Compliance Tool · OIG Enforcement

Corporate Integrity Agreements Dashboard

HHS OIG Corporate Integrity Agreements entered 2023–2026 that OIG lists as active or suspended, with violation summaries, the compliance obligations read from each agreement OIG publishes, and a plain read on what it means for your own program.

Source: OIG CIA Browser ↗  ·  Compiled as of August 30, 2026; last checked October 24, 2026 against OIG's own page for every agreement shown: all 68 effective dates and term lengths agree with OIG, 62 are listed Active and 6 Suspended, and 67 of the 68 agreements were read in full: 66 as text PDFs, and one scanned image rasterised at 300 dpi and put through OCR (on 2026-09-21, and again on 2026-10-24), which confirmed its Claims Review obligation and five year term from the agreement's own words, and whose pages were then rendered and read so that the sections its obligations sit in could be cited; the OCR reading order, not the scan, is what had made those numbers unreadable. OIG publishes no agreement document for the remaining one, the Kabakibou matter, and none was found elsewhere, so its provisions were not read and no claim here rests on them. Its OIG category and report type were checked against OIG's own detail page, which is a different thing from reading the agreement. The October 24 check changed the set. OIG now lists Connex Family Services as Closed on September 15, 2026, the end of its three-year term, so it was removed. Access DX Laboratory, which OIG has listed as effective since July 26, 2023, had been missing and was added. OIG now publishes Advanced Pathology Solutions' agreement, which was read and its obligations cited. Six agreements this dashboard showed as Active are now listed Suspended; OIG dates four of those suspensions before September 20, 2026, when the previous check recorded all 68 as Active, and whether OIG posted them late or that check missed them is not resolved. Read the status as OIG's listing, not as a term calculation. Every record here is one OIG lists as Active or Suspended, and none is one OIG lists as Closed. OIG's listing lags nominal term expiry, so agreements keep their Active status past the date their stated term runs out. Five of the 68 were past that date on October 24, 2026, all still listed Active, the most recent being Arun Arora, M.D., whose three-year term from September 20, 2023 elapsed on September 20, 2026. That count rises on its own as terms run out between refreshes, so treat a record past its own effective date plus term as one OIG has not yet moved, and confirm current status on the linked OIG page before relying on it. Suspended is OIG's word, and this dashboard does not read it as closed. OIG's CIA overview and FAQ pages do not define it. The overview says an agreement is closed after OIG receives and reviews the final report, and the FAQ says an agreement may be terminated early if the provider stops participating in the Federal health care programs or ceases operations, for example through a closure, sale or bankruptcy. Neither says which, if either, applies to a suspended agreement, so each of the six cards shows OIG's status and its date and keeps its obligations as the agreement states them. Settlement figures follow the DOJ press release, not OIG's Settlement Amount field. Those two disagree for eight records, so the field is not a check on this table: for two of them OIG states one component of a larger resolution, for two it truncates cents DOJ reports, and for four it does not match its own linked release. 62 of the 68 figures were confirmed against the DOJ release in September; the other six are composites or entity shares whose basis is stated in each record's note, among them Access DX's, which is its share of a $36.4M resolution as OIG's field states it. On 2026-10-24 DOJ's site refused the first automated requests, so its releases were not re-read in full; Access DX's release, retrieved later that day, is linked from its card. OIG reposts the opening of the DOJ release on its own page for 48 of the 68 records: for 42 of them the figure shown here appears in that opening, for five the record's note explains the difference, and for one, Moroun Nursing Center, the reposted release is a national takedown announcement that does not state the figure. Rite Aid's $409,368,524 is OIG's own Settlement Amount to the dollar; what it is not is the sum of the two components DOJ announces, because DOJ rounds both. Review obligations were read from the agreements themselves. The review type shown is the review the agreement names in its Independent Review Organization section. In September, 49 of the 52 records that name one already agreed, three named a review their agreement does not impose and were corrected, and three that said Other were filled in. Six records keep Other because their agreements impose several reviews that no single category describes. Access DX Laboratory and Advanced Pathology Solutions, read on 2026-10-24, show the reviews their agreements name. Each agreement's obligations were read out of its own sections. On 2026-09-21 the 66 agreements then readable were walked section by section, and every obligation shown on a card carries the section it was read from, with the review obligation quoted in the agreement's own words. That produced 872 cited obligations. On 2026-10-24 the two agreements read for the first time were walked the same way, Arun Arora's 2025 amendment added one obligation, and Connex Family Services' thirteen left with its record, for 898 cited obligations, between 6 and 20 per agreement. Every section label on an obligation line has been checked back against its agreement. The 66 review citations were checked on 2026-09-21, by walking each agreement's heading tree and reading the printed page where the text layer could not settle it, and eight of the 66 named the wrong section. By 2026-09-22 all 872 obligation labels then shown had been checked the same way, and 36 of those 872 were wrong and were corrected on 2026-09-22. 