AIS Newsletter Reports on Tough Halifax Integrity Agreement

Washington, DC (PRWEB) March 26, 2014

As part of its $ 85 million False Claims Act settlement with the Department of Justice for alleged Stark violations, Daytona Beach, Fla.-based Halifax Hospital Medical Center and Halifax Staffing have agreed to a five-year corporate integrity agreement (CIA) that requires its top managers — including the chief medical officer, chief revenue officer and service line administrator — to certify in writing that their departments comply with federal health care regulations. In the March 24 issue of Atlantic Information Services, Inc.’s (AIS) Report on Medicare Compliance, one chief compliance officer calls the Halifax CIA one of the toughest he has seen.

Like other CIAs, it requires the hospital to hire and retain a compliance officer who is not subordinate to the CEO or general counsel and reports directly to the board. “Noncompliance responsibilities of the compliance officer should be limited,” the CIA notes. In another familiar move, board members are required to routinely review the compliance program and sign a resolution every time attesting that Halifax has implemented an effective compliance program that adheres to all federal health program requirements. If they can’t make that promise, board members must sign a statement that they can’t guarantee compliance and lay out their corrective action plan.

But with the requirement that hospital executives must certify their departments’ compliance, Halifax’s CIA goes a step farther. “If you have to certify something, you take it very seriously,” says Brian Kozik, chief compliance officer at Lawrence General Hospital in Lawrence, Mass. “This will hold them accountable.” He also calls the CIA “a big message to the industry and to boards. All those people who sign certifications will be more accountable. It’s spread across the organization.” The CIA should empower compliance officers everywhere because it shows the weight the federal government is giving compliance programs — specifically the importance of face time with the board and reporting, he continues.

Halifax Hospital and Halifax Staffing were scheduled to go on trial March 3 before a jury in U.S. District Court for the Middle District of Florida when word came down of the settlement. The case is USA and Elin Baklid-Kunz v. Halifax Hospital Medical Center and Halifax Staffing, Inc. (U.S. DC MD of Fla., No 6:09-cv-1002-Orl-31TBS).

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About AIS

Atlantic Information Services, Inc. (AIS) is a publishing and information company that has been serving the health care industry for more than 25 years. It develops highly targeted news, data and strategic information for managers in hospitals, health plans, medical group practices, pharmaceutical companies and other health care organizations. AIS products include print and electronic newsletters, websites, looseleafs, books, strategic reports, databases, webinars and conferences. Learn more at

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