HHSM-500-2014-RFP-QINNCC_Amendment_6_Summary_of_Changes.docx

DEPARTMENT OF HEALTH & HUMAN SERVICES

Centers for Medicare & Medicaid Services 7500 Security Boulevard, Mail Stop B3-30-03 Baltimore, Maryland 21244-1850

Request for Proposal Number HHSM-500-2014-RFP-QINNCC Amendment Number 6

SUMMARY OF CHANGES

June 24, 2014

Section L

Section L.14.E Tab A: Conflict of Interest-Summary List of Contracts is revised as follows with changes in bold:

The Offeror shall disclose all healthcare related contracts, both government (local, state and federal) and non-government currently held with CMS, other government health care agencies, or with non-government entities, as a Prime and/or as a Subcontractor, for itself, its parent company, subsidiaries or other affiliated entities. For each contract, Offerors must provide the following:

1. Contract Amount

2. Short Description of Work or Service Performed

3. For each contract listed under this category, the Offeror or Contractor shall provide a statement to the effect whether or not the identified entity or the work presents an actual, potential or apparent organizational conflict of interest (OCI) versus the work to be performed under this contract for each OCI type:

a) Unequal Access to Information (see below),

b) Biased Ground Rules (see below), and/or

c) Impaired Objectivity (see below).

If the determination is that there is no OCI, then a brief explanation of the basis for that determination must be provided for each contract. If an actual, potential or apparent OCI is identified, then the Offeror shall submit a mitigation plan to resolve the conflict.

1)

Sample Disclosure Format for TAB A (See also Section J, Attachment J-20 (Organizational Conflict of Interest Sample Disclosure Format Template) checklist.

Section L.14.E Tab B: Conflict of Interest – Program Information Detail revised as follows with the changes in bold:

1. Conflict of Interest (Organizational) – Information and Detail

Therefore, the Offeror shall submit the disclosure of information contained in Section H.11.D.7 (a) though (i) Conflict of Interest Certificate, in order to be considered for award.

Examples of methods an Offeror may use to mitigate conflicts of interest, including conflicts created as a result of the financial relationships of officers, directors and managers within the organization, are provided below. The examples are not intended to be an exhaustive list of all the possible methods to mitigate conflicts of interest. Further, the Contracting Officer is not obligated to approve a mitigation method that uses one or more of these examples. An Offeror’s method of mitigating conflicts of interest will be evaluated on a case-by-case basis during the proposal evaluation process.

· Divestiture of the financial relationship the organization or individual has in another organization;

· If shared responsibilities create the conflict, a plan, included in the Conflicts of Interest Certificate, to separate or create firewalls between lines of business and management or critical staff from work on the contract; or

· If the conflict exists because of an individual’s indirect interest, recusal of the individual on decisions related to the indirect interest, divestiture of the interest or removal of the individual from the work under the contract.

2. Conflicts of Interest (Personal) – Information and Detail

In order to be eligible for award of a contract, the Government must ensure that an Offeror’s individual employees are free, to the greatest extent possible, of all personal conflicts of interest (PCI).

For the purposes of PCI disclosures, the Offeror’s Compliance Officer or designee shall review the Individual PCI Certifications for managers, key personnel and Board members. The Compliance Officer or designee may not review his/her own PCI Certification; this must be delegated to a separate manager/individual of the entity.

PCI includes reviewing the information of the Immediate Family. “Immediate Family” means yourself/your Spouse/Domestic Partner and/or any Dependent of the respondent or a dependent child which includes a son, daughter, stepson or stepdaughter who is either unmarried and under age 21 and living in the respondent’s house, or considered dependent under the U.S. tax code. An individual need not inquire of each family member regarding these items. Only disclose those things of which an individual is aware. If and individual later becomes aware of a financial matter that may cause a PCI, that individual must submit a revised PCI verification. Please provide the following information for PCI disclosures:

· A list of yours and your Extended Family’s current or known future employment, contracts or arrangements, regardless of size, held with any insurance organization or subcontractor of an insurance organization to be reviewed under the contract, including, the type of work performed, and the period of performance. Note; Do not include personal insurance policies.

· A list of yours and your Extended Family’s current or known future employment, contracts or arrangements, regardless of size, held with any providers or suppliers furnishing health services for which payment may be made under the Medicare program, including the type of work performed, and the period of performance.

· A list of all of yours and your Immediate Family’s financial interests in the following entities, including the percentage of ownership in each entity that might be reviewed under the contract: health facility, health payer organization, health plan or association, educational institution that owns or is affiliated with a medical school and/or health facility, pharmaceutical company, laboratory, DME supplier, medical transport service, health information technology (HIT, aka EHR) vendor or other provider or supplier of health services.

· A list of all of yours and your Immediate Family’s investments in medical companies, healthcare or medical sector funds and other healthcare or medical sector investment vehicles including, but not limited to, corporations, partnerships, joint ventures and other business entities (dollar amounts not required).

· A list of other Board of Director and/or equivalent governing body (e.g., board of trustees; board of managers; etc.) position(s) held by you and your Immediate Family and the length of time in the position(s).

These PCI Certifications may be marked “Confidential” and “Proprietary Business Information.”

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