While compliance is cumbersome and typically costly, the OIG`s Corporate Integrity Agreements guide companies in implementing an effective healthcare compliance program that ultimately leads to proper billing practices. This includes submitting accurate and complete claims to government health programs, appropriate agreements with physicians, and improving the quality of care for program recipients. Since the OIG`s Corporate Integrity Agreement is a contractual agreement between the OIG and a healthcare organization that requires the organization to meet a defined set of compliance obligations, it is important to meet all the requirements. Violations of the OIG`s Agreement on Business Integrity and non-compliance with obligations under the Agreement can result in severe penalties, including possible exclusion from participation in government health programs. A CIA is essentially a contract between a health care facility and the Office of the Inspector General. Under an CIA, a health care provider agrees to assume certain compliance obligations under a civil regulation regarding its future participation in federal health programs in exchange for the OIG`s agreement not to exclude the provider or provider of Medicare, Medicaid, and other federal health programs under its legal authority. A CIA typically has a five-year term and is designed to “ensure the integrity of federal health claims filed by [a] provider”.22 This article contains public domain material from the U.S. Department of Health and Human Services` Corporate Integrity Agreements Snapshot (PDF). Retrieved 14 April 2018.
It is important to note that the OIG does not choose the IRO. In addition, they do not give advice on selection and do not support organizations that are IRO. It is entirely up to the entity or supplier to determine the most appropriate organization to engage as an IRO. However, the Office of the Inspector General reserves the right to approve or reject the choice of the IRO by the Companies or the Supplier within 30 days of receipt by the Office of the Inspector General of the written notification of the identity of the IRO. As a rule, companies such as consultants, accounting firms (CPAs) or law firms are mandated to perform such tasks. While most health organizations that have settlement agreements with the Department of Justice have spent a lot of time, effort and money on an agreement, they have had relatively little thought into the process for selecting an IRO that would be approved by the OIG. In many cases, this has led to additional problems and exacerbations. The following discussion is designed to help any organization facing the prospects of a CIA think about how to find and select a qualified IRO.
The CIA clearly identifies areas of the company`s compliance program that need to be improved. While these are tailored to the specific compliance challenges discovered in the company in question, the CIA often requires the company: In the following years, the IRO will conduct annual transaction tests in which it will select a sample of transactions and request supporting documents. One of the most important steps for the company during this process is to determine the type of acceptance documentation to be provided. It is not always necessary to provide all documents related to the transaction, but it is important to agree with the IRO on the type and number of documents that would meet the requirements of the transaction test. .