oig-cia · CMS
oig-cia · CMS
oig-cia · CMS
oig-cia · CMS
oig-cia · CMS
AI summary
A Corporate Integrity Agreement is a forward-looking compliance agreement administered by HHS-OIG, commonly entered in connection with resolving a health care matter. It can require compliance programs, training, reviews, and reporting for a defined term. A registry entry records the agreement and published status; it is not an exclusion, court judgment, or risk score.
Dated source facts
What the cited record says
- Administering authority
- HHS Office of Inspector General
- Instrument
- Forward-looking compliance obligations for a defined term
Source-snapshot manifest receipt
Reproducible lineage, explicitly unsigned
This receipt attests the source snapshot manifest, not any individual fact.
The answer-series chain record is unsigned. It does not authenticate a person, organization, eligibility state, or individual fact.
- Snapshot manifest SHA-256
ae8f760bf68ae2420955c81e3a251af63a80a10409cb08e33843177072a3fd3c- Previous chain SHA-256
c78a9fd89889d19143ada30d1b1b6f49997c2c9fe35f92de907a526b8d70917b- Current chain SHA-256
021f00e562aeeb04b7eaaeb2191b0af6ec1872e3d005910986bc0fc1b91b149c- signature_linked_facts
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Follow the answer to its source
- Corporate Integrity Agreements registryHHS Office of Inspector GeneralSnapshot:
Limitation: The registry records agreements and their published dates and status. An agreement is a forward-looking obligation, not a finding made by Fonteum or a risk score.
Re-derive this answer from the cited government file; no Fonteum account is required.
Frequently asked questions
Questions about this answer
- Is a corporate integrity agreement an OIG exclusion?
- No. Integrity agreements and exclusions are separate OIG instruments with different source records and effects.
HHS's Office of Inspector General keeps a public registry of the health-care organizations and individuals operating under an integrity agreement — a forward-looking compliance arrangement OIG enters with a party, usually in connection with resolving a matter. The agreement does not adjudicate anything; it sets obligations going forward: a compliance program, training, internal and independent audits, and regular reporting to OIG, typically over a multi-year term. The registry lists each agreement, whether it is currently in effect or has concluded, and where the party is located. Read it as a map and one fact stands out: the active caseload is small, and it is densely concentrated in a handful of states.
The active caseload is the live picture — and it is small
Of the 335 agreements on the published registry, 114 are currently in effect. The remaining 221 are concluded — 208 marked Closed and 13 carrying no status label.
| Status | Agreements | Effective date | Closed date |
|---|---|---|---|
| Effective | 114 | 114 | 0 |
| Closed | 208 | 0 | 208 |
| Unlabelled | 13 | 0 | 0 |
Source: HHS-OIG Corporate Integrity Agreements, snapshot 2026-06-13.
The two date columns explain how the registry works. An effective date is published only while an agreement is in force; once it concludes, the row carries a closed date instead. That is why the 114 active agreements are exactly the rows that carry an effective date, and the 208 Closed agreements are exactly the rows that carry a closed date. The registry is therefore both a live roster and an archive in one file — and the live roster, the part that describes who is under an obligation today, is 114 agreements.
A corporate integrity agreement is a forward-looking compliance obligation, not a verdict rendered here. It records that an organization agreed to be monitored — and says nothing this study infers about fraud, wrongdoing, or the standing of any party.
Half the active caseload sits in five states
The five largest states hold 57 of the 114 active agreements — exactly 50.0% — and California and Florida alone hold 35, or 30.7%. The active caseload reaches 29 jurisdictions in all, but it thins out fast below the top of the list.
| State | Active agreements | Share of active |
|---|---|---|
| California | 18 | 15.8% |
| Florida | 17 | 14.9% |
| Texas | 9 | 7.9% |
| New York | 7 | 6.1% |
| Georgia | 6 | 5.3% |
| Pennsylvania | 5 | 4.4% |
| Illinois | 5 | 4.4% |
| North Carolina | 5 | 4.4% |
Source: HHS-OIG Corporate Integrity Agreements, the eight states with the most active agreements, snapshot 2026-06-13.
