{ "study": { "slug": "oig-corporate-integrity-agreements-2026", "title": "America's active integrity agreements: half sit in five states", "standfirst": "Half of America's active federal health-care integrity agreements — 50.0% — sit in just five states. Of the 335 agreements in HHS-OIG's published registry, 114 are currently in effect, and California and Florida alone hold 35 of those active cases, 30.7% of the national total; the remaining 79 are spread across 27 other jurisdictions.", "desk": "financial-distress", "article_type": "Original Research", "published": "2026-06-16", "issue": 81, "doi": "10.5072/fonteum/oig-corporate-integrity-agreements-2026", "url": "https://fonteum.com/research/oig-corporate-integrity-agreements-2026", "methodology_version": "oig-cia/v1" }, "data_as_of": "2026-06-13", "datasets": [ { "slug": "oig-cia", "name": "OIG Corporate Integrity Agreements", "publisher": "HHS OIG — Corporate Integrity Agreements", "upstream_url": "https://oig.hhs.gov/compliance/corporate-integrity-agreements/" } ], "key_findings": [ { "number": "114", "finding": "of the 335 integrity agreements on HHS-OIG's published registry are currently in effect — the live federal compliance caseload. The other 221 are concluded (208 Closed, 13 unlabelled). An agreement's effective date is published only while it is in force; once it concludes, the registry carries a closed date instead", "dataset": "oig-cia" }, { "number": "50.0%", "finding": "of the 114 active agreements — exactly 57 — sit in just five states: California, Florida, Texas, New York, and Georgia. The active caseload spans 29 jurisdictions in all, but it is heavily front-loaded into the largest", "dataset": "oig-cia" }, { "number": "30.7%", "finding": "of all active agreements (35 of 114) are in California and Florida alone — 18 in California, 17 in Florida — the two states that lead both the active caseload and the full registry", "dataset": "oig-cia" }, { "number": "77.2%", "finding": "of the active caseload (88 of 114) are full Corporate Integrity Agreements, the comprehensive form; the remaining 26 are the lighter-weight Integrity Agreement. Across the whole registry the split is 219 CIAs to 116 IAs", "dataset": "oig-cia" }, { "number": "335", "finding": "agreements across 43 jurisdictions make up the published registry, snapshot dated 2026-06-13, covering 333 distinct entities. Every figure is a count over the published regulatory record — no organization or individual is named, ranked, or scored, and no inference of fraud or wrongdoing is drawn", "dataset": "oig-cia" } ], "faqs": [ { "q": "What is a corporate integrity agreement?", "a": "A Corporate Integrity Agreement (CIA) is a compliance agreement the HHS Office of Inspector General enters with a health-care organization or individual, usually in connection with resolving a matter. It sets forward-looking obligations — training, internal audits, an independent review organization, and reporting to OIG — and typically runs for a multi-year term. An Integrity Agreement (IA) is a lighter-weight version of the same instrument. It is a compliance obligation, not a court judgment." }, { "q": "How many integrity agreements are currently active?", "a": "114 of the 335 agreements on HHS-OIG's published registry are currently in effect. The other 221 are concluded — 208 marked Closed and 13 unlabelled. The registry publishes an effective date only while an agreement is in force, and a closed date once it ends, so the 114 active agreements are exactly the rows that carry an effective date." }, { "q": "Which states have the most active integrity agreements?", "a": "California (18) and Florida (17) lead, followed by Texas (9), New York (7), and Georgia (6). Those five states hold 57 of the 114 active agreements — exactly 50.0% — and California and Florida alone hold 35, or 30.7%. The active caseload is present in 29 jurisdictions in total." }, { "q": "Does being on this list mean an organization committed fraud?", "a": "No. This study reports the published regulatory record and draws no inference about any party. A corporate integrity agreement is a forward-looking set of compliance obligations; the registry does not assert, and this study does not infer, fraud, wrongdoing, or risk about any named organization or individual. Figures are aggregate counts only." }, { "q": "What