In subsequent years, the IRO will conduct annual transaction testing to select a sample of transactions and request supporting documents. One of the most important steps for the company during this process is to determine the type of documentation it needs to provide. It is not always necessary to provide all documents related to the transaction, but it is important to agree with IRO on the nature and number of documents that would meet the requirements of the transactional test. The company needs to organize the documents as much as possible in advance, which makes it easier for the IRO to control and ultimately reduces the associated issues and costs. Many companies choose to perform their own transaction sample tests in order to anticipate the results of IRO tests. It was found that CIAs generally require the vendor to implement a compliance program that complies with the compliance policies published by the OIG. 2 As healthcare industry awareness and commitment to compliance has increased over the past decade, a large number of healthcare providers have voluntarily implemented compliance programs without direct government intervention. Despite the independent implementation of compliance programs, several health care providers have negotiated with the government to respond to allegations that they have violated federal fraud and abuse laws, such as false Claims Act3, Civil Monetary Penalties Law4 or the Fraud Civil Remedies Act5 program. instead of a formal CIA as part of the release of the executing authority from its power of exclusion. In recent years, the Office of Inspector General (OIG) has ”adapted” Enterprise Investment Agreements (CIAs) to target and prevent misconduct that served as the basis for an organization`s or individual`s agreement with the federal government. .