California and Florida lead the active caseload, and together they carry nearly a third of every agreement currently in effect. The concentration tracks where large health-care provider populations and OIG enforcement activity are heaviest; it is a map of where agreements are administered, not a ranking of any organization.
Most active agreements are the comprehensive kind
88 of the 114 active agreements — 77.2% — are full Corporate Integrity Agreements; the other 26 are the lighter-weight Integrity Agreement. The two instruments do the same job at different scale: the CIA carries the fuller set of obligations, the IA a lighter set generally used for smaller entities or individuals.
| Agreement type | Active | Concluded | Registry total |
|---|---|---|---|
| Corporate Integrity Agreement | 88 | 131 | 219 |
| Integrity Agreement | 26 | 90 | 116 |
Source: HHS-OIG Corporate Integrity Agreements, by agreement type, snapshot 2026-06-13. "Concluded" combines Closed and unlabelled rows.
The CIA share is higher among active agreements (77.2%) than across the full registry (65.4%), a sign that the comprehensive form runs its multi-year term while a larger share of the lighter IAs has already concluded. The split is structural — it reflects which instrument OIG used, not anything this study infers about the parties.
When the active agreements took effect
The active caseload spans agreements effective from 2019 onward, peaking at 25 in both 2022 and 2024. Because a CIA runs a multi-year term, agreements that took effect much before 2019 have largely concluded and dropped off the active list — so the effective-year curve is the footprint of the standard term, not a measure of yearly enforcement volume.
| Effective year | Active agreements | CIA | IA |
|---|---|---|---|
| 2019 | 1 | 1 | 0 |
| 2020 | 7 | 6 | 1 |
| 2021 | 15 | 14 | 1 |
| 2022 | 25 | 21 | 4 |
| 2023 | 19 | 11 | 8 |
| 2024 | 25 | 15 | 10 |
| 2025 | 15 | 13 | 2 |
| 2026 (partial) | 7 | 7 | 0 |
Source: HHS-OIG Corporate Integrity Agreements, currently-effective agreements by the year each took effect, snapshot 2026-06-13.
This is the only time view the active file supports: it counts agreements still in force by their start year, not a flow of new matters. The 2026 figure is a partial year. Reading the curve as a trend in enforcement would over-read it — older agreements are absent because they have ended, not because fewer were signed.
What one row actually is
Each row in oig_cia_agreements is one agreement: the party's name, the agreement type, its status, the effective or closed date, the location, and the registry's own record key. The published file is the current registry — active agreements alongside concluded ones — so counting and grouping these rows is the entire method here. The NPI-to-entity-graph link is not populated for this source: entity_id and npi are empty on every row, so an integrity agreement renders on no individual provider profile. Every figure in this study is a count or percentage at the status, state, type, or year level. No organization or individual is named, ranked, or scored, and no inference of fraud, wrongdoing, or risk is drawn about any party.
Methodology
All figures are direct aggregations over the oig_cia_agreements table, populated from HHS-OIG's Corporate Integrity Agreements registry (oig.hhs.gov). The table holds 335 agreement rows across 43 jurisdictions and 333 distinct entities; source release date 2026-06-13; public, read-only; license US-Government-Works. OIG maintains the registry on an ongoing basis, adding new agreements and moving concluded ones from an effective date to a closed date, so figures advance with each refresh.
This study reads the published registry as a whole and partitions it by status: the active caseload is the 114 rows with status = 'Effective' (each carrying an effective_date, no closed_date); the concluded set is the 208 Closed rows plus 13 unlabelled rows. The agreement-type groups are the two values the registry uses verbatim — Corporate Integrity Agreement and Integrity Agreement. State concentration counts active agreements by state; effective-year figures use extract(year from effective_date), which marks when an active agreement took effect, not a yearly flow of new matters. Because these are counts and ratios over a published file, every figure is exact as of the snapshot rather than estimated. Methodology version: oig-cia/v1. The source-provenance contract is documented in the provenance methodology.