is the difference between a CIA and an IA?", "a": "Both are compliance instruments OIG administers. The Corporate Integrity Agreement is the comprehensive form, with the fuller set of obligations; the Integrity Agreement is the lighter-weight version, generally used for smaller entities or individuals. Of the 114 active agreements, 88 (77.2%) are CIAs and 26 are IAs; across the full registry the split is 219 CIAs to 116 IAs." }, { "q": "Can I reproduce these figures?", "a": "Yes. Every number is a direct count over the public oig_cia_agreements table — HHS-OIG's Corporate Integrity Agreement registry, snapshot dated 2026-06-13 — with no modeling. The exact SQL for the status structure, the state concentration, the agreement-type split, and the effective-year breakdown is published in the reproducibility block below." } ], "citation": { "apa": "Fonteum Research. (2026, June 16). America's active integrity agreements: half sit in five states. Fonteum Research, Issue 81. https://doi.org/10.5072/fonteum/oig-corporate-integrity-agreements-2026", "url": "https://fonteum.com/research/oig-corporate-integrity-agreements-2026" }, "reproducible_sql": "-- America's ACTIVE federal health-care integrity-agreement caseload — what it\n-- is, where it sits, and how it is split between agreement types. Fully\n-- reproducible query.\n--\n-- Question: of the integrity agreements HHS-OIG publishes in its Corporate\n-- Integrity Agreement registry, how many are currently IN EFFECT, where are\n-- those active agreements located, and how do they break down by agreement\n-- type and effective year? The lead figure: 114 of the 335 agreements on the\n-- published registry are currently Effective, and 57 of those 114 (50.0%) sit\n-- in just five states. A Corporate / Integrity Agreement is a forward-looking\n-- COMPLIANCE obligation OIG enters with an organization or individual, typically\n-- alongside the resolution of a matter; this study reports the published\n-- regulatory record only and draws NO inference of fraud, wrongdoing, or risk\n-- about any party.\n--\n-- Source:\n-- public.oig_cia_agreements — HHS Office of Inspector General \"Corporate\n-- Integrity Agreements\" registry (oig.hhs.gov/compliance/corporate-\n-- integrity-agreements). 335 agreement rows; source_release_date 2026-06-13.\n-- Public, read-only. License: US-Government-Works (17 U.S.C. Sec. 105).\n-- methodology_version = 'oig-cia/v1'.\n--\n-- Universe: this study reads the published registry AS A WHOLE — every row is\n-- an agreement OIG lists. The registry carries both currently-Effective\n-- agreements and Closed (concluded) ones, so figures are a point-in-time\n-- snapshot, not a modeled trend. The NPI-to-entity-graph link is not\n-- populated for this source (entity_id is NULL on every row); no individual\n-- or organization is named in the study.\n--\n-- Counting note: effective_date is published only while an agreement is in\n-- force (it is NULL on every Closed row); closed_date is published only once\n-- an agreement concludes (NULL on every Effective row). The effective-year\n-- figures below therefore describe the currently-active population by the\n-- year each active agreement took effect — not an annual flow of new matters.\n\n-- ============================================================================\n-- (1) Universe reconciliation — the published registry at a glance.\n-- ============================================================================\nSELECT\n count(*) AS agreements,\n count(DISTINCT entity_name) AS distinct_entities,\n count(DISTINCT state) FILTER (WHERE state IS NOT NULL AND state <> '') AS jurisdictions,\n count(*) FILTER (WHERE status = 'Effective') AS effective,\n count(*) FILTER (WHERE status = 'Closed') AS closed,\n count(*) FILTER (WHERE status IS NULL) AS status_null,\n max(source_release_date) AS snapshot\nFROM public.oig_cia_agreements;\n-- agreements 335 · distinct_entities 333 · jurisdictions 43\n-- effective 114 · closed 208 · status_null 13 · snapshot 2026-06-13\n\n-- ============================================================================\n-- (2) Status structure — effective_date is present ONLY on Effective rows;\n-- closed_date is present ONLY on Closed rows. This is why the active\n-- caseload (114) equals the count of rows carrying an effective_date.