# kaal:claim:2317580-017

**Claim.** A CIA raises the stakes for directors who would otherwise neglect their governance responsibilities, because the agreement puts the company effectively on parole and gives the government direct access that facilitates detection of compliance failures.

**Type.** mechanism  **Support.** argued

**Holds when.**

- companies operating under an executed CIA
- OIG inspection and site visit rights

**Source quote.**

> A CIA increases the stakes for directors choosing to eschew their governance responsibilities. A company operating under a CIA is essentially on parole.55 CIAs give the government direct access to a health care corporation, facilitating the detection of compliance issues.

**From.** Wulf A. Kaal, Elizabeth R. Malay, *The Role of Corporate Integrity Agreements in the Expansion of Fiduciary Duties* (2013), III.2 Characteristics, page 11

**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.** governance-design

**Keywords.** detection, deterrence, governance-responsibilities, government-access

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