HIPAA · OSHA · CMS · OIG Compliance Advisory

They're Not Asking If
You're Compliant. They're Asking
You to Prove It.

Comply walks hospital systems and specialty practices through HIPAA audits, OSHA citations, and CMS Conditions of Participation — before a surveyor ever knocks.

See What's at Stake

Scroll to see the difference

340+

Audits Resolved

$2.1M

Avg. Penalty Avoided

< 48 hrs

Response Time

98%

Client Satisfaction

Level 1 — Routine to Serious

What happens after a HIPAA breach investigation?

The Office for Civil Rights opened 868 investigations in 2024. Most organizations don't know what a 'reasonable investigation response' looks like until after the penalty is assessed.

Scenario	Without Expert Guidance	With Comply Guidance
OCR Complaint Investigation	Average $1.2M–$4.8M civil monetary penalty Mandatory corrective action plan with 2–3 year OCR oversight Required annual self-audit submissions Public posting on OCR breach portal	Self-disclosure strategy reduces penalties by 60–80% Pre-negotiated CAP with minimal oversight period Audit-ready documentation submitted within 30 days Breach notification managed to minimize reputational exposure
Ransomware / Data Breach	Notification timeline violations compound penalties Business associate agreement gaps create joint liability Media notification triggers patient panic and disenrollment Class action exposure if notification is delayed	Breach risk assessment determines whether notification is required BAA remediation completed before OCR inquiry Coordinated notification strategy minimizes media footprint Documentation package prepared in advance of any investigation
Employee / Insider Threat	Workforce sanctions policy gaps result in OCR findings Inadequate access controls create systemic violation findings Up to $50,000 per violation per year of noncompliance Criminal referral to DOJ if willful neglect is established	Workforce training documentation demonstrates good faith Access control audit completed before investigation opens Proactive penalty mitigation through voluntary disclosure DOJ referral avoided through documented remediation timeline

No commitment. Your situation stays between us.

Level 2 — Deficiency to Immediate Jeopardy

How long do we have to respond to a CMS deficiency?

CMS gives you 10 calendar days to file a Plan of Correction after a deficiency notice. Most organizations spend 8 of those days understanding the citation. Comply starts the response on day one.

Scenario	Without Expert Guidance	With Comply Guidance
Deficiency Notice — Standard	Response deadline missed — escalation to Immediate Jeopardy Corrective Action Plan rejected on first submission (60% of DIY filings) CMS revisit survey scheduled — additional deficiencies cited Medicare/Medicaid payment suspension possible	Response filed within 10 days with complete documentation package CAP accepted on first submission — no revisit survey required Root cause analysis prevents recurrence findings Payment continuity maintained throughout remediation
Immediate Jeopardy Finding	Provider agreement terminated within 23 days if not abated CMS referral to State Agency for emergency suspension Medicare exclusion — loss of all federal program revenue Public posting on CMS website damages patient referrals	Immediate abatement plan prepared within hours of finding On-site compliance officer support during CMS revisit Provider agreement maintained — zero revenue interruption Remediation documented before public posting occurs
Conditions of Participation Violation	Termination from Medicare/Medicaid within 90 days State licensure referral — potential facility closure Average $2.3M revenue loss per month during exclusion Difficulty regaining certification — average 14-month process	Systematic CoP gap analysis completed before survey Appeals strategy preserves certification during remediation Revenue protection plan activated on day one Recertification achieved in average 6 weeks with Comply guidance

No commitment. Your situation stays between us.

Level 3 — Whistleblower to Federal Exclusion

What triggers a Corporate Integrity Agreement — and can we avoid one?

A whistleblower complaint filed under the False Claims Act can trigger simultaneous DOJ and OIG investigations before your compliance officer receives a single phone call. The next 72 hours are the ones that matter.

Scenario	Without Expert Guidance	With Comply Guidance
Whistleblower / Qui Tam Complaint	DOJ investigation without knowledge of scope or timeline False Claims Act exposure: 3x damages + $27K per false claim Relator receives 15–30% of government recovery Parallel OIG investigation triggered automatically	Internal investigation completed before DOJ contact Voluntary disclosure reduces FCA exposure by up to 50% Relator share minimized through cooperation credit OIG dialogue managed proactively — CIA terms negotiated
Corporate Integrity Agreement	Standard 5-year CIA with maximum reporting burden Independent Review Organization costs: $200K–$500K annually Any compliance failure triggers exclusion from all federal programs Executive certifications create personal liability for leadership	Negotiated CIA term reduced to 3 years with limited scope IRO costs minimized through documentation structure Compliance program enhancements prevent triggering events Executive liability protections built into compliance framework
Medicare / Medicaid Exclusion	Minimum 3-year exclusion from all federal healthcare programs Exclusion extends to all entities the individual owns or controls Average revenue impact: $4.1M per excluded provider per year Reinstatement requires full compliance demonstration — 18 months	Exclusion avoided through proactive self-disclosure and cooperation If exclusion occurs, reinstatement petition prepared immediately Revenue continuity plan implemented on day one Reinstatement achieved in average 7 months with complete documentation

No commitment. Your situation stays between us.

Track Record

The numbers that matter
when a surveyor is already in the building.

$4.8M

Largest penalty avoided

OCR HIPAA investigation — multi-location physician group, self-disclosure strategy, zero civil monetary penalty

17 days

CMS deficiency response

Corrective action plan accepted first submission — rural hospital, Conditions of Participation, immediate jeopardy finding cleared

100%

Survey pass rate

Clients who completed pre-survey readiness assessment passed without deficiency citations in 2024–2025

3 weeks

Avg. CIA negotiation timeline

Corporate Integrity Agreements negotiated with OIG — shorter compliance term, reduced reporting burden

What compliance officers say at 11 p.m.

"We received a CMS deficiency notice on a Thursday. By Monday morning, Comply had a remediation roadmap on my desk that our surveyors accepted without revision. I don't know what we would have done."

Chief Compliance Officer

Regional Health System, Southeast US

"Our HIPAA breach looked catastrophic from the outside. The self-disclosure strategy Comply built reduced our exposure by over 80%. The OCR investigator actually complimented our response documentation."

CFO

Multi-Specialty Physician Group, 12 locations

"I've worked with three compliance firms over my career. Comply is the first one that spoke to me like a peer — they knew our specific Conditions of Participation issues before I finished explaining them."

Practice Administrator

Ambulatory Surgery Center, Midwest

Regulatory Expertise

HIPAA / HITECHCMS CoPOSHA 1910OIG CIAStark Law42 CFR Part 2EMTALAAnti-KickbackMedicare ExclusionJoint CommissionCLIAMACRA / MIPS

The surveyor's calendar
doesn't care about yours.

Every week without a readiness assessment is a week your organization is exposed. A 30-minute confidential review costs you nothing. A deficiency notice costs considerably more.

Strictly confidential

30-minute consultation

No obligation

Response within 48 hours

They're Not Asking IfYou're Compliant. They're AskingYou to Prove It.

What happens after a HIPAA breach investigation?

How long do we have to respond to a CMS deficiency?

What triggers a Corporate Integrity Agreement — and can we avoid one?

The numbers that matterwhen a surveyor is already in the building.

What compliance officers say at 11 p.m.

The surveyor's calendardoesn't care about yours.

Schedule a Confidential Review

They're Not Asking If
You're Compliant. They're Asking
You to Prove It.

The numbers that matter
when a surveyor is already in the building.

The surveyor's calendar
doesn't care about yours.