Limitations
- A compliance record, not a finding of fraud. An integrity agreement is a forward-looking compliance obligation OIG enters with a party, typically in connection with resolving a matter. The registry does not adjudicate, and this study infers nothing about fraud, wrongdoing, liability, or risk of any named organization or individual.
- Aggregate and category-level only. Every figure is a count or percentage at the status, state, agreement-type, or year level. No party is named, ranked, or scored, and the NPI-to-entity-graph link is not populated, so no agreement renders on a provider profile.
- The registry is a current roster plus an archive. The file holds active and concluded agreements together; it is not a complete historical census of every agreement OIG has ever administered. Counts of past effective years describe agreements still in force, not the full historical flow.
- Effective year is the start of an active agreement, not annual enforcement volume. Because agreements run a multi-year term, the effective-year curve is shaped by which agreements remain in force, and older agreements are absent because they have concluded. The 2026 figure is a partial year.
- Status labels follow the registry. 13 rows carry no status label; all 13 are Corporate Integrity Agreements, and they are grouped with the concluded agreements throughout (both in the active-versus-concluded split and in the agreement-type table). Grouping otherwise follows the registry's own fields exactly.
- Snapshot, not a trend model. Figures reflect the single registry dated 2026-06-13. OIG refreshes it on an ongoing basis, so shares shift between releases; this study does not model change over time.
Sources
- HHS-OIG — Corporate Integrity Agreements — the public registry behind every figure in this study, listing each active and concluded agreement.
- HHS Office of Inspector General — the federal authority that administers integrity agreements and publishes the registry.
The companion dataset family page for OIG Corporate Integrity Agreements lists the spec and the studies that draw on it. This is the compliance-obligation companion to the exclusion record — who gets barred from Medicare, and why, why exclusions cluster around distressed operators, and the gap between federal and state exclusion screening; for the parts of the enforcement picture that touch billing eligibility see excluded providers still enrolled in Medicare and those still cleared to order and refer.
Frequently asked questions
- What is a corporate integrity agreement?
- A Corporate Integrity Agreement (CIA) is a compliance agreement the HHS Office of Inspector General enters with a health-care organization or individual, usually in connection with resolving a matter. It sets forward-looking obligations — training, internal audits, an independent review organization, and reporting to OIG — and typically runs for a multi-year term. An Integrity Agreement (IA) is a lighter-weight version of the same instrument. It is a compliance obligation, not a court judgment.
- How many integrity agreements are currently active?
- 114 of the 335 agreements on HHS-OIG's published registry are currently in effect. The other 221 are concluded — 208 marked Closed and 13 unlabelled. The registry publishes an effective date only while an agreement is in force, and a closed date once it ends, so the 114 active agreements are exactly the rows that carry an effective date.
- Which states have the most active integrity agreements?
- California (18) and Florida (17) lead, followed by Texas (9), New York (7), and Georgia (6). Those five states hold 57 of the 114 active agreements — exactly 50.0% — and California and Florida alone hold 35, or 30.7%. The active caseload is present in 29 jurisdictions in total.
- Does being on this list mean an organization committed fraud?
- No. This study reports the published regulatory record and draws no inference about any party. A corporate integrity agreement is a forward-looking set of compliance obligations; the registry does not assert, and this study does not infer, fraud, wrongdoing, or risk about any named organization or individual. Figures are aggregate counts only.
- What is the difference between a CIA and an IA?
- Both are compliance instruments OIG administers. The Corporate Integrity Agreement is the comprehensive form, with the fuller set of obligations; the Integrity Agreement is the lighter-weight version, generally used for smaller entities or individuals. Of the 114 active agreements, 88 (77.2%) are CIAs and 26 are IAs; across the full registry the split is 219 CIAs to 116 IAs.
- Can I reproduce these figures?
- Yes. Every number is a direct count over the public oig_cia_agreements table — HHS-OIG's Corporate Integrity Agreement registry, snapshot dated 2026-06-13 — with no modeling. The exact SQL for the status structure, the state concentration, the agreement-type split, and the effective-year breakdown is published in the reproducibility block below.
