The Health and Human Services Office of Inspector General has released new guidance on an important topic, Independent Review Organizations within Corporate Integrity Agreements. This article goes through the recent guidance and explains the requirements of objectivity and independence. The conclusion also provides several practical takeaways from the new guidelines.
Since the Sarbanes-Oxley Act and the greater focus on auditor independence that followed, Independent Review Organizations (“IROs”) have been a staple provision in the Health and Human Services (“HHS”) Office of Inspector General’s (“OIG”) Corporate Integrity Agreements (“CIAs”). With CIAs on the rise, in August 2016, the OIG issued new guidance on IRO independence and objectivity. The new guidance was prompted by concerns expressed by both individuals and entities, regarding circumstances that may affect the independence of an IRO that performs CIA reviews.
Read the full article in the January 2017 issue of Life Science Compliance Update.