What Makes a Great IRO? – Sam Cunningham

Throughout January, I’ve often heard from clients, contractors, and specialists who all emphasized the question/concern: ‘what makes a great IRO?’

I never thought about the quality of an IRO, assuming all are qualified. With our team having never had an IRO or overpayment analysis report rejected by the OIG or MACs, I assumed all clients were completely satisfied with their IRO’s work.

Recently, I have heard from clients of IROs going over budget, late reporting, not collaborating with the organization regarding potential variances, and not clearly articulating its independence to the OIG. For organizations and compliance officers working through their first CIA, these snags from your IRO are not acceptable. Here are some thoughts on what makes for a great client experience and what you should expect from your IRO firm.

Key Factors to a Great IRO

In addition to great collaboration, customer service, and proactive explanation of identified issues (the basics I would expect for any project), here are my specifics factors for IRO success:

1. Get your population correct. Run data integrity checks. Confirm that what you are seeing in the data should be there, but also look to see what is absent (e.g., is your filter inadvertently excluding a date, provider, or payer?). The most common mistake is running a population on just date of service versus paid date. Additionally, if it makes sense for your organization to exclude something, touch base with your Monitor and discuss.

2. Anticipate any extension requests in advance. There are occasions where the time frame to report is just too tight to conduct all field work by the reporting deadline. Both the entity and the IRO should discuss these potential timing issues, and clearly articulate a request to the Monitor.

3. Have straightforward clean reporting. IRO reports can vary from the minimalistic to the overly complicated where it is extremely difficult to follow the findings. Minimalistic runs the risk of omitting testing elements and overly complicate runs the risk of being returned with pointed questions from the Monitor.

4. Schedule and conduct collaborative variance discussions. Variance discussions will confirm the findings, but will also allow the organization to understand the findings. When it is time for the draft report, the findings should not come as a surprise. At the same time, the IRO should focus on independence and objectivity while still keeping an open mind of reversing a finding with additional documentation.

5. Write report recommendations that are squarely tied to a finding, reasonable, and applicable to the organization. The organization should be addressing each finding and recommendation, and credit should be given to where the organization is actively remediating.

Each CIA is unique with nuanced differences. If you read enough of these CIAs you will pick up on some of these nuances. In short, the above list could be summarized into one word “communication.” Organizations, IROs and the OIG should be in communication and not afraid of asking for clarification or voicing a concern.

SunHawk has served as the IRO, Board Advisor, and Overpayment Analyst for numerous clients. Our professionals have submitted over 70 IRO and related reports. If you are in need of additional help as either the IRO or IRO readiness, please feel free to reach out to me at [email protected] and please download our free CIA summary reports here.