An increasing number of healthcare organizations are negotiating Corporate Integrity Agreements (CIAs) with the federal government. Many agreements require the services of an Internal Review Organization to fulfill activities as outlined in the agreements. Provident’s Corporate Integrity Agreement and Independent Review Organization team facilitates the implementation of Corporate Integrity Agreement (CIA) and Independent Review Organization (IRO) obligations while reducing disruption to daily operations.
Independent Review Organization (IRO) Approach
Provident has the knowledge, skills, and experience, as well as a proven methodology and approach that is designed to meet your organization’s IRO requirements. As the Independent Review Organization, 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
Provident has functioned as the Independent Review Organization for a range of healthcare organizations including pharmaceutical and medical device companies, hospitals, skilled nursing facilities and rehabilitations centers. Specifically, Provident has:
- Conducted various types of reviews as outlined in CIA’s including:
- Unallowable Cost Reviews
- System Arrangement Reviews
- Focus Arrangement Reviews
- Transaction Arrangement Reviews
- Identified areas of improvement to adhere to CIA requirements including:
- Potential employee training needs
- Additional policies and procedures necessary to adhere to CIA requirements
- Workflow processes necessary to adhere to CIA requirements
- Routinely completed claims reviews and other clinical documentation assessments for healthcare clients
Provident recognizes the importance of managing IRO projects and report deadlines and will develop a detailed, resourced project plan and timeline. Additionally, all efficiencies gained from similar engagements are built into our plans, timelines and budgets.
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.
CIA 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.