Healthcare Monitorship Services

Healthcare monitorships can require independent oversight of compliance obligations, financial conditions, transaction commitments, and reporting requirements. PYA serves as an independent monitor and Independent Review Organization (IRO) for healthcare organizations operating under Corporate Integrity Agreements (CIAs), Deferred Prosecution Agreements (DPAs), and regulator-imposed post-transaction conditions related to financial stability and the public interest.

Healthcare has been a primary focus of PYA for more than 40 years. PYA’s monitorship work draws on in-house compliance, valuation, finance, reimbursement, coding, and technology risk professionals, allowing engagement teams to address requirements through a coordinated multidisciplinary approach.

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PYA’s Monitorship Services

Corporate Integrity Agreement (CIA) & Deferred Prosecution Agreement (DPA) Monitorships

PYA serves as an Independent Review Organization (IRO) under OIG Corporate Integrity Agreements (CIAs) and as an Independent Monitor under DOJ Deferred Prosecution Agreements (DPAs), providing oversight for healthcare organizations resolving fraud and abuse matters under the False Claims Act, Anti-Kickback Statute, or Stark Law. Depending on the engagement mandate, PYA’s work may include claims-data review, testing of billing and coding accuracy, review of compliance hotline operations, and evaluation of compliance program design and effectiveness in matters involving HHS-OIG, DOJ, and State Medicaid Fraud Control Units (MFCUs).

Independent Monitor for Healthcare Transactions & Conversions

PYA serves as an independent transaction monitor for state agencies, regulators, and county commissions overseeing healthcare transactions and regulator-imposed post-transaction conditions. These engagements may address financial stability, community benefit, implementation of transaction commitments, and reporting to public-sector stakeholders.

Representative Public-Sector Monitorship Experience

PYA has served as an independent monitor for the Northwell Health and Nuvance Health transaction in Connecticut and as a post-transaction monitor for the Banner Health/Wyoming Medical Center transaction in Wyoming. Beyond those two engagements, PYA has acted as an independent monitor and Independent Review Organization (IRO) on healthcare compliance and transaction matters involving regulatory bodies in Rhode Island, Georgia, Kentucky, North Carolina, South Carolina, and Florida. The work centers on independent oversight of compliance obligations and transaction commitments, with reporting to the regulators, courts, and government agencies involved.

Healthcare Expertise for Complex Monitorship Engagements

Healthcare Monitorship Services: Financial and Operational Oversight

Healthcare Regulatory and Financial Experience

Monitorship work can require detailed knowledge of reimbursement, physician compensation, payer contracting, healthcare regulatory matters, financial performance, and data privacy and cybersecurity. PYA’s healthcare-focused professionals bring experience across these disciplines to help engagement teams evaluate requirements in the context of healthcare operations.

Multidisciplinary Expertise Under One Firm

Monitorship engagements may require compliance, valuation, coding, claims analytics, financial analysis, reimbursement, and technology or data privacy expertise within the same scope. PYA houses these disciplines internally, helping coordinate the work across one engagement team and reducing the need to rely on multiple outside firms.

Independence and Objective Reporting

PYA is privately owned and has no third-party investors. Monitorship work is performed according to the requirements of the applicable CIA, DPA, court order, or regulatory agreement, with findings reported on the schedule and in the format required by the engagement.

How PYA Structures Monitorship Engagements

Each monitorship begins with the scope defined by the applicable CIA, DPA, court order, or regulatory agreement. PYA assigns a dedicated team to the engagement, coordinates with the organization’s legal, compliance, finance, and other relevant functions, and reports findings according to the required schedule and format. The engagement approach is designed to meet the monitoring mandate while limiting unnecessary disruption to day-to-day operations.

Healthcare Monitorship Frequently Asked Questions

What role does PYA serve in a healthcare monitorship?

PYA serves as an independent monitor and Independent Review Organization (IRO), providing objective oversight under the requirements of a Corporate Integrity Agreement, Deferred Prosecution Agreement, court order, or regulatory agreement. Depending on the engagement mandate, PYA’s work may include compliance review, claims testing, financial analysis, transaction oversight, and reporting to regulators, courts, or other public-sector stakeholders.

What can PYA review as an Independent Review Organization under a Corporate Integrity Agreement?

Depending on the CIA and engagement mandate, PYA’s work may include claims-data review, billing and coding assessments, and evaluation of compliance program design and effectiveness.

How does PYA’s transaction and conversion monitoring differ from its CIA or DPA monitoring work?

Transaction and conversion monitoring focuses on the conditions and commitments attached to a healthcare transaction, which may include financial stability, community benefit, and required reporting. CIA or DPA monitoring is structured around the compliance and oversight requirements established in the applicable agreement.

How is a PYA monitorship engagement structured?

The scope is defined by the applicable CIA, DPA, court order, regulatory agreement, or transaction condition. PYA assigns a dedicated team, coordinates with the relevant organizational functions, and reports findings according to the schedule and format required by the engagement.

What expertise does PYA bring to a healthcare monitorship engagement?

A healthcare monitorship engagement may require compliance, valuation, coding, claims analytics, financial analysis, reimbursement, technology risk, and data privacy expertise. PYA houses these disciplines internally and assigns engagement teams based on the specific monitoring mandate and the issues under review.

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The PYA Difference

Over our 40-year history, PYA has consistently delivered high-value advisory services to our national client base. Our team is deployed to develop custom plans using proven approaches and work plans.

Independence

Private ownership means we answer only to our clients, not to third-party investors, giving us the freedom to be thorough and thoughtful in our work. We judge our success by our clients’ success.

Relationships

We value long-term relationships and work hard to maintain them. Our commitment to client relationships and the communities we serve remains constant.