Wellcare Corporate Integrity Agreement

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1 – See 42 U.C 1320a-7a; No. 1320a-7 (b) (7). 2 – The OIG has published a series of compliance program guidelines for different health care providers and applicants. A detailed list of these OIG compliance programs can be find on the OIG website: oig.hhs.gov/ fraud/complianceguidance.html. 3 – 31 U.S.C No. 3729 to 3733. 4 – 42 U.C No. 1320a-7a. 5 – 31 U.C. No. 3801 to 3812. 6 – DOJ and HHS, HCFAC annual report for GJ 2011, February 1, 2012. 7 – Id.

8 – Id. 9 – 42 U.S.C. 10 – 42 U.S.C No. 1320a-7b (b). 11 – 42 U.C 12 – 42 U.C No. 1320a-7 (a). 13 – 42 U.S.C No. 1320a-7 (b). 14 – 42 U.C No. 1395nn (a) (1).

15 – 31 U.S.C 16 – GAO Report, “Health Care Fraud – Types of Providers I Medicare, Medicaid, and the Children`s Health Insurance Cases,” GAO 12-820, 27. September 2012. 17 – Id. to 29. 18 – Id. to 31. 19 – False Claims Act, 31 U.S.C. 20 – See comparative agreements between the United States and Temple University – Of the Commonwealth System of Higher Education, valid May 14, 2012. 21 – See www.oig.hhs.gov. 22 – Communication, 74 FR 52964, 9 October 2009.

23 – See www.oig.hhs.gov/fraud/cia/faq.asp. Detailed information and questions about the CIA and IROs can be found strategicmanag.wpengine.com 24 – 24 “Building a Partnership for Effective Compliance,” The Third Government-Industry Roundtable, July 30, 2001, www.oig.hhs.gov/fraud/docs/compliance. 25 – 25 id. to 226 – Id. to 3. 27 – See www.oig.hhs.gov/fraud/cia/cia_list. 28 – “Frequently asked questions about IRO Indepen-dence,” www.oig.hhs.gov. 29 – Id. at 1:2.30 – GAO, Government Auditing Standards, July 2007 Revision (Yellow Book), GAO-07-731G, available at www.gao.gov/assets/80/76968.pdf. 31 – OIG Report “Focus on Compliance – The Next Generation of Corporate Integrity Agreements,” October 9, 2012. 32 – Id. It is important to note that the OIG does not select the IRO.

In addition, they do not give advice on how to select one, nor support the organizations that are supposed to be the IRO. It is entirely up to the entity or supplier to determine the most appropriate organization that should be engaged as an IRO.