Who uses this data
The source data behind this study is public
Compliance teams, journalists, and researchers work from the same federal source families cited above — queried by NPI or facility identifier through Fonteum’s open dataset pages and API. Every figure traces to a frozen, downloadable snapshot you can reproduce yourself.
Datasets used
Reproducibility
Every claim, reproducible
The SQL
-- America's ACTIVE federal health-care integrity-agreement caseload — what it
-- is, where it sits, and how it is split between agreement types. Fully
-- reproducible query.
--
-- Question: of the integrity agreements HHS-OIG publishes in its Corporate
-- Integrity Agreement registry, how many are currently IN EFFECT, where are
-- those active agreements located, and how do they break down by agreement
-- type and effective year? The lead figure: 114 of the 335 agreements on the
-- published registry are currently Effective, and 57 of those 114 (50.0%) sit
-- in just five states. A Corporate / Integrity Agreement is a forward-looking
-- COMPLIANCE obligation OIG enters with an organization or individual, typically
-- alongside the resolution of a matter; this study reports the published
-- regulatory record only and draws NO inference of fraud, wrongdoing, or risk
-- about any party.
--
-- Source:
-- public.oig_cia_agreements — HHS Office of Inspector General "Corporate
-- Integrity Agreements" registry (oig.hhs.gov/compliance/corporate-
-- integrity-agreements). 335 agreement rows; source_release_date 2026-06-13.
-- Public, read-only. License: US-Government-Works (17 U.S.C. Sec. 105).
-- methodology_version = 'oig-cia/v1'.
--
-- Universe: this study reads the published registry AS A WHOLE — every row is
-- an agreement OIG lists. The registry carries both currently-Effective
-- agreements and Closed (concluded) ones, so figures are a point-in-time
-- snapshot, not a modeled trend. The NPI-to-entity-graph link is not
-- populated for this source (entity_id is NULL on every row); no individual
-- or organization is named in the study.
--
-- Counting note: effective_date is published only while an agreement is in
-- force (it is NULL on every Closed row); closed_date is published only once
-- an agreement concludes (NULL on every Effective row). The effective-year
-- figures below therefore describe the currently-active population by the
-- year each active agreement took effect — not an annual flow of new matters.
-- ============================================================================
-- (1) Universe reconciliation — the published registry at a glance.
-- ============================================================================
-- audit-claim: universe
SELECT
count(*) AS agreements,
count(DISTINCT entity_name) AS distinct_entities,
count(DISTINCT state) FILTER (WHERE state IS NOT NULL AND state <> '') AS jurisdictions,
count(*) FILTER (WHERE status = 'Effective') AS effective,
count(*) FILTER (WHERE status IS DISTINCT FROM 'Effective') AS concluded,
count(*) FILTER (WHERE status = 'Closed') AS closed,
count(*) FILTER (WHERE status IS NULL) AS status_null,
max(source_release_date) AS snapshot
FROM public.oig_cia_agreements;
-- agreements 335 · distinct_entities 333 · jurisdictions 43
-- effective 114 · concluded 221 · closed 208 · status_null 13 · snapshot 2026-06-13
-- ============================================================================
-- (2) Status structure — effective_date is present ONLY on Effective rows;
-- closed_date is present ONLY on Closed rows. This is why the active
-- caseload (114) equals the count of rows carrying an effective_date.
-- ============================================================================
-- audit-claim: status-vector
SELECT
coalesce(status, '(unlabelled)') AS status,
count(*) AS agreements,
count(effective_date) AS with_effective_date,
count(closed_date) AS with_closed_date
FROM public.oig_cia_agreements
GROUP BY status
ORDER BY agreements DESC;
-- Closed 208 · 0 effective_date · 208 closed_date
-- Effective 114 · 114 effective_date · 0 closed_date
-- (unlabelled) 13 · 0 effective_date · 0 closed_date
-- ============================================================================
-- (3) HEADLINE: the ACTIVE caseload is geographically concentrated. Of the 114
-- currently-Effective agreements, the five largest states hold 57 — exactly
-- 50.0% — and California + Florida alone hold 35 (30.7%).
