The Office of Inspector General of the Department of Health and Human Services has entered into a corporate integrity agreement with Tenet Healthcare Corporation. The agreement is part of Tenet’s resolution of its civil and administrative liability for a wide range of investigated conduct, including diagnosis-related group upcoding, improper outlier payments, kickbacks to physicians, and other fraudulent activities. In June, Tenet also agreed to pay more than $900 million to the United States in exchange for a release of its liability.
The five-year agreement requires that Tenet implement a comprehensive compliance program; provide a variety of general and specialized compliance training to its employees, contractors, physicians, and those who serve on Tenet hospital governing boards; establish an employee hotline and reporting mechanism; and repay overpayments. The agreement also requires that Tenet maintain its existing quality initiatives and companywide compliance program; formalize in writing its policies and procedures in the areas of billing, , reimbursement, and compliance; provide a variety of general and specialized compliance training to its employees, contractors, and physicians it employs or who serve on a Tenet hospital governing board; and engage independent outside entities to provide reviews of compliance and effectiveness in five areas, including Medicare outlier payments, DRG claims, unallowable costs, physician financial arrangements, and clinical quality systems.
“We believe the requirements of this corporate integrity agreement are consistent with standards we already live by and principles we strongly believe in,” said Trevor Fetter, Tenet’s president and CEO, in a statement. “Because of the many changes and enhancements we have made at Tenet in the past three years, we already have in place many of the procedures and systems called for by this corporate integrity agreement.”
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