Banner Health Corporate Integrity Agreement: What You Need to Know

Banner Health, one of the largest non-profit healthcare systems in the United States, has recently entered into a Corporate Integrity Agreement (CIA) with the Office of Inspector General (OIG) of the U.S. Department of Health and Human Services (HHS) to resolve alleged violations of the Anti-Kickback Statute and Stark Law. This agreement highlights the importance of complying with federal healthcare laws and regulations and the consequences for failing to do so.

What is the Anti-Kickback Statute and the Stark Law?

The Anti-Kickback Statute prohibits offering, paying, soliciting, or receiving anything of value to induce or reward referrals of items or services reimbursed by federal healthcare programs such as Medicare and Medicaid. The Stark Law, also known as the Physician Self-Referral Law, prohibits physicians from referring patients to entities in which they or their immediate family members have a financial interest for certain designated health services reimbursed by Medicare or Medicaid.

What were the allegations against Banner Health?

Banner Health allegedly violated the Anti-Kickback Statute and the Stark Law by engaging in financial relationships with physicians that provided incentives for referrals of patients to Banner Health entities. These financial relationships included lease agreements, employment agreements, and professional services agreements that were allegedly above fair market value or not commercially reasonable.

What is the Corporate Integrity Agreement?

A Corporate Integrity Agreement is a contract between the OIG and a healthcare provider to implement compliance measures to prevent and detect fraud and abuse. The CIA requires Banner Health to establish and maintain an effective compliance program, conduct annual reviews and certifications of its compliance program, and engage an independent review organization to review its arrangements with physicians and other referral sources.

What are the consequences of violating a Corporate Integrity Agreement?

Violating a CIA can result in severe penalties and exclusion from participating in federal healthcare programs. The CIA with Banner Health requires the appointment of a Corporate Responsibility Officer to oversee compliance with the agreement, and any failure to comply with the CIA could result in an extension of the agreement or termination of Banner Health`s participation in federal healthcare programs.


The Banner Health Corporate Integrity Agreement underscores the importance of compliance with federal healthcare laws and regulations. Healthcare providers must ensure that their financial relationships with physicians and other referral sources comply with the Anti-Kickback Statute and the Stark Law. Violations of these laws can have severe consequences, including exclusion from participating in federal healthcare programs. The implementation of a robust compliance program and the engagement of an independent review organization can help healthcare providers prevent and detect potential fraud and abuse.