This chapter describes the legal context created to protect federal health programs from fraud and abuse, and the creation of coercive measures and penalties for violations of the law. It also describes the essential elements of the transaction agreements and the requirements of the CIA, including the role of independent monitoring bodies (OVOS) that ensure compliance with the terms of the agreement. Although cumbersome and generally cumbersome and costly to complete, OIG Corporate Integrity Agreements leads organizations to implement an effective public health compliance program that ultimately leads to proper billing practices. These include submitting specific and comprehensive payment requests to federal health programs, appropriate agreements with physicians, and improving the quality of care provided to program recipients. Since the OIG Corporate Integrity Agreement is a contractual agreement between the OIG and a health organization requiring the organization to meet a defined set of compliance obligations, it is important to meet all conditions. Violations of the OIG Corporate Integrity Agreement and non-compliance with obligations under the agreement may result in severe penalties, including the possible exclusion of participation in federal public health programs. It is important to note that the OIG does not select the IRO. In addition, they do not give advice on how to select one, nor support the organizations that are supposed to be the IRO. It is entirely up to the entity or supplier to determine the most appropriate organization that should be engaged as an IRO. However, the OIG reserves the right to approve or reject the decision of the companies or IRO supplier within 30 days of the OIG`s written notification of the identity of the IRO. Typically, companies such as consultants, accountants (CPAs) or law firms are responsible for carrying out these tasks.
While most health organizations that have transaction agreements with the DOJ have spent a great deal of time, effort and money reaching an agreement, they have given little thought to the process of selecting an IRO that needed to be approved by the IG. In many cases, this has led to further problems and aggravations.