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What Does the Contract Say? . Conflict of Interest Requirements10th SOW Contracts contain Section H.11New Contract Term incorporated in Section H.24Necessary due to existing COIs caused by RECs, Beacons, HIEs, and otheroutside business arrangements. What Does the Contract Say?. Incorporates
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1. 10th SOW QIO ContractsQuality Net Contracting SessionDecember 13, 2011
Presenter: Naomi A. Haney-Ceresa
Contracting Officer
Subject: Conflict of Interest Section H.24 and Deliverable F.2.H.8
2. What Does the Contract Say? Conflict of Interest Requirements
10th SOW Contracts contain Section H.11
New Contract Term incorporated in Section H.24
Necessary due to existing COIs caused by RECs, Beacons, HIEs, and other
outside business arrangements
3. What Does the Contract Say? Incorporates QIO Mitigation Plans
Required Quarterly (Monthly) Reporting of Conflicted Case Review Activities
Format is included in contract term
Reporting required for ALL conflicted case reviews
4. Who Does it Apply to? ALL 10th SOW QIO contracts
Intent is to ensure all COIs (existing, future) are/will be sufficiently
avoided, neutralized or mitigated to remove/reduce risk
COIs involving impaired objectivity; bias ground rules or unfair competitive advantage
Primarily Impaired Objectivity
5. Is There a Corresponding Deliverable?
Yes, Section F.2, Deliverable # F.2.H.8
Description: Quarterly Referral Report (some are Monthly)
Who Receives: CS, COTR, COI Specialist
6. Is There a Corresponding Deliverable? Due: 10 days after end of Quarter (or Month)
Format: Hardcopy to CS with Electronic OR Hardcopy to COR, COI Specialist
Most Frequent Question: “If I have no conflicted reviews, do I still need to submit a report? “YES”
7. How Will CMS Enforce? Onsite compliance audits “Are you following contract’s Mitigation Plan?”
Review Quarterly (Monthly) Reports to assess increase/decrease in risk
Could affect: Past Performance; Issue PIP; and/or Termination
8. How Will CMS Enforce? EXTREMELY IMPORTANT—Cannot change without contract modification
Read contract transmittal letter for details!
9. What Happens During Contract Performance? Section H.24 may require updating
Depends on each QIOs book of business and the development of new COIs
What do we mean by new? New relationship/grant/agreement or contract that creates a COI
10. What Happens During Contract Performance?
Contract term (H.24) will be modified to incorporate new mitigation plans during contract performance
Will be required to include reporting of conflicted case referrals for mitigation plans that are incorporated during performance
11. How is the Clause Changed? Formal Contract Modification
Section H.24, First paragraph of the clause will be revised to include the date and subject of mitigation plans that are added during performance
Section F.2.H.8 will not be modified but reporting is required