On November 5, 2015, OIG excluded C.F. Health Management, Inc. d/b/a/ Gainesville Pain Management (Gainesville), for a period of five years, based on a material breach of its Corporate Integrity Agreement (CIA). During the first reporting period of its CIA, Gainesville’s Independent Review Organization (IRO) identified an error rate of 28% in its Discovery Sample and an error rate of 37.98% in its Full Sample, resulting in an extrapolated overpayment of $239,961.80. On July 16, 2015, OIG issued a letter demanding stipulated penalties in the amount of $34,000 based on Gainesville’s failure to repay the overpayment identified by its IRO. After Gainesville failed to respond to OIG’s demand letter, OIG issued a notice of material breach and intent to exclude on August 21, 2015. Under the terms of the CIA, Gainesville had 25 days to request a hearing with an Administrative Law Judge. Gainesville did not request a hearing and the exclusion went into effect on November 5, 2015. Senior Counsel Nicole Caucci represented OIG.