OIG Corporate Integrity Agreement – Recruiting an IRO

Multiple handshakes_OIG Corporate Integrity Agreement

The Office of Inspector (OIG) Corporate Integrity Agreement requires the selection of an  Independent Review Organization (IRO) within 90 days of signing the agreement. This is one of the most important choices a healthcare organization subject to a Corporate Integrity Agreement (CIA) must make. If you’ve had little to no experience choosing one, selecting the right IRO for you can be a most challenging task.


Is the IRO a ‘Policing Agency’ for the OIG Corporate Integrity Agreement?

We are often asked this question and our answer is a definite NO!  When The Fox Group, LLC is your IRO, it is not a ‘policing agency’ for the OIG! We are a liaison between the OIG and the client. Once a client signs an engagement agreement with The Fox Group, our goal is to work as a team to assist the client in completing their corporate integrity agreement requirements.

As the IRO, we cannot act as a consultant to a client. For example, we cannot train staff on issues such as billing and coding. However, within our IRO reports and spreadsheets, we create a learning environment for providers and staff members.  We provide detailed notes, findings, and recommendations so that clients can utilize our report as a guide to correct their mistakes and decrease their error rate!

The initial challenge is you may not know how the IRO is going to perform until you are at the end of the first review year (or quarter for IA’s requiring quarterly reviews).  Currently, you must submit the IRO report to the Office of Inspector General of the Department of Health and Human Services within 60 days of the end of the review period.  Facing this deadline can oftentimes be an issue if the IRO has not prepared you properly for the review. Thus, your initial experience with the selected IRO may lead you to reconsider your choice.

Select or Replace your IRO

Changing IROs in the middle of your Corporate Integrity Agreement may seem like an onerous task.  But it does not have to be traumatic.

The IRO plays a key role in determining the organization’s compliance with the terms of the OIG corporate integrity agreement.  Given the gravity of the duties of the IRO and their relationship to you and your organization, the selection should be made thoughtfully and properly.


Critical IRO questions to consider in fulfilling OIG Corporate Integrity Agreement requirements.

  • Does the IRO  have experience in different types of reviews?
  • Does it matter where the IRO  is located?
  • Is the IRO free of conflicts of interest and meets all review standards?
  • Does the IRO provide expectations of your responsibilities before your first reporting?
  • What timeline does the IRO follow?
  • What is the IRO’s staff expertise?
  • What information does the IRO provide?

A good IRO will provide guidance during the process and will maintain an interactive relationship with the client.


What an IRO does and what it does not do

What an IRO is/does:

  • Is an independent third party,
  • Has no prior relationship with an organization,
  • Provides reports for you to submit to the OIG,
  • The scope of work provided is specifically delineated and limited to the requirements as outlined in the CIA

What an IRO is not:

  • Is not an agent of the government,
  • Cannot advocate for an organization or provide consultation/advice to an organization, during the engagement,
  • Cannot assist in implementation nor can an IRO provide reports other than the IRO report as required by the CIA.


Experience and expertise

The Fox Group, LLC, provides personalized, conscientious, and comprehensive IRO services. We are well versed in addressing the details of the CIA to help your organization comply with
mandates from the Office of Inspector General (OIG).

Our team of experts has assisted numerous healthcare organizations with many types of CIAs.  An example of some clients include . . .

  • Neurology practice
  • Large acute-care teaching hospital
  • Interventional cardiology clinic
  • Development centers
  • Diagnostic imaging centers
  • Internal medicine
  • Multilocation pain management
  • Network of skilled nursing facilities
  • Retail pharmacy
  • Hospice facility/in & outpatient
  • Rehabilitation center

In each case, our many years of hands-on experience and understanding of the details that go into meeting CIA reporting requirements has enabled our clients to provide the OIG with a
comprehensive, easy-to-follow, well-thought-out IRO report.

The Fox Group has worked with a diverse group of healthcare entities to provide comprehensive and expert IRO services, ensuring that these entities are in compliance with their CIA.

When you need proven expertise and performance

Cindy Winn, MBA, CHSP

Ms. Cindy Winn has over 20 years of healthcare experience and expertise in operations, project management, and is certified as a HIPAA Security Professional (CHSP).

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