Corporate Integrity Agreement Support

Strategic Management has unmatched compliance expertise and experience in assisting clients with meeting OIG Corporate Integrity Agreement (CIA) requirements used in civil settlements; and in serving as an Independent Review Organization (IRO) and Board Compliance Expert. The firm 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. They have intimate knowledge of CIA requirements relating to claims processing, Anti-Kickback Statute, Stark Law and other provisions.

What is a Corporate Integrity Agreement?

Corporate Integrity Agreements are documents outlining the obligations that a health care sector company makes with the DHHS Office of Inspector General as part of a civil settlement. The Agreement create a framework within which the company must operate to avoid being barred from participation in federal health care programs.

They generally last 5 years, during which time the provider must implement or expand a comprehensive compliance program and mandate establishing processes for managing and reporting “reportable events,” such as overpayments and potential violation of law. Most CIAs require an Independent Review Organization to review and monitor compliance with the terms and conditions of the CIA.

Strategic Management has extensive experience with CIA compliance with federal health care regulations and can help organizations across the health care industry meet important CIA deadlines and requirements.

Independent Review Organization Services

The benefits of engaging Strategic Management Services as an IRO includes:

  • Experience of providing IRO services to dozens of organizations including hospitals, skilled nursing facilities, clinical and imaging labs, physician practices, home health agencies, hospices, DME suppliers, among others.
  • Claims processing team is led by a nationally recognized expert on the OIG-approved RAT-STATS statistical sampling methodology used in conducting claims reviews, supported by certified medical coders, nurses, health information managers, and compliance professionals that together possess the knowledge, skills and ability to conduct statistical sampling, reviewing claims for medical necessity, coding and billing requirements.
  • Unparalleled expertise and experience in reviewing of arrangements with physicians for compliance with the Stark Law and the Anti-kickback statute.
  • A lead consultant ensures quality control in meeting all CIA requirements with timely, well documented reports that identify areas warranting added attention and how to address them.
  • Written certification in meeting OIG required independence, objectivity and non-conflict-of-interest standards of the General Accountability Office (GAO) “Generally Accepted Government Audit Standards” for operational reviews.
  • All IRO reports have been accepted by the OIG as meeting requirements and standards.

Compliance Expert to the Board

With over 30 years’ experience as a healthcare compliance consulting firm, Strategic Management is uniquely qualified to be a compliance expert to the Board under CIAs to assist in their compliance programs oversight CIA obligations. This includes assessing compliance program effectiveness, providing findings and recommendations for program improvements, and training Boards on compliance responsibilities and regulatory standards.