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Don Forgione Centers for Medicare & Medicaid Services

Joint Session: CMS/ESRD Network Program Updates, Contracts, Conflict of Interest, & Demonstration Projects Organizational Conflict of Interest (OCI) Brief Overview. Don Forgione Centers for Medicare & Medicaid Services. 2007 CMS/ESRD Networks’ Annual Meeting February 26, 2007. The Causes.

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Don Forgione Centers for Medicare & Medicaid Services

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  1. Joint Session: CMS/ESRD Network Program Updates, Contracts, Conflict of Interest, & Demonstration ProjectsOrganizational Conflict of Interest (OCI)Brief Overview Don Forgione Centers for Medicare & Medicaid Services 2007 CMS/ESRD Networks’ Annual Meeting February 26, 2007

  2. The Causes • An OCI may be created when entering into a contract or agreement, or accepting a grant, that has the potential to affect your ability to carry out the requirements of your contract with CMS.

  3. A New Environment • The 8th SOW contract encourages the QIOs to partner, similar to the network contract encouraging you to seek partners and new resources. • Since then, the level of program scrutiny has greatly increased. • We must interpret the contract language more stringently now.

  4. Top Ten OCI Issues • The contract agreement or grant is for work similar to the federal contract work • It gives the appearance that one vendor is being favored over others • It is a related party transaction • It results in an inadvertent endorsement • It appears to result from use of your position to give you an unfair advantage

  5. Top Ten (cont.) • The co sponsor of an event is a funds only contributor • The appearance of coercion in entering into a relationship • The appearance of bribery in entering into a relationship • Registration fees • The social component of an event

  6. Prior Review and Approval • On May 5, 2006, we issued an instruction to the QIOs to seek prior approval for all outside contracts and subcontracts. • Due to the current environment, we must require that henceforth the Networks also seek prior approval for all outside contracts and subcontracts. • We are committed to responding within 30 days

  7. OCI Review Process • Any request for an OCI review should be sent to the Project Officer • Please include all relevant information • The PO will send the package, with a recommendation, to the contract specialist and to the OCI specialist • The decision will be issued by the Contract Officer

  8. Questions?

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