\n-- ============================================================================\nSELECT\n coalesce(status, '(unlabelled)') AS status,\n count(*) AS agreements,\n count(effective_date) AS with_effective_date,\n count(closed_date) AS with_closed_date\nFROM public.oig_cia_agreements\nGROUP BY status\nORDER BY agreements DESC;\n-- Closed 208 · 0 effective_date · 208 closed_date\n-- Effective 114 · 114 effective_date · 0 closed_date\n-- (unlabelled) 13 · 0 effective_date · 0 closed_date\n\n-- ============================================================================\n-- (3) HEADLINE: the ACTIVE caseload is geographically concentrated. Of the 114\n-- currently-Effective agreements, the five largest states hold 57 — exactly\n-- 50.0% — and California + Florida alone hold 35 (30.7%).\n-- ============================================================================\nSELECT\n state,\n count(*) AS effective,\n round(100.0 * count(*) / sum(count(*)) OVER (), 1) AS pct_of_active\nFROM public.oig_cia_agreements\nWHERE status = 'Effective' AND state IS NOT NULL AND state <> ''\nGROUP BY state\nORDER BY effective DESC, state\nLIMIT 8;\n-- CA 18 15.8% · FL 17 14.9% · TX 9 7.9% · NY 7 6.1% · GA 6 5.3%\n-- PA 5 4.4% · IL 5 4.4% · NC 5 4.4%\n-- top-5 (CA,FL,TX,NY,GA) = 57 = 50.0% · CA+FL = 35 = 30.7%\n-- 29 distinct jurisdictions carry an active agreement; 0 active rows lack a state.\n\n-- ============================================================================\n-- (4) Concentration, computed directly (no manual sum of the rows above).\n-- ============================================================================\nSELECT\n count(*) AS active_total,\n count(*) FILTER (WHERE state IN ('CA','FL','TX','NY','GA')) AS top5,\n round(100.0 * count(*) FILTER (WHERE state IN ('CA','FL','TX','NY','GA'))\n / count(*), 1) AS top5_pct,\n count(*) FILTER (WHERE state IN ('CA','FL')) AS ca_fl,\n round(100.0 * count(*) FILTER (WHERE state IN ('CA','FL')) / count(*), 1) AS ca_fl_pct,\n count(DISTINCT state) FILTER (WHERE state IS NOT NULL AND state <> '') AS active_jurisdictions\nFROM public.oig_cia_agreements\nWHERE status = 'Effective';\n-- active_total 114 · top5 57 · top5_pct 50.0% · ca_fl 35 · ca_fl_pct 30.7%\n-- active_jurisdictions 29\n\n-- ============================================================================\n-- (5) Agreement TYPE split of the active caseload. A Corporate Integrity\n-- Agreement (CIA) is the comprehensive form; an Integrity Agreement (IA) is\n-- the lighter-weight form. Among the 114 active agreements, CIAs dominate.\n-- ============================================================================\nSELECT\n agreement_type,\n count(*) FILTER (WHERE status = 'Effective') AS effective,\n count(*) FILTER (WHERE status = 'Closed') AS closed,\n count(*) AS total\nFROM public.oig_cia_agreements\nGROUP BY agreement_type\nORDER BY total DESC;\n-- Corporate Integrity Agreement 88 effective · 118 closed · 219 total\n-- Integrity Agreement 26 effective · 90 closed · 116 total\n-- (active CIA share = 88/114 = 77.2%)\n\n-- ============================================================================\n-- (6) WHEN the active agreements took effect. CIAs run a multi-year term, so the\n-- active population spans roughly the last several years; agreements\n-- effective before ~2019 have largely concluded and dropped off the active\n-- list. 2022 and 2024 are the busiest effective years still in force.\n-- ============================================================================\nSELECT\n extract(year FROM effective_date)::int AS effective_year,\n count(*) AS effective,\n count(*) FILTER (WHERE agreement_type = 'Corporate Integrity Agreement') AS cia,\n count(*) FILTER (WHERE agreement_type = 'Integrity Agreement') AS ia\nFROM public.oig_cia_agreements\nWHERE status = 'Effective'\nGROUP BY effective_year\nORDER BY effective_year;\n-- 2019 1 (1 CIA, 0 IA)\n-- 2020 7 (6, 1)\n-- 2021 15 (14, 1)\n-- 2022 25 (21, 4)\n-- 2023 19 (11, 8)\n-- 2024 25 (15, 10)\n-- 2025 15 (13, 2)\n-- 2026 7 (7, 0) (partial year)", "license": "U.S. Government Works (federal sources; 17 U.S.C. §105)", "generated_by": "Fonteum — https://fonteum.com", "notes": "Aggregate, source-traced figures frozen to the snapshot above. Reproduce by running reproducible_sql against the cited federal dataset; no per-entity records are included." }