859 were found in their agreement's heading tree, and the heading's printed title was read against the obligation. Seven the walk cannot settle, because the text layer splits a heading, a label names two provisions or footnotes, or the provision sits in the definitions, were checked by finding the provision's own heading and words in the agreement's text. Community Options' six were read off its rendered pages, because it is a scan. Rite Aid's eleven were checked first, and six of them pointed elsewhere in the same agreement. Rite Aid cited its compliance officer, compliance committee, board oversight and management certification lines at III.1 to III.4 where the agreement has III.A.1 to III.A.4; its IRO engagement at III.C.2, which is Board Training, where the agreement has III.D.1.a; and its IRO independence certification at III.C.3, which is Training Records, where the agreement has III.D.3. A label of the form III.1 cannot be a section of these agreements at all, because a roman numeral takes a letter before it takes a number, and looking for that shape found fourteen more across five other records, each corrected against its own agreement. Reading the other 841 found sixteen more wrong. Eleven cited the wrong provision: an IRO engagement at Training Records or at a records-retention clause, an independence certification at a section with no such item, focus arrangements procedures at Covered Persons training, an Arrangements Review at the Anti-Kickback section that precedes it, two EyePoint policies at the compliance-program item instead of their own, and a Veloxis line that cited one of the two programs it names. Five named an Independent Review Organization in agreements that engage none: four quality-of-care agreements engage an Independent Monitor, and McKinsey's engages an Independent Compliance Expert. All sixteen are corrected. On 2026-10-24 all 898 labels now shown were walked again against their agreements' heading trees by machine. All but eleven resolved there; Community Options' six were read off its rendered pages again, and the other five (a label naming two provisions and their footnotes, a provision that sits in an amendment, an appendix the text layer titles only in its footer, a records section the text layer prints twice, and an appendix sub-heading) were checked by reading the provision itself. One EyePoint label was corrected to cite the footnotes that carry its wording. 898 of the 898 obligation labels have now been checked against their agreements, and that leaves 0 of the 898 labels unchecked. A checked label says where the obligation is; it is still a summary of the obligation, not the agreement's words. The controls this dashboard suggests are separate and are not the agreement's terms. 43 of the 268 lines previously shown attributed a duty to an agreement: 31 were replaced by the cited obligation itself, and 12 were rewritten as this dashboard's own suggestion. Seven stated something their agreement does not say rather than merely overstating its scope: a prospective coding review no agreement in this set requires, a speaker-program monitoring threshold given as 2 where the agreement says 35, owner-level certifications in an agreement whose only certification is by the compliance contact and the chief executive, management certifications in an agreement that has none, a grant-expenditure review that is actually a review of Federal Financial Reports, an arrangements review called annual that runs in the first and fourth reporting periods, and owner accountability described as built into obligations that reach owners only by making them Covered Persons. An earlier word-frequency pass over the same 268 lines is what decided which to read first; word overlap settles nothing about whether a document imposes a duty, and none of the results above rest on it. 18 of these 68 are Integrity Agreements and one is a Recipient Compliance Agreement, per OIG's own Report Type field, and those impose fewer of the usual elements. Counting the cards that list each provision, out of the 67 with a list: exclusion screening 67, a review by an IRO, a monitor or a compliance expert 66, annual reports 66, training 65, notification of investigations 64, reportable events 61, record retention 55, written standards 50, a compliance officer 49, management certifications 49, a compliance committee 48, a disclosure program 42, board oversight 39, an overpayment procedure 19, a notice posted for patients 17, and a lesser compliance contact in place of an officer 8. No element but exclusion screening is on every card, which is why no card shows a generic list any more. These count the cards, not the agreements: a card lists the obligations that were located and read, so an agreement can carry a provision its card does not list  ·  68 agreements  ·  2023–2026  ·  agreements effective in this window that OIG lists as Active or Suspended

