CVS Health Corporation Corporate Integrity Agreement
CORPORATE INTEGRITY AGREEMENT BETWEEN THE OFFICE OF INSPECTOR GENERAL OF THE DEPARTMENT OF HEALTH AND HUMAN SERVICES AND CVS HEALTH CORPORATION I. PREAMBLE CVS Health Corporation and its subsidiaries (collectively, “CVS Health”) hereby enters into this Corporate Integrity Agreement (CIA) with the Office of Inspector General (OIG) of the United States Department of Health and Human Services (HHS) to promote compliance with the statutes, regulations, and written directives of Medicare, Medicaid, and all other Federal health care programs (as defined in 42 U.S.C. § 1320a-7b(f)) (Federal health care program requirements). CVS Health is an integrated pharmacy services health care provider engaged in certain business lines that do business with Federal health care programs. Except as otherwise specified herein, the terms of this CIA shall apply to Omnicare, Inc. and its operating subsidiaries, which is CVS Health’s business line of institutional pharmacy services operations (“IPS Operations”), as defined in Section II.C.1, below. Effective August 18, 2015, CVS Health acquired Omnicare, Inc. Contemporaneously with this CIA, Omnicare, Inc. is entering into a Settlement Agreement with the United States. In consideration of the obligations of CVS Health in this CIA and the obligations set forth in the settlement agreement entered into among the United States of America, acting through the United States Department of Justice and on behalf of the OIG-HHS; Omnicare, Inc.; NCS Healthcare, LLC; NeighborCare, Inc.; and Relators Donald Gale and Marc Silver on June 25, 2014 (hereinafter “2014 Omnicare Settlement Agreement”), OIG agrees to release and refrain from instituting, directing, or maintaining any administrative action seeking exclusion from Medicare, Medicaid, and all other Federal health care programs (as defined in 42 U.S.C.
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