HA550 Unit 7 Corporate Integrity Agreement Review Example

Reviewed by Chester Goodwin, MBA Health Care Law and Ethics Purdue University Global Free custom sample in 24 to 48h

This HA550 Unit 7 compliance program review tests a composite eleven-facility skilled nursing chain against its Corporate Integrity Agreement in year three of five, ninety days before the annual report to the inspector general is due. It was written for Purdue Global HA 550, Health Care Law and Ethics, in the Master of Health Administration (MHA). The agreement followed a settlement over therapy billing, and federal rules separately require chains of five or more facilities to run compliance programs. Each obligation group, governance, people, claims and reporting, is rated met, at risk or not met. The most serious finding is a board that adopted an effectiveness resolution without a documented review in fourteen months. A ninety-day plan follows, and the review asks whether the program would survive the agreement's end.

CourseHA550 Health Care Law and Ethics
UnitUnit 7
Paper typeCompliance program review
LengthAbout 890 words, 6 pages double-spaced
FormatAPA 7 student paper
SchoolPurdue University Global
ProgramMaster of Health Administration (MHA)
UpdatedOctober 2026

Free sample paper for HA550 Unit 7

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Year Three of Five: A Compliance Program Review Testing a Composite Eleven-Facility Skilled Nursing Chain Against the Obligations of Its Corporate Integrity Agreement, Ninety Days Before the Annual Report Is Due, and Asking Whether the Program Would Outlast the Agreement

[Student Name]

Purdue University Global

HA550: Health Care Law and Ethics

Unit 7 Compliance Program Review

[Instructor Name]

[Date]

The chain, the agreement's terms and every finding are composite and bracketed for the writer's own data; obligations are described as such agreements typically phrase them, and the review is coursework, not legal advice.

What this part is doingThe review is organized by the agreement's own obligation groups, so each finding maps to a requirement the chain must report on.
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Background

A Corporate Integrity Agreement is a set of compliance obligations that the Office of Inspector General commonly negotiates, often for five years, when a provider settles allegations under the False Claims Act. In exchange, the inspector general agrees not to seek to exclude the provider from federal health programs. Breaching the agreement can lead to stipulated penalties, and a material breach can lead to exclusion. The chain's agreement followed a settlement over therapy billing under the earlier payment system for skilled nursing facilities, in which payment rose with therapy minutes. Separately, federal rules require organizations operating five or more facilities to maintain a compliance and ethics program with a compliance officer and a liaison at each facility (42 C.F.R. § 483.85, 2024).

Method

For each obligation, the review states it as such agreements typically phrase it, lists the evidence reviewed, states the finding with its source and assigns a rating: met, at risk or not met.

Governance

Obligation: the board reviews the compliance program at least quarterly and adopts an annual resolution on its effectiveness. Evidence: board minutes for [eight] quarters; the resolution for year two. Finding: the board last received a compliance report [14] months ago; the year-two resolution was adopted without a documented review. Rating: at risk. This is the most serious finding, because agreements of this kind place responsibility on the board directly, and missed board obligations can trigger stipulated penalties. A board that signs a resolution on a program it has not reviewed in fourteen months is the finding an inspector general reads first.

People

Compliance officer. Obligation: a senior officer who reports to the chief executive and the board, without legal or financial duties that conflict. Finding: the officer reports to the general counsel. Rating: not met. Management certifications. Obligation: designated managers certify annually that their areas comply. Finding: [31] of [34] certifications filed; [three] facility administrators who started this year have not certified. Rating: at risk. Training. Obligation: [two] hours of general training and [three] hours of specific training for staff involved in billing and therapy. Finding: [96] percent completion for general training; [81] percent for specific training at [two] facilities. Rating: at risk.

Claims

Obligation: an Independent Review Organization reviews a sample of claims each year and reports the error rate. Finding: year-two error rate [7.2] percent, mostly in coding of patient characteristics under the current payment model, which pays by patient condition rather than therapy minutes (83 Fed. Reg. 39162, 2018). The agreement requires a corrective action plan when the error rate exceeds [five] percent; one was drafted but not implemented at [four] facilities. Rating: at risk.

What this part is doingLinking the claims findings to the current payment model shows that compliance risk moved with the payment system rather than disappearing.
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Reporting

Obligations: report reportable events, such as substantial overpayments, within [30] days; screen staff and vendors against exclusion lists monthly; maintain a disclosure hotline. Findings: one overpayment of [$118,000] identified in [month] was returned and reported on time; exclusion screening was complete; hotline calls were logged, but [five] of [22] lacked documented follow-up. Rating: met for reportable events and screening; at risk for the hotline.

What the Inspector General Will Look For

The annual report must describe each obligation, how it was met and any changes since the last report, and an officer must certify it. An inspector general reviewer typically compares the report against the agreement's terms, looks for patterns across years and asks for supporting documents where the report is vague. A report that states a board resolution was adopted, without evidence of the review behind it, invites questions. The safest report is plain: it discloses the gaps found here, describes the plan to close them and gives dates. Disclosure of a problem with a plan usually carries less risk than a gap the reviewer finds alone.

