A Northeast hospital system identified that one of its teaching hospitals had submitted improper claims - they did not have the proper documentation or were uploaded-to federal healthcare programs. The hospital system uncovered the false claims during the course of an internal audit performed as part of its voluntary compliance program. In the summer of 2000, the hospital system agreed to resolve its False Claims Act liability. The OIG did not impose a CIA because the hospital system disclosed the misconduct to the government and the hospital system had a preexisting , comprehensive compliance program.