does the CIA Entail?
The CIA required CVS Caremark to implement several corrective measures, including:
1. Enhancing its compliance program: CVS Caremark was required to develop and implement an improved compliance program to ensure that the company and its employees complied with all federal health care programs.
2. Establishing a compliance committee: The company was required to establish a compliance steering committee made up of senior executives to oversee the implementation of its compliance program.
3. Conducting annual audits: CVS Caremark was required to conduct annual audits of its claims and payment processes to ensure compliance with federal laws.
4. Improving privacy and security measures: The company was required to implement enhanced privacy and security measures to protect the health information of its customers.
5. Hiring an independent monitor: CVS Caremark was required to hire an independent monitor to oversee its compliance with the CIA for five years.
What Has Changed Since the CIA?
CVS Caremark has implemented several changes to its operations since the CIA was put in place. The company has improved its compliance program, established a compliance steering committee, and conducted annual audits to ensure compliance.
Additionally, CVS Caremark has implemented enhanced privacy and security measures to protect its customers’ health information. The company has also made significant changes to its prescription drug discount program, bringing it into compliance with anti-kickback laws.
Conclusion
The CVS Caremark Corporate Integrity Agreement serves as a reminder of the importance of corporate integrity and compliance with federal laws. The corrective actions taken by the company since the CIA was put in place have reinforced its commitment to compliance and improved its operations overall.
As a consumer, it is essential to be aware of the compliance practices of the companies you interact with, particularly those in the healthcare industry. Being informed can help you make more informed decisions and protect your interests.