Lessons learned from an Independent Review Organization

Provident has served as an Independent Review Organization (“IRO”) for organizations fulfilling their Corporate Integrity Agreements (“CIAs”). Throughout our engagements, we have identified key findings and recommendations through our review of Arrangement Procedures, Arrangement Requirements and Focused Arrangements. Below are key items we think are necessary to ensuring your policies, procedures and systems meet federal and state requirements:

  • Tracking Fair Market Value – ensure there are processes, systems and a methodology in place for tracking Fair Market Value (“FMV”). We recommended implementing a process whereby FMV research and documentation is centrally located for administrators and key personnel to reference when completing Business Needs forms. We further recommend that the FMV research and documentation is updated and revised regularly.
    • Compliance With Anti-Kickback Safe Harbor – all new and revised arrangements should be reviewed by internal or external counsel with expertise in Anti-Kickback Statute and other applicable State and Federal laws, including the Stark Law.
    • Signed Agreements – implement a tracking system and process whereby all arrangements are reviewed for appropriate signatures and dates prior to the execution of a contract. This includes signatures and dates for all responsible internal and external (vendor) parties. Additionally, we recommend a stop -gap whereby no invoices or payments are made or generated unless a contract number is available (indicating a written agreement was signed).
    • Remuneration Related to Focus Arrangement Properly Tracked track and document all types and quantities of services performed or items provided. Organizations should require the submission of remuneration documentation prior to making any payments.
    • Service and Activity Logs – ensure Medical Director and Assistant Medical Director logs are complete, accurate and signed by Administrators. Service logs should include dates of services, hours and activities performed. We further suggest training for physicians and administrators so that all parties understand the importance of service and activity log and the documentation necessary to ensure they are complete. An escalation policy is further recommended in the event physicians are not compliant with completing logs.

Finally, we recommend frequent and regular internal and external audits to ensure compliance with OIG and local guidelines (e.g. post-payment audits to ensure signatures, documentation and service logs are present). For more information about Provident’s IRO services, including mock-IRO services, please visit our IRO services page. 

 

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