America's active integrity agreements: half sit in five states

HHS's Office of Inspector General keeps a public registry of the health-care organizations and individuals operating under an integrity agreement — a forward-looking compliance arrangement OIG enters with a party, usually in connection with resolving a matter. The agreement does not adjudicate anything; it sets obligations going forward: a compliance program, training, internal and independent audits, and regular reporting to OIG, typically over a multi-year term. The registry lists each agreement, whether it is currently in effect or has concluded, and where the party is located. Read it as a map and one fact stands out: the active caseload is small, and it is densely concentrated in a handful of states.

The active caseload is the live picture — and it is small

Of the 335 agreements on the published registry, 114 are currently in effect. The remaining 221 are concluded — 208 marked Closed and 13 carrying no status label.

Source: HHS-OIG Corporate Integrity Agreements, snapshot 2026-06-13.

The two date columns explain how the registry works. An effective date is published only while an agreement is in force; once it concludes, the row carries a closed date instead. That is why the 114 active agreements are exactly the rows that carry an effective date, and the 208 Closed agreements are exactly the rows that carry a closed date. The registry is therefore both a live roster and an archive in one file — and the live roster, the part that describes who is under an obligation today, is 114 agreements.

A corporate integrity agreement is a forward-looking compliance obligation, not a verdict rendered here. It records that an organization agreed to be monitored — and says nothing this study infers about fraud, wrongdoing, or the standing of any party.

Half the active caseload sits in five states

The five largest states hold 57 of the 114 active agreements — exactly 50.0% — and California and Florida alone hold 35, or 30.7%. The active caseload reaches 29 jurisdictions in all, but it thins out fast below the top of the list.

Source: HHS-OIG Corporate Integrity Agreements, the eight states with the most active agreements, snapshot 2026-06-13.

California and Florida lead on both measures — the active caseload and the full registry — and together they carry nearly a third of every agreement currently in effect. The concentration tracks where large health-care provider populations and OIG enforcement activity are heaviest; it is a map of where agreements are administered, not a ranking of any organization.

Most active agreements are the comprehensive kind

88 of the 114 active agreements — 77.2% — are full Corporate Integrity Agreements; the other 26 are the lighter-weight Integrity Agreement. The two instruments do the same job at different scale: the CIA carries the fuller set of obligations, the IA a lighter set generally used for smaller entities or individuals.

Source: HHS-OIG Corporate Integrity Agreements, by agreement type, snapshot 2026-06-13. "Concluded" combines Closed and unlabelled rows.

The CIA share is higher among active agreements (77.2%) than across the full registry (65.4%), a sign that the comprehensive form runs its multi-year term while a larger share of the lighter IAs has already concluded. The split is structural — it reflects which instrument OIG used, not anything this study infers about the parties.

When the active agreements took effect

The active caseload spans agreements effective from 2019 onward, peaking at 25 in both 2022 and 2024. Because a CIA runs a multi-year term, agreements that took effect much before 2019 have largely concluded and dropped off the active list — so the effective-year curve is the footprint of the standard term, not a measure of yearly enforcement volume.

Source: HHS-OIG Corporate Integrity Agreements, currently-effective agreements by the year each took effect, snapshot 2026-06-13.

This is the only time view the active file supports: it counts agreements still in force by their start year, not a flow of new matters. The 2026 figure is a partial year. Reading the curve as a trend in enforcement would over-read it — older agreements are absent because they have ended, not because fewer were signed.

What one row actually is

Each row in oig_cia_agreements is one agreement: the party's name, the agreement type, its status, the effective or closed date, the location, and the registry's own record key. The published file is the current registry — active agreements alongside concluded ones — so counting and grouping these rows is the entire method here. The NPI-to-entity-graph link is not populated for this source: entity_id and npi are empty on every row, so an integrity agreement renders on no individual provider profile. Every figure in this study is a count or percentage at the status, state, type, or year level. No organization or individual is named, ranked, or scored, and no inference of fraud, wrongdoing, or risk is drawn about any party.

Methodology

All figures are direct aggregations over the oig_cia_agreements table, populated from HHS-OIG's Corporate Integrity Agreements registry (oig.hhs.gov). The table holds 335 agreement rows across 43 jurisdictions and 333 distinct entities; source release date 2026-06-13; public, read-only; license US-Government-Works. OIG maintains the registry on an ongoing basis, adding new agreements and moving concluded ones from an effective date to a closed date, so figures advance with each refresh.

This study reads the published registry as a whole and partitions it by status: the active caseload is the 114 rows with status = 'Effective' (each carrying an effective_date, no closed_date); the concluded set is the 208 Closed rows plus 13 unlabelled rows. The agreement-type groups are the two values the registry uses verbatim — Corporate Integrity Agreement and Integrity Agreement. State concentration counts active agreements by state; effective-year figures use extract(year from effective_date), which marks when an active agreement took effect, not a yearly flow of new matters. Because these are counts and ratios over a published file, every figure is exact as of the snapshot rather than estimated. Methodology version: oig-cia/v1. The source-provenance contract is documented in the provenance methodology.

Limitations

• A compliance record, not a finding of fraud. An integrity agreement is a forward-looking compliance obligation OIG enters with a party, typically in connection with resolving a matter. The registry does not adjudicate, and this study infers nothing about fraud, wrongdoing, liability, or risk of any named organization or individual.
• Aggregate and category-level only. Every figure is a count or percentage at the status, state, agreement-type, or year level. No party is named, ranked, or scored, and the NPI-to-entity-graph link is not populated, so no agreement renders on a provider profile.
• The registry is a current roster plus an archive. The file holds active and concluded agreements together; it is not a complete historical census of every agreement OIG has ever administered. Counts of past effective years describe agreements still in force, not the full historical flow.
• Effective year is the start of an active agreement, not annual enforcement volume. Because agreements run a multi-year term, the effective-year curve is shaped by which agreements remain in force, and older agreements are absent because they have concluded. The 2026 figure is a partial year.
• Status labels follow the registry. 13 rows carry no status label; all 13 are Corporate Integrity Agreements, and they are grouped with the concluded agreements throughout (both in the active-versus-concluded split and in the agreement-type table). Grouping otherwise follows the registry's own fields exactly.
• Snapshot, not a trend model. Figures reflect the single registry dated 2026-06-13. OIG refreshes it on an ongoing basis, so shares shift between releases; this study does not model change over time.

Sources

• HHS-OIG — Corporate Integrity Agreements — the public registry behind every figure in this study, listing each active and concluded agreement.
• HHS Office of Inspector General — the federal authority that administers integrity agreements and publishes the registry.

The companion dataset family page for OIG Corporate Integrity Agreements lists the spec and the studies that draw on it. This is the compliance-obligation companion to the exclusion record — who gets barred from Medicare, and why, why exclusions cluster around distressed operators, and the gap between federal and state exclusion screening; for the parts of the enforcement picture that touch billing eligibility see excluded providers still enrolled in Medicare and those still cleared to order and refer.