-- ============================================================================
-- audit-claim: state-vector
SELECT
state,
count(*) AS effective,
round(100.0 * count(*) / sum(count(*)) OVER (), 1) AS pct_of_active
FROM public.oig_cia_agreements
WHERE status = 'Effective' AND state IS NOT NULL AND state <> ''
GROUP BY state
ORDER BY effective DESC, state
LIMIT 8;
-- CA 18 15.8% · FL 17 14.9% · TX 9 7.9% · NY 7 6.1% · GA 6 5.3%
-- PA 5 4.4% · IL 5 4.4% · NC 5 4.4%
-- top-5 (CA,FL,TX,NY,GA) = 57 = 50.0% · CA+FL = 35 = 30.7%
-- 29 distinct jurisdictions carry an active agreement; 0 active rows lack a state.
-- ============================================================================
-- (4) Concentration, computed directly (no manual sum of the rows above).
-- ============================================================================
-- audit-claim: concentration
SELECT
count(*) AS active_total,
count(*) FILTER (WHERE state IN ('CA','FL','TX','NY','GA')) AS top5,
round(100.0 * count(*) FILTER (WHERE state IN ('CA','FL','TX','NY','GA'))
/ count(*), 1) AS top5_pct,
count(*) FILTER (WHERE state IN ('CA','FL')) AS ca_fl,
round(100.0 * count(*) FILTER (WHERE state IN ('CA','FL')) / count(*), 1) AS ca_fl_pct,
count(*) FILTER (WHERE state NOT IN ('CA','FL')) AS outside_ca_fl,
count(DISTINCT state) FILTER (WHERE state IS NOT NULL AND state <> '') AS active_jurisdictions,
count(DISTINCT state) FILTER (
WHERE state IS NOT NULL AND state <> '' AND state NOT IN ('CA','FL')
) AS outside_ca_fl_jurisdictions
FROM public.oig_cia_agreements
WHERE status = 'Effective';
-- active_total 114 · top5 57 · top5_pct 50.0% · ca_fl 35 · ca_fl_pct 30.7%
-- outside_ca_fl 79 · active_jurisdictions 29 · outside_ca_fl_jurisdictions 27
-- ============================================================================
-- (5) Agreement TYPE split of the active caseload. A Corporate Integrity
-- Agreement (CIA) is the comprehensive form; an Integrity Agreement (IA) is
-- the lighter-weight form. Among the 114 active agreements, CIAs dominate.
-- ============================================================================
-- audit-claim: agreement-type-vector
SELECT
agreement_type,
count(*) FILTER (WHERE status = 'Effective') AS effective,
count(*) FILTER (WHERE status IS DISTINCT FROM 'Effective') AS concluded,
count(*) AS total,
round(
100.0 * count(*) FILTER (WHERE status = 'Effective')
/ sum(count(*) FILTER (WHERE status = 'Effective')) OVER (),
1
) AS pct_of_active,
round(100.0 * count(*) / sum(count(*)) OVER (), 1) AS pct_of_registry
FROM public.oig_cia_agreements
GROUP BY agreement_type
ORDER BY total DESC;
-- Corporate Integrity Agreement 88 effective · 131 concluded · 219 total
-- 77.2% of active · 65.4% of registry
-- Integrity Agreement 26 effective · 90 concluded · 116 total
-- 22.8% of active · 34.6% of registry
-- ============================================================================
-- (6) WHEN the active agreements took effect. CIAs run a multi-year term, so the
-- active population spans roughly the last several years; agreements
-- effective before ~2019 have largely concluded and dropped off the active
-- list. 2022 and 2024 are the busiest effective years still in force.
