1、1 中文 3325 字 本科毕业 论文 （ 设计 ） 外 文 翻 译 外文题目 Independent Review Organizations Must Meet GAO Yellow Book Standards 外文出处 Journal of Health Care Compliance,2010(2):27-32 外文 作者 Herrmann Thomas E 2 原文 ： Independent Review Organizations Must Meet GAO “Yellow Book” Standards BACKGROUND On July 30, 2001, the OIG
2、, in conjunction with the Health Care Compliance Association (HCCA), cosponsored a Government Industry Roundtable to discuss “issues surrounding the implementation and maintenance of effective compliance programs.” Specifically addressed in the discussion was the OIGs requirement, in the context of
3、health care fraud and abuse settlements, that an IRO be retained by a health care entity to perform annual billing, systems, and/or other compliance reviews. Participants recognized that: The OIG requires IROs because the OIG does not have the resources to conduct the level of review necessary to de
4、termine if a provider is meeting the requirements of the CIA as well as other Federal health care program requirements. Additionally, a review by an independent entity provides the OIG with assurances that a providers compliance program and billing systems are objectively reviewed. Roundtable partic
5、ipants referenced a number of advantages associated with using an IRO. “IROs provide a broad industry perspective and expertise, are independent, help identify system weaknesses, make helpful recommendations, and their reviews serve as a useful benchmark for future reviews conducted by the provider.
6、” OIG REQUIREMENTS FOR IRO INDEPENDENCE The obligations for an audit/review organization, such as an IRO, to meet “independence” standards are referenced in GAGAS as set forth by the GAO in its “Yellow Book.” These standards are applicable to financial audits, typically performed by certified public
7、 accountants (CPAs), attestation engagements, and performance audits, which may be undertaken by professionals such as consultants and lawyers. The great majority of CIAs does not mandate financial audits but are rather focused on performance audits, i.e., those involving claims, systems, or arrange
8、ments with referral sources that may implicate the anti-kickback statute and 3 Stark law. From the perspective of the OIG, it is essential that an IRO conduct its reviews with both independence and objectivity. A standard requirement in an OIG CIA is that “the IRO must perform its review in a profes
9、sionally independent and objective fashion, as appropriate to the nature of the engagement, taking into account any other business relationships or engagements” Typically, the IRO is obligated to provide a certification regarding its professional independence and objectivity. Further, the usual CIA
10、specifies that “in the event OIG has reason to believe that the IROis not independent and objective, the OIG may, at its sole discretion, require” the engagement of a new IRO. The OIG has stated that an IRO should follow “the standards for auditor independence set forth in the General Accounting Off
11、ice (GAO), Government Auditing Standards (2003 Revision).” The OIG has indicated that, under these standards, “CIA reviews would be considered performance audits and IROs would be subject to the independence standards set forth in the Yellow Book that relate to performance audits.” In referencing th
12、e GAO Yellow Books applicability to IRO independence, the OIG has further noted: When assessing independence, the two overarching principles that must be considered are that: audit organizations should not perform management functions or make management decisions； and audit organizations should not
13、audit their own work or provide non-audit services in situations where the non-audit services are signify- cant/material to the subject matter of the audits. THE GAO YELLOW BOOK STANDARDS The GAO Yellow Book, first issued by the Comptroller General of the United States in 1972, is intended to: Addre
14、ss the unique requirements of governmental entities； Establish general standards for both governmental and nongovernmental auditors performing audits in accordance with GAGAS； Supplement field work and reporting standards of the American Institute of certified Public Accountants (AICPA) Auditing Standards Board；
