What is the OIGs position on determining the independence of an “independent review organization” for purposes of a CIA review?
A determination of whether a particular entity, such as a CPA firm, is “independent” for purposes of serving as an independent review organization (IRO) is fact specific. At the time of contracting with an IRO, the provider will be in a better position than the OIG to assess the independence of a potential IRO. However, the OIG will consider the IRO’s independence when assessing the annual reports and supporting materials submitted by the provider. Factors that raise questions regarding an entity’s independence are similar to those cited in American Institute of Certified Public Accountants’ Code of Conduct and SEC rulings.
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