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# Look to Comparable CIAs in Risk Assessment: Attorney
- URL: https://www.fdaweb.com/look-to-comparable-cias-in-risk-assessment-attorney/
- Published: 2016-01-28T12:00:00.000Z
- Updated: 2026-09-15T02:31:36.000Z
- Author: David McFarland
- Tags: Drugs, Devices, #legacy-id-D5134593

> Attorney **John Bentivoglio** (Skadden Arps) says that corporate integrity agreements (CIAs) are “important to those operating under their obligations and to others in the same healthcare sector. They provide important guidance as to what the OIG believes to be effective oversight and operational controls for healthcare organizations. Companies should review new CIAs with similarly situated companies as part of a periodic (at least annual) risk assessment process.”  
>  
> Writing in an online [post](https://www.skadden.com/sites/default/files/publications/Examining%5FRecent%5FCorporate%5FIntegrity%5FAgreement%5FTrends.pdf?ref=fdaweb.com), Bentivoglio outlines the number of open CIAs and their use in various industry sectors and looks at them in terms of board and management oversight and incentive compensation and financial clawbacks.