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In response to a surge in Medicare, Medicaid and private health care insurance fraud and abuse, a special AICPA task force issued SOP 99-1--guidance for CPAs whose clients have settled claims with the Department of Health and Human Services (HHS). (The text of the SOP, without appendices, appeared in the JofA, July99, pages 102-106.)

According to HHS officials, such fraud and abuse allegations are likely to continue to grow. To resolve the allegations, a health care provider usually enters into a corporate integrity agreement (CIA) with the HHS. The CIA specifies what the provider is required to do to set up a corporatewide integrity and compliance program. It also requires that the provider's management annually report on and have an assessment made of its compliance with the CIA. The assessment, which a CPA can perform, includes an agreed-upon procedures report and a billing analysis.

"The HHS inspector general was concerned because the reports have been inconsistent--too short and incomplete or too long and lost in detail" said William Titera, chairman of the AICPA health care task force.

"We need assurance that providers are adhering to the CIA requirements," said Dennis J. Duquette, the HHS deputy inspector general for management and policy. "To achieve that assurance, we needed a common approach."

Duquette told the JofA that SOP 99-1, intended to assist providers in strengthening their internal controls and identifying current and emerging problems, is "a firewall against fraud and abuse."

SOP 99-1, Guidance to Practitioners in Conducting and Reporting on an Agreed-Upon Procedures Engagement to Assist Management in Evaluating the Effectiveness of Its Corporate Compliance Program (product no. 014921JA), is available from the AICPA order department for $10.50 ($13 for non-members) at 888-777-7077.