As an increasing number of healthcare organizations are negotiating Corporate Integrity Agreements (CIAs) with the federal government, many of them do not understand the scope or impact the Corporate Integrity Agreement will have on their organizations. Provident Management Consulting (“Provident”) serves as a trusted advisor to successfully navigate the challenges of Corporate Integrity Agreement negotiation readiness, and implementation. Provident’s Corporate Integrity Agreements/Independent Review Organization team facilitates the implementation of CIA and IRO obligations while reducing disruption to daily operations.
A COMPREHENSIVE APPROACH
Provident provides comprehensive CIA, IRO, and Deferred Prosecution Agreement (DPA) services to health care organizations and the law firms that support them. We are able to step in and provide solutions throughout the process, from planning, to implementation, to reporting.
- Review of Draft CIAs
Provident can become involved early in the Corporate Integrity Agreement negotiation process. Drawing on our extensive CIA and IRO experiences, our clients and their outside counsel call on Provident to review draft CIAs and provide insights and recommendations on how to lessen the impact of the requirements.
- Assessing CIA readiness
We collaborate with the chief compliance officer, general counsel, and/or senior management to assess an organization’s capacity to implement and report on its Corporate Integrity Agreement obligations, as well as its readiness to respond to the data and information needs of its IRO. The evaluation plan may include assessing the organization’s written controls and information systems, and identifying gaps and/or vulnerabilities in the following:
- Written controls and documented processes
- Covered persons/ineligible persons
- Training and education
- Compliance monitoring and auditing
- Data capture systems and reporting capabilities
- Reporting/government notifications
- Mock IRO Services
Using the same procedures as the IRO, Provident conducts mock IRO assessments by reviewing and testing the policies, procedures, processes, and systems that an organization’s IRO will review and test during its activities. Provident will also test the organization’s ability to pull accurate, complete data samples prior to the IRO’s field work, which results in a more efficient process when it counts.
- IRO Services
Provident has the knowledge, skills, and experience, as well as a proven methodology and approach that isdesigned to meet your organization’s IRO requirements while ensuring minimal disruption to the organization’s daily operations. As the IRO, we fulfill the following critical tasks:
- Educate relevant stakeholders about CIA obligations and IRO requirements
- Develop and implement an IRO work plan and testing procedures in accordance with CIA requirements
- Facilitate communications with the Office of the Inspector General
- Conduct data pulls, reviews and analysis
- Develop IRO reports that are timely
- Offer solutions to enhance the organization’s compliance with its CIA
WHAT SETS US APART
Our years of experience serving as the Independent Review Organization (IRO) to numerous health care organizations allows us to effectively prepare clients for the extensive provisions of their CIAs as well as their IRO’s procedures.
Our team has significant knowledge and the proven expertise and methodologies to facilitate the implementation of your company’s Corporate Integrity Agreement obligation while reducing disruption to its daily operations. Corporate Integrity Agreement implementation requires significant project management and industry knowledge; Provident can help you effectively mobilize and organize your organization’s resources to that end.
In addition, the Provident team has expertise in the key areas addressed by CIAs, including sales and marketing, state reporting and aggregate spend, compliance monitoring and auditing, fair market value, medical affairs, clinical affairs, and government price reporting.