CIA & IRO SERVICES
When the OIG is involved, you need the right partner in your corner.
A Corporate Integrity Agreement (CIA) is one of the most serious compliance obligations a healthcare organization can face. KHC provides independent review organization (IRO) expertise as well as comprehensive readiness support, so your organization meets every obligation, on time, without surprises.

Time is a factor with CIAs.
A CIA is a binding legal obligation entered into with the Office of the Inspector General (OIG) of the U.S. Department of Health and Human Services typically following a government investigation, voluntary disclosure, or settlement. CIAs impose specific deadlines and compliance requirements that the client must meet and may require independent assistance.
Corporate Integrity Agreement Requirements
KHC provides a variety of consulting services for clients who are currently under a CIA. We can serve as your IRO, conducting the independent, objective reviews the agreement requires. KHC also offers services to assist you in developing the internal documentation, and training your organization must have in place.
IRO Preparation
The first year of the CIA, which is prior to the IRO review, provides an opportunity to ensure all the necessary requirements of the CIA are in place.
KHC facilitates comprehensive preparation for the IRO visit, conducting pre-review assessments to identify gaps, areas of weakness, and issues your organization will be required to meet. We work with your internal team to ensure documents, policies and procedures are in order before the review begins.
Compliance Plan Development and Support
A CIA may reveal that an organization's existing compliance plan needs additional development or that a newly recruited Compliance Officer needs experienced guidance to navigate the requirements. KHC provides compliance plan development to meet the seven core elements for an effective compliance plan.
KHC can also assist with audit plans, work plans, policies and procedures, and corrective action plans. We also provide mentorship for newly recruited Compliance Officers, supporting their professional development and ensuring they have the knowledge and tools to sustain the compliance plan after KHC's engagement concludes.
We don't just consult on healthcare. We've worked inside it.
Corporate Integrity Agreements impose strict reporting deadlines. If your organization has recently entered into a CIA, early engagement with KHC is critical. KHC can mobilize quickly.
Our team includes:
Compliance Officers • Certified Coders • Regulatory Administrators • Billing & Reimbursement Specialists • Nurses & Clinical Professionals • CPAs • Physicians
CIA & IRO Services
- Function as IRO for both claims and arrangement reviews
- Assist with required implementation reports
- Provide IRO Readiness including mock audits
- Compliance plan development including audit plans, work plans, and corrective action plans
- Client education and training on fraud, abuse, and regulatory compliance
- Mentorship of newly recruited Compliance Officers
Has your organization received a government notice or entered into a CIA?
A KHC consultant will review your CIA obligations, clarify what your organization needs to have in place, and outline what an IRO engagement would look like. A CIA moves on the OIG's timeline, not yours. Let's talk now.

