# Hls Draft Cia Response > 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. - Skill: `finchipaiorg/hls-draft-cia-response` (Agent Skill) - Install (CLI): `npx skillmds@latest add finchipaiorg/hls-draft-cia-response` - Raw SKILL.md: https://api.skillmd.com/api/skills/finchipaiorg/hls-draft-cia-response/raw - Safety review: pending - Works with: Claude Code, Claude.ai, OpenAI Codex - Category: Finance & Business - Author: FinchipAIOrg (https://skillmd.com/u/finchipaiorg) - Updated: 2026-09-22 - Page: https://skillmd.com/skills/finchipaiorg/hls-draft-cia-response --- # 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.