Draft Corporate Integrity Agreement Response

---
name: hls-draft-cia-response
task_id: healthcare-life-sciences/draft-corporate-integrity-agreement-response
description: Drafts a CIA implementation plan and board resolution package that maps each CIA obligation to a timeline, addresses chief compliance officer qualification and independence requirements, and includes multi-period staffing and budget projections for review.
activates_for: [planner, solver, checker]
---

# Skill: Draft Corporate Integrity Agreement Implementation Plan and Board Resolution

## 1. Subject-matter triage

- Confirm the proposed CIA’s effective date, term, required attachments, and any incorporated policies, then anchor every deadline to that date.
- Separate obligations that are immediate, recurring, contingent, or board-facing, because they drive different drafting sections and approval paths.
- Identify any items that require advance buildout before effectiveness, especially staffing, training infrastructure, reporting workflows, and governance approvals.
- If the source set includes multiple affected entities, periods, or workstreams, enumerate them before drafting so each gets its own implementation line.

## 2. Failure modes the skill is correcting

- The implementation plan stays at a high level and fails to convert CIA obligations into concrete milestones, owners, and due dates.
- The plan omits the compliance implications of personnel involved in the conduct that triggered the agreement, leaving remedial actions vague instead of specific.
- The draft ignores chief compliance officer qualification, independence, and reporting-line requirements, creating avoidable governance defects.
- Staffing needs are described qualitatively, but not translated into current-versus-required headcount, interim coverage, and hiring timing.
- Training readiness is assumed rather than built, so the plan does not show how initial and recurring training deadlines will be met.
- Budget support is incomplete when it does not show the multi-period cost of compliance operations, monitoring, independent review, training, and related overhead.
- Reporting obligations are treated generically, without separate treatment for reportable events, material changes, annual certifications, and notice provisions.
- The board resolution authorizes compliance in principle but does not clearly approve the program, committee structure, budget, and officer authority needed for implementation.

## 3. Legal frameworks / domain conventions that apply

- Treat the CIA as a binding regulatory compliance instrument; draft against the actual text of the agreement and any incorporated policies or appendices.
- Use the CIA’s own definitions, deadlines, notice provisions, certification mechanics, and stipulated-penalty structure as the controlling framework for the plan.
- Apply corporate governance conventions for board action: identify the approving body, recite the authority being delegated or ratified, and state any committee creation or charter update explicitly.
- For compliance officer independence, use standard healthcare compliance practice: the compliance function must be able to escalate, investigate, and report without undue interference from operations or legal functions.
- For remediation of implicated personnel, use a corrective-action framework that ties roles, restrictions, reassignments, discipline, monitoring, or separation to the underlying conduct and risk exposure.
- For staffing, use a realistic operating model that distinguishes baseline compliance staffing from project-based implementation support and outside-review support.
- For budgeting, use a multi-period projection that separates personnel, external advisors, monitoring, training, technology, audit support, and other agreement-required expenses.
- If the CIA requires fair market value or independence review for arrangements, build a documented approval process with benchmarking, conflict checks, and prospective signoff.
- For all legal propositions relied on, cite the operative authority as stated in the source documents or the controlling CIA provision; do not state obligations in conclusory form without naming the governing provision.

## 4. Analytical scaffolds

1. Obligation-to-timeline map
   - List each CIA obligation, the trigger, the deadline, the owner, the prerequisite, and the implementation status.
   - For recurring items, specify frequency and the first occurrence.
   - For contingent items, state the trigger condition and the action required if triggered.

2. Compliance leadership section
   - Identify the chief compliance officer requirements in the CIA.
   - State whether the current candidate satisfies each requirement.
   - If there is any gap, propose a transition, backfill, or reporting-line change that preserves independence.

3. Personnel remediation section
   - Identify personnel whose roles are implicated by the conduct or whose responsibilities must change because of the agreement.
   - State the specific remedial action for each person or role, with timing and oversight.
   - Distinguish discipline, retraining, reassignment, supervision, and removal where appropriate.

4. Staffing and operating model section
   - Compare required compliance capability against current resources.
   - Show interim coverage for any gap period before new hires or vendors are in place.
   - Tie each role to a function: monitoring, training, investigations, reporting, data analytics, or program administration.

5. Budget section
   - Break costs into periods that match the CIA term or implementation phases.
   - Include internal labor, external review, training, technology, travel, remediation, and other required spend.
   - Flag any cost item that is one-time, recurring, or contingent on a trigger.

6. Training and policy rollout section
   - State which audiences must be trained, when the training must be completed, and what materials or systems must exist first.
   - Identify the policy and attestation updates needed to support the training plan.
   - Include make-up training and refreshers where the CIA contemplates ongoing obligations.

7. Reporting and escalation section
   - Separate annual, periodic, event-driven, and board-notification obligations.
   - For each, state who prepares it, who reviews it, who approves it, and when it must be delivered.
   - Build a path for escalation of issues that could create notice, certification, or penalty exposure.

8. Board resolution section
   - Translate the plan into board action: approve the implementation plan, authorize the budget, establish any committee, and delegate implementation authority.
   - Include any required reporting cadence back to the board and the standard for updating the board on material compliance issues.

## 5. Vertical / structural / temporal relationships

- Organize the plan in the order the CIA obligations must be satisfied: immediate setup, near-term buildout, recurring compliance, and year-end or term-end reporting.
- Where one obligation depends on another, state the dependency explicitly; do not bury prerequisite sequencing inside narrative text.
- If a deadline depends on effectiveness, use the effectiveness date as the anchor and calculate forward from that point in the document.
- Distinguish board-level governance actions from management-level implementation actions so the approval package is not internally inconsistent.
- If the CIA contains multiple affected business lines, facilities, or functions, keep the implementation steps separated by unit and by period.

## 6. Output structure conventions

- Draft two standalone documents: one CIA implementation plan and one board resolution.
- CIA implementation plan should read like an operative compliance roadmap, not a memo about what the roadmap will contain.
- Use clear headings that conventional healthcare compliance reviewers expect: overview, obligations and timeline, leadership and staffing, remediation, training, reporting, budget, and controls.
- Include specific owners, deadlines, and dependencies in the body of the implementation plan; avoid abstract commitments without execution detail.
- Board resolution should contain recitals, board findings, operative approvals, committee actions if needed, delegation of authority, and a record of adoption.
- Make the resolution specific enough that the board can rely on it for implementation authority and oversight, not merely symbolic endorsement.
- Preserve internal consistency between the plan and the resolution on names, roles, committees, budget authority, and reporting cadence.
- Write with enough specificity that the deliverables can be adopted, circulated, and filed without further substantive drafting.