Deferred Prosecution Agreement (DPA), Corporate Integrity Agreement (CIA) & Independent Review Organization (IRO)
Working alongside legal counsel in the healthcare industry
Our team has a long history of working alongside legal counsel in the healthcare industry. We bring years of experience related to negotiation, implementation and management of Deferred Prosecution Agreement (DPA), Corporate Integrity Agreement (CIA) and Independent Review Organization (IRO) services. We have acted in numerous roles within the healthcare sector. Our clients include the following in the healthcare field:
- Academic medical centers
- Acute care facilities
- Ambulatory surgery centers
- Ancillary service providers
- Billing & collections companies
- Critical-access hospitals
- Dental practices
- Durable medical equipment suppliers
- Federally qualified
- Health centers
- Health plans home health & hospice providers
- Outpatient clinics
- Pharmaceuticals
- Physician practices
- Rural health clinics
- Skilled nursing facilities
- Urgent care
Our Solution
Whether actively negotiating the terms of a DPA or CIA, or an agreement has already been executed, we can help. Our seasoned team of professionals can assess an organization's vulnerabilities and aid in the development and deployment of remediation strategies. We can also ensure the implementation of an effective compliance program meeting all the requirements of the Office of Inspector General's (OIGs) seven elements along with the added element of non-intimidation/non-harassment as required in certain states.
The Seven Fundamental Elements of an Effective Compliance Program
- Implementing written policies, procedures and standards of conduct.
- Designating a compliance officer and compliance committee.
- Conducting effective training and education.
- Developing effective lines of communication.
- Conducting internal monitoring and auditing.
- Enforcing standards through well-publicized disciplinary guidelines.
- Responding promptly to detected offenses and undertaking corrective action.
We have the ability to test an organization's readiness for their designated reviews
Federal sentencing guidelines reinforce the need for an effective compliance program. A key element of which is driven by the organization's ability to demonstrate an auditing and monitoring program constructed in a manner which continually assesses, identifies and addresses risk areas specific to the healthcare entity's strategy and mission. Upon execution of a DPA or CIA, an organization will have heightened sensitivity to ensure they continue to meet the terms of these agreements. We can provide services as a "mock IRO," testing an organization's readiness for their designated reviews.
Independent & Objective
As an IRO, our healthcare team has been recognized as an authority on independent and objective review of claims, systems, focus arrangements, transactions and marketing practices. We have assisted numerous clients to successfully navigate the terms of their CIA. Our highly specialized professionals are experienced in revenue cycle, compliance and internal audit with qualifications including credentials in:
- Certified Healthcare Internal Audit Professional (CHIAP)
- Certified in Healthcare Compliance (CHC)
- Certified Internal Auditor (CIA)
- Certified Information Systems Auditor (CISA)
- Registered Nurse (RN)
- Certified Professional Coder (CPC)
- Certified Coding Specialist (CCS)
- Certified Fraud Examiner (CFE)
- Certified Public Accountant (CPA)
We offer unsurpassed knowledge of government national and local coverage determinations and claims processing regulations. Our unique client approach, rooted in partnership, results in experiential learning and understanding for all participants of both the process and the rigid requirements set forth under each agreement.
Our findings and recommendations have successfully stood the rigorous tests of the Office of Inspector General and the Department of Health and Human Services. We employ methodologies backed by the highest industry standards, including those sanctioned by the Institute of Internal Auditors and the U.S. Government Accountability Office and including industry standards in statistical sampling practices. Clients benefit from our ability to effectively communicate logic used in arriving at our resulting findings and the importance of the observations noted, with additional emphasis of the business risk and the impact non-compliance may have on the organization.