100%

Healthcare-Focused

30+

Years Experience

End-to-End

IRO Support

Meet Your CIA Obligations with Confidence 

What is an Independent Review Organization (IRO)? 

An Independent Review Organization (IRO) is a neutral third party that provides external reviews and determines the medical necessity of healthcare services. This is an essential component of a Corporate Integrity Agreement (CIA) or Integrity Agreement (IA) – validating key compliance areas, such as arrangements with referral sources,, claims and marketing practices. 

Strategic Management Services takes a thorough approach and streamlines the process to make it easy and effective for our clients.  Not only do we offer healthcare-specific IRO services โ€“ such as claims reviews and evaluating compliance โ€“ but we also run mock IRO reviews to help you prepare.

Every Review You Need to Prove Compliance

Comprehensive IRO Services

  • Arrangements Reviews
    Determine if your arrangements comply with the Anti-Kickback Statute, the Stark Law, and CIA requirements โ€“ all based on regulatory expertise. Our consultants conduct reviews of arrangements between your healthcare organization and its practitioners, suppliers, vendors, and other healthcare providers. 
  • Claims Reviews
    Evaluate your claims to ensure they are in accordance with federal healthcare coding and billing requirements. Our team uses a sampling strategy developed based on the OIGโ€™s approved RAT-STATS methodology to make claims reviews accurate and efficient.
  • Systems Review
    Verify the compliance of all systems that track, monitor and verify claims, arrangements, pricing, and marketing and sales activities. Our consultants review your systems โ€“ such as claims processes, policies, and procedures – using expert knowledge of governing Federal requirements and standards.

Struggling to Meet Your CIA Obligations?

  • Transaction Reviews
    Ensure your transactions are not at risk of non-compliance with the Anti-Kickback Statute, Stark Law, or CMS program coverage. Our statistics experts select samples of transactions to be reviewed in accordance with OIG RAT-STATS and CMS Program Integrity standards.
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    Our consultants review unallowable costs included in a health care organizationโ€™s cost reports or claims submitted to Federal health care programs. We then determine if unallowable costs were reported and adjusted – and ensure they are not included in the future cost report or claims.
  • Marketing Practices Reviews
    Determine whether your marketing practices meet Federal healthcare program requirements. Our consultants examine marketing practices carried out by pharmaceutical or device manufacturers, managed care organizations and other types of health care organizations engaging in marketing practices with federal healthcare beneficiaries.
  • Secret Shopping & Compliance Reviews
    Establish whether your organization conducts its marketing or enrollment practices in accordance with Federal requirements. We complete these reviews in two ways: 
    • Monitoring marketing practices of pharmaceutical and device manufacturers and marketing and enrollment practices of managed care organizations. 
    • Conducting secret shops by posing as a Medicare or Medicaid eligible beneficiary seeking information about or enrollment with the organization. 

Related Resources

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12 Tips for Selecting an IRO

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Preparing for a Corporate Integrity Agreement

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FAQs About OIG Corporate Integrity