Summary of Ratings

Met: [two]. At risk: [six]. Not met: [one].

Ninety-Day Plan

1. Board: schedule a compliance review this month and every quarter, with minutes recording discussion.

2. Compliance officer: move the officer's reporting line from the general counsel to the chief executive, and give the officer a standing seat at board meetings.

3. Certifications and training: complete outstanding items within [30] days.

4. Claims: implement the corrective action plan at the four facilities and retest.

5. Hotline: assign follow-up owners and close open cases.

Would the Program Outlast the Agreement?

Federal guidance describes an effective compliance program by its elements: leadership, policies, training, communication, monitoring, enforcement and response (Office of Inspector General, 2023). Today, much of the chain's program exists because the agreement requires it. To outlast it, the chain should build compliance into ordinary management, with facility administrators accountable for results, a budget not tied to the agreement's term and a board that asks questions without being told to.

What this part is doingAsking whether the program would survive the agreement turns a compliance check into a test of culture.
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Limits

The review relied on documents and interviews over three weeks; it did not retest claims.

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References

42 C.F.R. § 483.85 (2024). https://www.ecfr.gov/current/title-42/section-483.85

83 Fed. Reg. 39162 (2018). Medicare program; prospective payment system and consolidated billing for skilled nursing facilities (SNF) final rule for FY 2019.

Office of Inspector General. (2023). General compliance program guidance. U.S. Department of Health and Human Services. https://oig.hhs.gov/compliance/general-compliance-program-guidance/

What the HA550 Unit 7 assignment asks for

In Unit 7, HA 550 students typically test one provider's compliance program against a written standard, such as federal guidance or a Corporate Integrity Agreement. Instructions usually require describing the standard, examining evidence for each element or obligation, stating findings, rating them and recommending corrective actions. Organize the review by the standard's own structure, so every finding maps to a requirement. State each finding as a fact with its source, not an impression. Explain consequences, such as stipulated penalties for breaches. Cite federal guidance and any facility-specific rules in APA style. Close with a short corrective plan and a judgment about whether the program reflects the organization's culture or only its obligations.

How this HA550 Unit 7 example is built

The sample explains what a Corporate Integrity Agreement is and why this chain has one, adding the federal requirement for compliance programs in multi-facility operators. A margin note explains the organization by obligation group. The method rates each finding. Governance comes first, with the board's missed reviews rated at risk and a highlighted line naming it the finding an inspector general reads first. People findings cover the compliance officer's reporting line, certifications and training. Claims findings link the review organization's error rate to the current payment model, with a margin note. Reporting findings follow. A section on what the inspector general looks for, a summary of ratings, a ninety-day plan and a question about lasting culture, with a third note, close the review.

Reading the HA550 Unit 7 grading rubric

HA 550 compliance review rubrics generally award points for an accurate description of the standard, organized review of each element, evidence-based findings, appropriate ratings, explanation of consequences, a corrective plan, attention to culture, sources and presentation. Standard points go to explaining the agreement or guidance correctly. Organization points reward following the standard's structure. Finding points depend on facts with sources. Rating points require consistent criteria. Consequence points go to penalties and exclusion risk. Plan points reward owners and deadlines. Culture points go to asking whether compliance would survive without the agreement. Reviews that place board obligations first, because agreements hold boards responsible directly, tend to score best.

HA550 Unit 7 help: mistakes that cost points

Compliance reviews often lose points by describing the program in general terms without testing it against the standard's actual obligations. Others state findings as opinions without evidence. Some list problems without explaining what they could cost. Organize the review by the standard, rate each obligation with evidence and a source, and explain the consequence of each gap. Put governance first, since boards carry direct responsibility. Write a short corrective plan with owners and dates. Then step back and ask whether the program depends on the agreement or would continue on its own, and recommend changes that build compliance into everyday management.

Get an HA550 Unit 7 example written to your instructions

Hospital, practice, nursing chain or health plan: whichever organization your Unit 7 review covers, send its materials with the rubric. Findings rest on documents and carry ratings, governance duties get their own section, and no compliance claim is made for anyone. It arrives in 24-48h, and the first custom sample is free. The paper above is an original model document written by our desk, not a submitted student paper and not an official Purdue University Global document.

More HA550 papers and MHA samples

HA550 Unit 7 questions, answered

Where can I find a free HA550 Unit 7 sample paper?

The complete HA550 Unit 7 compliance program review is here, testing a composite nursing home chain against its Corporate Integrity Agreement in year three.

What is a Corporate Integrity Agreement?

A set of compliance obligations the inspector general negotiates with a provider settling fraud allegations, in exchange for not seeking exclusion.

What happens if a provider breaches the agreement?

Stipulated penalties can apply, and a material breach can lead to exclusion from federal programs.

What was the most serious finding in HA550 Unit 7?

The board adopted an effectiveness resolution without a documented review in fourteen months.

How long is the HA550 Unit 7 review?

About seven pages organized by the agreement's obligation groups.