Implementing CIA Learning

Posted by Amanda Holm on Jun 17, 2014 2:10:58 PM

A Real-World Roadmap to Successful CIA Learning Rollout


The PDG white paper, Implementing CIA Learning, provides an overview of planning and implementing the learning programs that are required as part of a Corporate Integrity Agreement (CIA). Here’s a selection from the white paper:

The learning components of a Corporate Integrity Agreement are unique and different from any other type of corporate learning your organization will do. Traditional learning models aren’t enough for CIA learning; a CIA has very specific legal and regulatory requirements, and failure to meet them comes at a significant cost. An organization managing a CIA needs a very specific learning strategy for success, a pragmatic plan which is outlined in this white paper.

What is a CIA?

The United States Office of Inspector General (OIG) at the Department of Health and Human Services defines a CIA as follows:

A Corporate Integrity Agreement (CIA) is a document that outlines the obligations an entity agrees to as part of a civil settlement. An entity agrees to the CIA obligations in exchange for the OIG’s agreement that it won’t seek to exclude entity from participation in Medicare, Medicaid or other Federal health care programs. The CIAs have common elements, but each one is tailored to address the specific facts of the case and CIAs are often drafted to recognize the elements of a pre-existing compliance program.

The manufacturers and distributors of pharmaceuticals, biologics, and medical devices are the most frequent recipients of CIAs, and CIAs are typically issued as part of the settlement relating to actions an entity has taken in violation of government regulations. Therefore, virtually all CIAs include provisions that the entity takes steps to change practices and behaviors that led to previous violations.

What is your CIA Learning Readiness?

How will you…

  •          Identify and locate Covered Persons?
  •          Determine your LMS and certification ability?
  •          Reach your vendors and contractors?
  •          Identify what content you have and what you need to develop?
  •          Communicate with OIG and your internal stakeholders?
  •          Deal with constant changes and updates?
  •          Resource your CIA team?
  •          Rollout and track effectively?

…all within 120 days?


Want to learn more? You can download the white paper here for free! You can also find out more about implementing CIA learning with these resources:


Topics: Corporate Integrity Agreement