Which of the following Is Required under a Corporate Integrity Agreement
A company under a corporate integrity agreement may amend an IRO, but must notify the Office of the Inspector General (OIG) within 30 days of the change with a statement of the reasons for the change. The Office of the Inspector General has the option to refuse the selection of the new IRO within 30 days of notification by the claimant. The scope of work is defined by the company`s integrity agreement and depends on the important issues contained in the initial agreement with the U.S. government. Most agreements cover one or more areas, the agreements of . B electronic with referral sources, marketing practices, claims processes and cost reporting. ICA can be used to solve problems related to quality of care or business integrity.  While the overall size of the IRO may not be as large, it is imperative that the IRO has sufficient resources to perform transaction testing during the term of the ICA. Testers don`t need to be auditors, but it`s best if they have a prior understanding of transaction sampling and the requirements for creating and maintaining working papers.
Transactional testing, conducted annually for the duration of the ICA, places significant demands on the company`s senior management and other employees in the areas tested. Management must not only provide documentation to support the samples selected by the IRO, but often also educate IRO testers on the types of documentation provided as evidence and answer questions. There is a learning curve for IRO testers, so it is important that the IRO limit changes testers from year to year. Frequent changes within the IRO test team only place higher demands on management to train new testers each year. The typical CIA requires the IRO to conduct a system review and assessments of certain areas within the first year. As part of this review, the IRO will likely require the Corporation to provide its policies, standard operating procedures (SOPs), work instructions and other documents to help it understand the Corporation`s activities. The IRO will review these documents and assess whether they are comparable to industry best practices and comply with the required rules and regulations. There are usually on-site and off-site components for the work of an Independent Review Body (IRO). On-site work is essential to gain first-hand knowledge of the company`s operations. In cases where the required documents can be reasonably and efficiently provided to the IRO without visiting the supplier`s website(s), most of the IRO`s work may be performed off-site. Strategic management has found that the less time there is on site in a company, the less it disrupts the normal operations of the organization. The key to a successful verification is to keep the entity up to date when specifying the required date.
ICAs create a framework within which the company must operate to avoid being excluded from participation in government health programs.  States use the CIA as part of their enforcement efforts.  :9 Where statistical sampling of claims or other data is required under a business integrity agreement, the Office of the Inspector General (OIG) requires independent review bodies to apply their SO-called RAT-STATS methodology. This is used to generate the sample, the sampling unit and the population from which the sample is selected must be defined. The inability of an independent review body (IRO) to properly apply this methodology can be very problematic. In fact, many potential IROs may not be familiar with this methodology. Strategic Management has one of the country`s leading experts on the RAT-STATS methodology along with Dr. Cornelia Dorfschmid, Executive Vice President of the company. In subsequent years, the IRO will conduct annual transaction testing in which it will select a sample of transactions and request supporting documentation.
One of the most important steps for the company during this process is to determine the type of supporting documents it needs to provide. 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 verifying the transaction. The company needs to organize the documents as far in advance as possible, which makes testing easier for the IRO and ultimately reduces the questions and associated costs. Many companies choose to perform their own transaction sample tests to anticipate the results of IRO tests. In this way, they can identify weaknesses in supporting documentation and correct gaps and weaknesses. In addition, the IRO will conduct at least one other review of the system in the last few years of the CIA. Strategic Management is a pioneer in supporting the healthcare industry with timely and innovative regulatory compliance solutions. It was founded 20 years ago by the former Inspector General of the Department of Health and Human Services (HHS).
It was the first consulting firm to focus on compliance and ethics initiatives for healthcare companies – even before the government issued formal guidance on compliance programs for the industry. It is one of the few consulting firms that focuses exclusively on the healthcare compliance industry and stands out for its unique expertise, qualifications and people….