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. The following discussion is intended to help any organization facing the prospects of a CIA think about how to find and select a qualified IRO. On August 7, 2012, the HHS Office of Inspector General (OIG) held a “roundtable” with representatives of health companies that had reached an agreement with the OIG on Business Integrity (CIA). The focus on Compliance – The Next Generation of Corporate Integrity Agreements roundtable should be provided with information on compliance “best practices” and efforts to ensure law-adity and effective operation, in accordance with CIA conditions. The discussion focused on various topics, including: In recent years, the Office of Inspector General (OIG) has “adapted” the Business Integrity Agreements (CIA) to target and prevent the faults that have served as the basis for billing an organization or individual with the federal government.

Some of these specialized ICAs are highlighted below: Under the CIA between HHS OIG and Exactch, Inc., effective December 7, 2010, all new consulting and renewal agreements must require a consultant to disclose the financial agreement with the company`s patients and affiliated hospitals.