The Millennium Health Corporate Integrity Agreement

On October 16, 2015, Millennium Health entered into a Corporate Integrity Agreement (CIA) with the Department of Health and Human Services Office of Inspector General (OIG). We are using the opportunity of the CIA to demonstrate our unwavering commitment to being a good business partner to the government, private payers, clinicians, and most importantly, the patients we serve.

A CIA is a mandatory compliance program that provides the OIG with information about Millennium’s compliance efforts. The purpose of the compliance program is to assure that Millennium is operating its business in compliance with applicable Federal health care laws, rules and regulations. The OIG requires an independent company called Independent Review Organization (IRO), to monitor Millennium’s compliance activities and report to the OIG on the status of those activities. Below are a handful of initiatives and how they impact Millennium and our employees.

  • Management Certifications – Certain members of senior management are required to certify to the OIG that the departments under their control are in compliance with applicable laws, rules and regulations. Some Millennium employees will be asked to provide information to support the Management Certification process. Please be as thorough, accurate, and of course, honest as possible.
  • Code of Conduct and Policies – Millennium will make modifications to our Business Code of Conduct and certain policies, such as billing, business relationships and arrangements with physicians, medical necessity for all testing, requisition forms, and more. All employees will be required to read and review the documents.
  • Compliance Training – Over the next year, Millennium employees will be required complete at least one hour of compliance training, and some employees will be required to complete additional training. More information about Compliance Training will be available soon.
  • Disclosure Program – Employees will be required to report suspected compliance concerns through the Compliance Hotline (866-677-3847). Over the next year, we will be educating employees more on compliance concerns, along with the Millennium Non-Retaliation Policy.
  • Sanction Screening – Organizations that receive federal health care dollars, e.g., Medicare, are prohibited from making payments, including salary and benefits, to individuals and entities that are not eligible to participate in Federal health care programs. The CIA requires us to conduct monthly Sanction Screenings, of all employees, vendors and contractors to ensure that we are complying with this requirement.
  • Field Force Monitoring – The CIA requires Millennium to implement a program to monitor and document, through direct observation, the activities of the sales force. We are required to complete 50 full-day ride-alongs with the sales force throughout the next year. We have contracted with a consulting firm to assist us with completing the ride-alongs and documenting our Field Force Monitoring program.