Corporate Integrity Agreement between OIG and The Christ Hospital in Cinncinnati, Ohio

From the OIG Press Release:

On May 24, 2010, OIG notified TCH that OIG was considering excluding TCH based on evidence that TCH improperly rewarded cardiologists for referring patients to TCH in violation of the anti-kickback statute. The facts underlying the potential exclusion formed the basis of the Government’s May 21, 2010, settlement in United States ex rel. Fry v. Health Alliance of Greater Cincinnati, et al., Case No. 1:03-cv-00167 (S.D. Ohio). TCH and The Health Alliance for Greater Cincinnati paid $108 million to resolve False Claims Act liability for the conduct.

Under the terms of the 5-year CIA, TCH is required to implement compliance measures, hire an outside reviewer of its financial relationships with physicians, and be monitored by OIG. The CIA also includes a provision requiring a committee of the Board of Trustees to annually review the company’s compliance program and certify its effectiveness. According to TCH, the hospital agreed to the corporate integrity agreement “to further demonstrate beyond any doubt that the hospital’s leadership is conducting every aspect of its business with the highest ethical standards and in full compliance with all Federal and State laws and regulations.”


  • The entire agreement can be accessed here
  • Read the press release here



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