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Corporate Integrity Agreements – Lessons Learned: Negotiating Terms, Selecting An IRO, Meeting Obligations

Webinar Date/Time: April 16, 2015 at 1:00–2:00 p.m. EST

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There are over 300 active Corporate Integrity Agreements (CIAs) between the Department of Health and Human Services Office of Inspector General (OIG) and health care organizations. New CIAs are being added on a regular basis. Many organizations focusing on litigation and settlement with the U.S. Department of Justice (DOJ) fail to look ahead to and are ill prepared for the prospects of a second settlement with the OIG. It is important that providers, health plans, and practitioners, as well as their legal counsel, understand the scope and the details of the entire settlement process. Failure to properly define and clarify all issues and terms in a CIA before signing can lead to added expense and effort in meeting CIA obligations. Properly selecting the Independent Review Organization (IRO) is extremely important for a health care organization that has entered into a CIA with the OIG. This engagement can be costly if not done effectively. An overlooked issue with a CIA is the health care organization not understanding entirely what is required to comply and burdening unprepared staff who were not part of the negotiation process, with new unplanned responsibilities. This webinar will focus on the entire CIA process from negotiation through life with the obligations of a settlement agreement and CIA.

Hear from the experts who will address the entire process: (a) how cases pass from the DOJ to the OIG; (b) the OIG process followed for CIA development; (c) duties and selection of IROs; (d) role of the OIG Monitor; and (e) tips on how to best manage meeting CIA obligations.


  • Understand Settlement versus CIA
  • Learn about how DOJ turns case over to OIG
  • Describe role of OIG attorney developing the CIA
  • Relate OIG attorney versus OIG monitor
  • Discuss best practices in negotiating a CIA
  • Relate common terms and conditions in CIAs
  • Outline Independent Review Organization (IRO) role
  • Outline Compliance Monitor / Compliance Expert role
  • Provide tips on how to select an IRO
  • Go over how to prepare for the IRO reviews
  • Learn how to manage IRO as part of CIA
  • What to Expect when you are Expecting (the IRO)
  • Provide tips on how to live (and still thrive) under a CIA


Cornelia M. Dorfschmid, PhD, is Executive Vice President of Strategic Management Services, LLC. (SMS), a Virginia-based company that provides consultative services to health care providers on government health programs, and specializing in developing, implementing and measuring effective compliance programs for health businesses. Dr. Dorfschmid is a leading national expert on preparing for and advising on corporate integrity obligations of CIAs, as well as being the IRO. Under her direction, SMS ranks among the top four firms selected to be an IRO.

Thomas Herrmann, JD, is Senior Vice President for SMS. Prior to joining SMS, he was an Administrative Appeals Judge with the Medicare Appeals Council. He also served over 20 years in the Office of Counsel to the OIG where he negotiated and managed CIAs. With SMS, he has coordinated more than a dozen IRO engagements on behalf of SMS. He is frequently consulted by law firms and clients negotiating terms and conditions for CIAs.

Both speakers provide both the external consultative or enforcement perspective but also the inside view due to their experience as acting compliance officers.