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10th SOW QIO Contracts Quality Net Contracting Session December 13, 2011

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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10th SOW QIO Contracts Quality Net Contracting Session December 13, 2011

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    1. 10th SOW QIO Contracts Quality Net Contracting Session December 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 contracts 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 IMPORTANTCannot 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

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