100%
Healthcare-Focused
30+
Years Experience
Full Scope Support
of CIA requirements
What is a Corporate Integrity Agreement?
A Corporate Integrity Agreement is a binding obligation entered as part of a civil settlement with the OIG. CIAs typically run five years and require the organization to maintain a qualifying compliance program, report specified events, and submit to independent review. Most CIAs require an IRO to monitor and report on compliance throughout the agreement term.
How We Help
Independent Review Organization Services
Strategic Management Services has served as an IRO for dozens of organizations across the healthcare sector, including hospitals, skilled nursing facilities, clinical and imaging labs, physician practices, home health agencies, hospices, durable medical equipment (DME) suppliers, and more. Every IRO engagement is built to produce OIG-accepted deliverables.
Here is what that looks like:
- Dedicated Consultant
We assign a lead consultant responsible for quality control across all CIA requirements with timely, well-documented reports that identify issues and how to address them. - RAT-STATS Claims Reviews
If the CIA requires a physician arrangements review, it’s conducted using OIG-approved RAT-STATS statistical sampling methodology. A nationally recognized expert in that methodology leads the process, supported by certified medical coders, nurses, health information managers, and compliance professionals. The result: statistically defensible reports that meet OIG requirements and hold up to scrutiny. - Stark Law and Anti-Kickback Statute Reviews
Our team conducts physician arrangement reviews for compliance with the Stark Law and Anti-Kickback Statute, drawing on long-standing technical depth in both areas. Organizations leave these reviews with a clear picture of where their arrangements stand and what actions, if any, are needed to achieve compliance. - Certified Independence
We provide written certification that meets OIG-required independence, objectivity, and non-conflict-of-interest standards, consistent with the General Accountability Office’s (GAO) Generally Accepted Government Audit Standards for operational reviews. - 100% Acceptance
All of our IRO reports have been accepted by the OIG as meeting applicable requirements and standards, reducing the back-and-forth that delays CIA fulfillment and increases exposure.
Recognition from Our Clients
Compliance Expert to the Board
CIAs frequently require a designated compliance expert to the Board. Strategic Management Services fulfills this role for organizations that need independent, qualified oversight of their compliance program obligations.
As Compliance Expert to the Board, we conduct an annual compliance program review, provide compliance training to the Board, and attend Board meetings on compliance matters. We’re also available to the Board as needed to answer questions, deliver additional training, and keep them current on compliance risks and industry trends.
Our team brings 30 years of healthcare compliance consulting experience and a track record of successful CIA fulfillment to every engagement. The firm’s leadership includes individuals who previously served in executive capacities with the OIG, including the Inspector General, Chief of the OIG Counsel’s Administrative Litigation Branch, and Director of Resource Management and Operations.
Fulfill Your CIA With Confidence
Reports accepted by the OIG on the first submission. Talk with an expert about your agreement.
CIA Implementation
Strategic Management Services also offers CIA implementation, a service typically used by small to mid-size organizations that need direct support putting the terms of a Corporate Integrity Agreement into practice. The firm works alongside the Compliance Officer to carry out every requirement of the CIA.
This includes developing policies, building out training, coordinating management attestations, and drafting both the workplan and the implementation report due to the OIG monitor.
