Board oversight and governance
Board engagement, reporting structures, meeting materials, compliance education, minutes, and documentation of meaningful oversight.
Compliance Expert Services (CIA)
Independent compliance expertise for healthcare organizations and their Boards.
A Corporate Integrity Agreement places significant responsibility on an organization’s Board to oversee the effectiveness of its compliance program. When the CIA requires the retention of an independent Compliance Expert, Rivet Health Law provides experienced, objective compliance review and Board advisory services focused on Federal health care program requirements and effective compliance program oversight.
Reviewed by Joseph Rivet · October 3, 2026
The Challenge
Independent review. Meaningful Board oversight.
The Compliance Expert serves an important independent role in the organization’s CIA obligations. The review provides the Board with an objective assessment of the compliance program’s design, implementation, resources, operations, and overall effectiveness.
Compliance officer independence and authority
Reporting relationships, access to the Board, organizational authority, staffing, resources, and independence from operations.
Compliance committee effectiveness
Composition, participation, meeting cadence, reporting, accountability, and follow-through on identified issues.
Risk assessment and work planning
How compliance risks are identified and prioritized, and whether the auditing and monitoring plan is meaningful.
Auditing and monitoring
Whether the organization can identify, measure, report, and respond to compliance risks.
Policies and procedures
Codes of Conduct, policy governance, implementation, accessibility, and periodic review.
Education and training
Required compliance education, completion tracking, role-specific training, and gaps that remain.
Hotline and reporting systems
Reporting mechanisms, response times, investigations, documentation, trending, non-retaliation, and escalation.
Investigations and corrective action
How allegations are investigated, how findings are documented, and whether corrective actions are monitored.
Enforcement and accountability
Disciplinary standards, consistency, leadership accountability, and whether expectations are enforced.
Executive and operational reporting
Whether leadership and the Board receive timely, understandable information about emerging risks.
Who We Help
Who this work is for
Effective compliance programs must work outside the Boardroom. Reviews consider how compliance requirements interact with actual healthcare operations, including billing and reimbursement, clinical operations, finance, human resources, auditing, investigations, vendor relationships, leadership accountability, and organizational governance.
- Healthcare organizations operating under a Corporate Integrity Agreement
- Boards responsible for compliance program oversight
- Organizations required to retain an independent Compliance Expert
- Leadership teams preparing an Annual Report to the OIG
Our Process
First steps you can take today
These steps organize the file. They are not a substitute for counsel.
- 1
Read the CIA provisions that require a Compliance Expert and note the current Reporting Period.
- 2
Gather the latest Board compliance materials, including reports, minutes, education, and the committee calendar.
- 3
List prior recommendations and whether each corrective action was implemented.
- 4
Identify relationships that could affect the Compliance Expert’s independence before the engagement starts.
Independent review. Meaningful Board oversight.
The Compliance Expert serves an important independent role in the organization’s CIA obligations. The review provides the Board with an objective assessment of the compliance program’s design, implementation, resources, operations, and overall effectiveness.
Rivet Health Law conducts a comprehensive evaluation tailored to the organization’s CIA requirements, operations, risk profile, and Federal health care program participation.
Our approach goes beyond checking boxes. We evaluate whether the compliance program is actually working.
Written Compliance Expert Report
Following the review, Rivet Health Law prepares a comprehensive written Compliance Expert Report addressing the review methodology, observations regarding the effectiveness of the compliance program, identified areas for improvement, and recommendations for corrective action.
Where required by the CIA, the report is designed to support the organization’s Annual Report to the Office of Inspector General (OIG), including the Board’s response and associated corrective action plans.
Recommendations are designed to be specific, practical, measurable, and actionable. The goal is not simply to identify a weakness, but to provide the Board and organization with a meaningful path toward strengthening the compliance program.
Direct engagement with the Board
The Compliance Expert’s responsibility is fundamentally different from that of management or an internal compliance department.
Rivet Health Law can present findings directly to the Board, participate in Board discussions concerning compliance program effectiveness, explain significant compliance risks, and provide an independent perspective regarding whether corrective actions adequately address identified concerns.
This relationship provides the Board with an additional source of objective information to assist directors in fulfilling their compliance oversight responsibilities.
Annual reviews that measure progress
For CIAs requiring Compliance Expert reviews during each Reporting Period, subsequent reviews should not simply repeat the prior year’s assessment.
We evaluate whether previous recommendations were implemented, whether corrective action plans produced measurable improvement, whether new risks have emerged, and whether the compliance program continues to mature.
This creates a documented progression from identification, to corrective action, to implementation, to validation, and to sustained compliance.
Independence matters
Credibility requires independence.
Before accepting a Compliance Expert engagement, Rivet Health Law evaluates relationships and circumstances that could reasonably call the Compliance Expert’s objectivity into question. Required independence certifications and disclosures can be incorporated into the Compliance Expert reporting process consistent with the organization’s CIA.
From CIA obligation to sustainable compliance
A Corporate Integrity Agreement creates substantial obligations, but it also provides an opportunity to build a stronger compliance infrastructure.
Rivet Health Law’s Compliance Expert services are designed to provide Boards with an independent, credible, and practical assessment of compliance program effectiveness while helping organizations demonstrate meaningful improvement throughout the term of the CIA.
Common questions
- What does the written report cover?
- The Compliance Expert Report addresses the review methodology, observations on the effectiveness of the compliance program, areas for improvement, and recommendations for corrective action. Where the CIA requires it, the report is designed to support the Annual Report to the OIG, including the Board’s response and corrective action plans.
- Does the Compliance Expert meet with the Board?
- Yes. Rivet Health Law can present findings directly to the Board, join discussions about program effectiveness, explain significant compliance risks, and give an independent view of whether corrective actions address the concerns that were identified.
- Do later reviews repeat the first year?
- No. For CIAs that require a review in each Reporting Period, the next review looks at whether prior recommendations were implemented, whether corrective action produced measurable improvement, whether new risks have emerged, and whether the program continues to mature.
- How is independence handled?
- Before accepting the engagement, Rivet Health Law evaluates relationships and circumstances that could reasonably call the Compliance Expert’s objectivity into question. Required certifications and disclosures can be included in the reporting process, consistent with the organization’s CIA.
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(231) 799-4870
rivethealthlaw.com
Before the review
6 itemsWhat to have ready
These are the materials a Compliance Expert review usually starts from. The CIA controls the final scope.
Check items off as you collect them. Your progress is saved on this device.
This sheet is a gather list for your own file. It is not legal advice.
Industries
CIA Compliance Expert
Need an independent CIA Compliance Expert?
Rivet Health Law works with healthcare organizations and their Boards on independent Compliance Expert reviews, written reports, Board presentations, and assessments throughout CIA Reporting Periods.
This page is educational. It is not legal advice and does not create an attorney-client relationship. Facts, contracts, and appeal windows control the next step.