67 agreements shown
68CIAs (2023–2026)
~$2.77BTotal settlements
$650MLargest settlement (combined)
~65%False Claims Act
5 yr / 3 yrTypical agreement terms

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Cross-CIA takeaways for your organization

Patterns across the 2023–2026 agreements: what to audit, tighten, and watch for in your own compliance program.

Whistleblowers are your early-warning system
Most of these cases were initiated by employee, competitor, or patient whistleblowers under the False Claims Act's qui tam provisions. A disclosure program people actually trust, with genuine non-retaliation protections, is what surfaces these problems internally instead of through a qui tam complaint. The FCA's relator share gives employees a real incentive to go to the government when they can't reach leadership.
Relevant: Kinex, Advanced Urology, Modern Nuclear, Semler, Fresno Community, Matrix, and others
Medical-necessity documentation is a billing matter
Multiple CIAs accompany settlements resolving allegations of billing for tests or procedures that were medically unnecessary or not performed. Every ordered test or procedure needs a contemporaneous clinical rationale in the record. High-frequency tests (urine drug testing, respiratory panels, wound-care procedures) are OIG audit priorities; audit your own ordering patterns against clinical benchmarks before regulators do.
Relevant: Bethany, Dr. Malone, VHS Holdings, Advanced Urology, Kinex, Patient Choice, Semler
Document FMV for financial arrangements with referring physicians
Several CIAs accompany settlements resolving allegations of improper financial arrangements with referral sources, from above-FMV supervision fees for physicians (Modern Nuclear) to physician bonuses for referrals (Fresno) to kickbacks disguised as marketing fees (Patient Choice). As a practice, keep all compensation to physicians who can refer (employment, co-management, supervision, hospitality, technology subsidies) at fair market value, commercially reasonable, and documented before execution; the legal conditions depend on the Stark exception or Anti-Kickback safe harbor relied on.
Relevant: Modern Nuclear, Fresno Community Hospital, Patient Choice Labs, NUWAY
Risk-adjustment coding must match the clinical record
Matrix Medical Network ($36.5M) submitted diagnosis codes to Medicare Advantage where the assessment forms didn't contain enough clinical information to support them. For any MA plan, ACO, or value-based contract where diagnosis coding affects payment, each submitted code must be supported by the contemporaneous record. Retrospective coding enhancements without documentation are a known OIG and DOJ target.
Relevant: Community Care Health Network (Matrix)
Quality-of-care failures can also be False Claims Act matters
Several nursing-home and disability-services CIAs accompany settlements resolving allegations that accepting Medicare/Medicaid payment while providing objectively substandard care (understaffing, neglect, failure to meet minimum standards) violated the False Claims Act under the "worthless services" theory: that care so deficient it has no value makes the claims for it false. Liability still turns on knowingly submitting false claims. Staffing adequacy is a billing-compliance matter, not just a quality metric.
Relevant: Center for Disability Services, Moroun/Villa, American Health Foundation, Riverpark/Avamere
Controlled-substance oversight is a federal compliance obligation
Walgreens ($300M) and Dr. Kabakibou ($3.5M) each settled allegations under both the False Claims Act and the Controlled Substances Act, and DOJ states that the claims in each are allegations only, with no determination of liability. For pharmacies, DEA's regulations place a corresponding responsibility for the proper prescribing and dispensing of controlled substances on the pharmacist who fills a prescription; a practical safeguard is to monitor for suspicious prescriptions and act on what the monitoring finds. For physicians, a practical safeguard, not a rule these cases set, is never to sign controlled-substance prescriptions in advance for others to complete or dispense, and to document the medical need for each opioid order; telemedicine and delegation rules vary and are not summarized here. In the Kabakibou matter the government alleged pre-signed opioid prescriptions, which the release says state law prohibited, and separately alleged billing federal programs for unnecessary tests.
Relevant: Walgreen Co, Kamal Kabakibou

This dashboard compiles publicly reported HHS OIG Corporate Integrity Agreements and DOJ press releases, summarized for general compliance-learning purposes. The summaries and lessons are interpretive and may simplify complex settlements. This is not legal advice. Brandon Goulter is not an attorney, and using this dashboard creates no professional advisory relationship. Settlement figures, effective dates, and obligations should be confirmed against the linked OIG pages and CIA documents, and current requirements verified with a licensed attorney before acting. Active means OIG still lists the agreement as active, which is not the same as the term having time left on it. OIG keeps an agreement listed as active until it closes it out, and the final annual report and closeout come after the nominal end date, so an effective date plus a duration can land in the past while the agreement is still listed. Five agreements here are in that position as of October 24, 2026, and each was confirmed against its own OIG page rather than inferred from the dates. Suspended means OIG lists the agreement as Suspended; OIG does not define the term on its CIA pages, and this dashboard does not treat it as closed. Settlement amounts are civil recoveries except where a case note says otherwise; the largest-settlement figure ($650M, McKinsey) is a combined criminal and civil resolution, of which $323M was the civil False Claims Act portion. Agreement status was verified against the OIG CIA directory as of October 24, 2026; status can change as OIG closes agreements following final-report review. Effective dates, term lengths, listed status, settlement figures and the named review obligation were checked against OIG's page for all 68 (OIG's page states no settlement figure for Advanced Pathology Solutions, so that figure rests on DOJ's release) and against the agreement itself for the 67 that are readable, most recently on 2026-10-24. Each card separates two things that were previously mixed. What this agreement requires was read out of that agreement's own text, and every line carries the section it was read from. 67 of the 68 cards have had every reference checked against the agreement's own headings and say so; 898 of the 898 references have been checked in all. The other card lists no obligations, because OIG publishes no agreement for it. The review obligation is different: for all 67 readable agreements it is quoted in the agreement's own words and its citation has been checked against the headings above the sentence it quotes. It is not a complete list of the agreement's terms. Controls this dashboard suggests is this dashboard's reading of the conduct, written here, taken from no agreement and required by none. Case summaries are likewise this dashboard's reading. They draw on DOJ and OIG announcements and the agreements, and some add context those sources do not state. A settlement resolves allegations without a finding of liability. Unless a summary says that a party admitted particular facts, pleaded guilty or was found liable, it does not say whether the conduct it describes was admitted or only alleged: some resolutions include admissions, a deferred prosecution agreement or a guilty plea that a summary does not mention, and an admission of particular facts is not an admission of every allegation. For the one matter where OIG publishes no agreement document, the card says so and claims nothing about its provisions. Confirm any obligation against the linked agreement before relying on it.

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