Does the OIG endorse or assist a provider in choosing a compliance vendor or IRO?
The OIG does not endorse any proprietary products. Moreover, the OIG will not indicate which IROs it believes are most qualified. It is up to the provider to determine the most appropriate CPA firm, law firm, or consultant to engage as its IRO. If, following the annual review, the OIG has concerns about the quality of the review, or the independence of the IRO based on the totality of the circumstances, the OIG may make those concerns known to the provider.
The OIG does not endorse any proprietary products. Moreover, the OIG will not indicate which IROs it believes are most qualified. It is up to the provider to determine the most appropriate CPA firm, law firm, or consultant to engage as its IRO. If, following the annual review, the OIG has concerns about the quality of the review, or the independence of the IRO based on the totality of the circumstances, the OIG may make those concerns known to the provider. 4. Material Violations Question: The OIG’s corporate integrity agreements (CIA) require that the provider report to the OIG all “material violations.” Providers often ask the OIG whether a certain percentage or dollar threshold is appropriate for determining if a violation is “material.” Does the OIG believe such percentage or numeric thresholds are appropriate for determining if there was a “material violation?” Answer: No. The OIG defines the term “material violation” in its CIAs by noting that it could be (i) a substantial overpa
