Your settlement with the government requires an Independent Review Organization: Now what?

Bert F. Lacativo (blacativo@glassratner.com) is a former FBI Special Agent and a Senior Managing Director and National Head of Investigations for GlassRatner in Dallas, TX. He is currently leading an IRO engagement. Adam Lampert (alampert@glassratner.com) is an associate for GlassRatner in Dallas, TX.

The Health and Human Services Office of Inspector General (OIG) has accused your company of improprieties, and after careful negotiation by your counsel, there is an agreement to settle under the auspices of a Corporate Integrity Agreement (CIA). Now that your company has entered into a CIA, it can get back to business as usual, right? Not so fast. As part of the CIA, the OIG has required that the company engage (at its expense) an Independent Review Organization (IRO). Let’s explore what an IRO is and what this might mean for your company.

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