# kaal:claim:2317580-004

**Claim.** Corporate Integrity Agreements are a hybrid instrument: they are compliance programs funded by health care companies but administratively enforced by the government, that is, contracts between health care companies and the federal government carrying costly mandatory compliance measures and penalties.

**Type.** definitional  **Support.** asserted

**Holds when.**

- health care companies settling federal health care program investigations

**Source quote.**

> CIAs are administratively-enforced compliance programs funded by health care companies but enforced by the government. In other words, they are contracts between health care companies and the federal government and can involve costly mandatory compliance measures and penalties.

**From.** Wulf A. Kaal, Elizabeth R. Malay, *The Role of Corporate Integrity Agreements in the Expansion of Fiduciary Duties* (2013), I. Introduction, page 6

**Cite as.** Wulf A. Kaal, Elizabeth R. Malay, The Role of Corporate Integrity Agreements in the Expansion of Fiduciary Duties (2013). SSRN: https://ssrn.com/abstract=2317580

**Verify.** sha256 of source PDF `50973e1e820aef47a4e7ffdbdcb513d03f1845643fcf4fa5910e9528a0b7dac2` at https://raw.githubusercontent.com/wulfkaal/Academic-Papers/main/papers/pdf/Kaal%20and%20Malay%20-%202013%20-%20The%20Role%20of%20Corporate%20Integrity%20Agreements%20in%20the%20Expansion%20of%20Fiduciary%20Duties.pdf

**Topics.** compliance

**Keywords.** corporate-integrity-agreements, compliance-programs, public-private-enforcement, health-care-regulation

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