When You Need a Seasoned, Experience IRO,
What Should You Look For?
If your organization has recently negotiated or is in process of negotiating a Corporate Integrity Agreement (CIA) with the Office of the Inspector General for the U.S. Department of Health and Human Services (“OIG”), one of your new obligations under the CIA will likely be to find an organization to serve as Independent Review Organization ("IRO") as required by the CIA.
Independent - Not Adversarial
Our background as compliance officers and compliance staff for provider organizations means that we bring our deep experience in design and implementation of compliance processes for focus arrangements, or for Medicare and Medicaid claims development and submission, to bear as we conduct IRO reviews.
As your IRO we understand what it means to be independent and to maintain our independence (as required by the CIA) – which means in part that in the IRO role we can’t help you design and implement required structures or processes. But we can suggest approaches or options that we have seen work in other organizations, and that you might consider as you implement and improve your compliance program and CIA required processes. While maintaining our independence, we are often able in this manner to help organizations better meet the requirements of their CIA.
Our Diverse Experience Managing CIA
and IRO Requirements
Because of our experience managing IRO requirements – not only as an IRO service provider – but also as compliance officers and staff who have been responsible for an organization’s successful CIA implementation, we know how to approach and facilitate an IRO review process that is consistent with all CIA requirements, and will help provider organizations successfully meet CIA obligations. We have managed the IRO process from multiple vantage points, including:
Serving as IRO for several organizations who are subject to this CIA requirement
Managing the IRO process as chief compliance officer or compliance staff for organizations subject to CIAs
Assisting organizations with implementation and operation of CIA and IRO requirements as consultants and outside advisors
Expert IRO Experience
Arete Compliance Solutions offers a uniquely qualified IRO team, who have:
Served as IRO and/or Board Expert pursuant to recent CIA requirements
Implemented and managed compliance officer or senior compliance staff for several organizations under CIAsCIAs (including management of the IRO process) as chief
Attained decades of experience working with Medicare and Medicaid payment rules relevant to Claims Review IRO engagements, and with the requirements for submitting clean claims to governmental programs
Conducted and designed numerous claims audits and claims reviews in nearly every health care provider setting
Trained as attorneys and have substantial practical experience with the requirements of the Stark Law and Anti-Kickback Statute, and with related regulatory requirements relevant to Focus Arrangements CIAs
As compliance officers and compliance staff have designed, and in concert with management, implemented compliance systems and processes to assure compliance with Medicare and Medicaid payments rules, and with the requirements of the Stark Law and Anti-Kickback Statute
We believe our practical approach – steeped in years of hands on experience helping provider organizations build and operate effective compliance programs and processes – makes us unique in the community of IRO service providers. If you need an IRO please contact us. We would be honored to work with you and to conduct this important CIA required review of your organization’s compliance with CIA and Federal health care program requirements.
At our mission is to help you and your organization succeed.