http://ashmann.uk/2009/10/ AIs require practitioners to implement certain elements of the compliance program, appoint an independent third party to conduct quarterly audits, and submit an initial annual report. Impact assessments shall also contain provisions on infringements and non-compliance under which the IGO may impose sanctions for non-compliance with the conditions of the impact assessment. Since the damage examination carried out by the IRO involves verification of the medical necessity of the items and services invoiced, the IRO retained by the practitioner must be able to assign licensed nurses, doctors or other health professionals with the necessary training, training and expertise to meet the medical necessity. IRO staff must also have expertise in Medicare and Medicaid program requirements, which apply to exam rights. IRO personnel conducting the coding test must have a nationally recognized coding certification. The IRO must also be able to certify that it can carry out an independent and objective control of the damage. For AI purposes, “independence” and “objectivity” are defined in the government auditing standards published by the U.S. Government Accountability Office (the Yellow Book). [4] If the practitioner is considering an external billing entity, certain additional requirements apply. For example, the OIG practitioner must certify that he or she has no ownership or control of the external billing entity and is not employed by the company or is a consultant for the company.
In addition, the external billing entity must obtain annual certifications with regard to the training of its employees and that it has guidelines and a screening process to prevent the employment of excluded persons. Independent audit bodies may be a consulting, accounting or law firm. The key to determining the type of organization to select as an IRO depends on the scope of work contained in the Corporate Integrity Agreement (CIA), which requires an external party to verify and monitor compliance with the terms of the agreement. Most ASAs include reviewing agreements with referral sources, verifying complaints, and/or marketing practices. The selected IRO should have the necessary expertise to carry out the work.