-- ============================================================================
-- audit-claim: effective-year-vector
SELECT
extract(year FROM effective_date)::int AS effective_year,
count(*) AS effective,
count(*) FILTER (WHERE agreement_type = 'Corporate Integrity Agreement') AS cia,
count(*) FILTER (WHERE agreement_type = 'Integrity Agreement') AS ia
FROM public.oig_cia_agreements
WHERE status = 'Effective'
GROUP BY effective_year
ORDER BY effective_year;
-- 2019 1 (1 CIA, 0 IA)
-- 2020 7 (6, 1)
-- 2021 15 (14, 1)
-- 2022 25 (21, 4)
-- 2023 19 (11, 8)
-- 2024 25 (15, 10)
-- 2025 15 (13, 2)
-- 2026 7 (7, 0) (partial year)The snapshot
| dataset_id | oig-cia |
| snapshot_date | 2026-06-13 |
| slsa_provenance_url | pending - publishes with the SLSA provenance generator (not yet live) |
The JOINs
universe: the published registry as a whole -- 335 agreement rows, source_release_date 2026-06-13 active caseload = status = 'Effective' -- 114 rows; effective_date present, closed_date NULL concluded = status = 'Closed' (208) + unlabelled (13) -- 221 rows; closed_date present on the 208 Closed concentration: GROUP BY state WHERE status='Effective' -- CA 18, FL 17, TX 9, NY 7, GA 6 = 57 of 114 (50.0%) California + Florida active -- 35 of 114 (30.7%); 29 jurisdictions carry an active agreement type split of active = agreement_type -- CIA 88 (77.2%), IA 26; whole registry 219 CIA / 116 IA active by effective year = extract(year from effective_date) -- 2022 and 2024 the busiest still-in-force years (25 each)
The pipeline version
| git_sha | 8c06d24b |
| slsa_provenance | pending - publishes with the SLSA provenance generator (not yet live) |
| methodology_version | oig-cia/v1 |
Reproduce this
Run the exact query against the frozen 2026-06-13.
Cite this study
Citation-ready for researchers and AI.
Check the chain
The cited snapshot identifies the federal file. Where an attestation is present, its file hash can be re-derived; figures are not individually signed.
oig-cia · 2026-06-13Not suppliedInspect supplied artifact- FINANCIAL DISTRESS · JUN 2026The OIG exclusion list, explained: who gets barred from Medicare, and whyThe OIG List of Excluded Individuals and Entities (LEIE) holds 68,055 active exclusions spanning 1977–2026. The most common reason to be barred from Medicare is not fraud — it is losing a state license: §1128(b)(4) license actions are 41% of the list. And only 10.3% of records carry an NPI, so the list is mostly non-clinicians.
- FINANCIAL DISTRESS · JUN 2026OIG Exclusion Check: The 2026 Excluded-Provider LandscapeAt the July 14, 2026 audit cutoff, the OIG LEIE, SAM.gov, and 13 state Medicaid programs contained 10,824 NPI-identified providers barred from a public health program — yet the single most complete list, the OIG LEIE, named only 6,880 of them. Screen against that one source and 36.4% of excluded providers come back clean.
- FINANCIAL DISTRESS · JUN 2026State Medicaid Exclusion Lists vs the Federal LEIE: The GapIn the July 14, 2026 production observation, 3,188 of 4,949 NPI-identified providers excluded across 13 state Medicaid programs — 64.4% — carried no record on the federal OIG LEIE. Another 15,487 in-force state exclusion records had no NPI and could not be matched to the federal list by identifier.
- FINANCIAL DISTRESS · JUN 2026Barred but billable: excluded providers still enrolled in Medicare19 providers barred from all federal health programs by the OIG still hold an active Medicare enrollment record in PECOS — out of 6,880 in-force NPI-identified federal exclusions. Most trace to a single refresh cycle's lag, but two have stood for over a year, one excluded since 2015.
- FINANCIAL DISTRESS · JUN 2026Industry payments to providers on the OIG exclusion listIn program year 2024, drug and device manufacturers reported $3.84 million in Open Payments to 294 physicians and other providers who now sit on the federal OIG exclusion list, spread across 3,055 separate transfers. A single category — debt forgiveness — accounts for $3.27 million of that total.
Federal source citations
Fonteum LLC · June 16, 2026 · All figures trace to the frozen federal-data snapshot cited above.