Independent Review Organizations: A Compliance Contract with the HHS Office of Inspector General

Thomas Herrmann | April 2011

On April 12, Thomas Herrmann, a Strategic Management Vice President, held a joint presentation with Felicia Heimer, Senior Counsel, Office of Counsel to the Inspector General about independent review organizations (IROs) at the Health Care Compliance Association’s 15th Annual Compliance Institute in Orlando, Florida.  Mr. Herrmann’s and Ms. Heimer’s presentation, titled Independent Review Organizations – A Compliance Contract with the HHS Office of Inspector General, discussed the Department of Health and Human Services Office of Inspector General’s (OIG) requirements and expectations of an IRO regarding its independence, qualification and performance of Corporate Integrity Agreement (CIA) reviews.   Mr. Herrmann and Ms. Heimer examined the various professional, ethical and auditing standards which govern IRO reviews and activities.  In addition, they provided practical tips for health care entities to ensure a good working relationship with the OIG and IRO.

About the Author

Thomas Herrmann advises health care clients on compliance and regulatory matters, with a focus on development and management of effective health care compliance programs. Mr. Herrmann is a recognized expert on issues related to the federal Anti-Kickback Statute, Stark Law and the False Claims Act.