Episode 31 ·
Life and Learnings from a CIA: A Discussion with Lucia Pizano-Urbina from Broward Health
Send us Fan Mail How do you know? Where’s the proof? In this episode, Captain Integrity Bob Wade welcomes Lucia Pizano-Urbina of Broward Health to chat about life operating under a Corporate Integrity Agreement and the world of Compliance. Hear how to create a CIA Annual Report Subcommittee, always have a plan of correction for any item, be organized, learn the CIA (Corporate Integrity Agreement) inside and out, and check, check, check. Learn more at CaptainIntegrity.com
- Corporate Integrity Agreements
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Life and Learnings from a CIA (with Lucia Pizano-Urbina, Broward Health)
Episode Date: May 11, 2022
In this episode of Stark Integrity, host Bob Wade (“Captain Integrity”) is joined by Lucia Pizano-Urbina of Broward Health to discuss a topic many organizations hope to avoid—but should fully understand: life under a Corporate Integrity Agreement (CIA).
What Is a CIA?
A Corporate Integrity Agreement is typically imposed as part of a settlement with the government following compliance violations. It places an organization under heightened oversight, requiring detailed reporting, monitoring, and corrective actions.
As this episode highlights, operating under a CIA is not just a legal obligation—it is a full-scale operational commitment.
Life Under a CIA
Lucia shares real-world insights into what it takes to successfully manage a CIA, including:
- Building strong internal structure and accountability
- Creating dedicated committees (such as an annual report subcommittee)
- Maintaining rigorous documentation and organization
- Developing corrective action plans for identified issues
The overarching theme? Preparation and discipline are everything.
“How Do You Know?”
A key takeaway from this episode is the importance of being able to answer one simple question:
“How do you know?”
Under a CIA, assumptions are not enough. Organizations must be able to produce clear evidence that:
- Policies are being followed
- Controls are working
- Compliance activities are effective
Proof—not intention—is what matters.
Practical Lessons for All Organizations
Even for organizations not under a CIA, the lessons from this episode are highly valuable. Key takeaways include:
- Know your compliance program inside and out
- Document everything clearly and consistently
- Be proactive in identifying and correcting issues
- Build systems that can stand up to scrutiny
In many ways, a CIA represents the highest standard of compliance discipline—and a model others can learn from.
Final Thoughts
This episode offers a rare, practical look into life under a Corporate Integrity Agreement. With insights from Lucia Pizano-Urbina, it highlights both the challenges and the opportunities to build a stronger, more effective compliance program.
The message is clear: whether or not you are under a CIA, adopting these practices can help ensure your organization is prepared, defensible, and aligned with regulatory expectations.
Click here to listen to this Stark Integrity Podcast Episode:
https://podcasts.apple.com/us/podcast/life-and-learnings-from-a-cia-a-discussion/id1588939373?i=1000558817101&l=fr-FR