Another Unique Integrity Agreement Signals a Trend towards HHS-OIG’s Comfort with a Belt and Suspenders

In recent years, there have been only a handful of Corporate Integrity Agreements and Integrity Agreements in which the HHS Office of the Inspector General has included a “conditional exclusion release.” Inclusion of these is atypical, as HHS-OIG’s historical practice has been to provide an outright release of its permissive exclusion authority in exchange for a CIA or IA.