Conflicts of Interest Policies | Simon&Co., LLC https://mjsimonandcompany.com/issues/program-integrity/conflicts-of-interest-policies/ Experts in Health and Human Services Policy, Appropriations, & Budget Strategies Fri, 11 Oct 2024 21:26:14 +0000 en-US hourly 1 https://mjsimonandcompany.com/wp-content/uploads/cropped-Simon-Co-icon-32x32.png Conflicts of Interest Policies | Simon&Co., LLC https://mjsimonandcompany.com/issues/program-integrity/conflicts-of-interest-policies/ 32 32 GAO COI Sustained, Issues with Firewall Plans in Proposal https://mjsimonandcompany.com/program-integrity/conflicts-of-interest-policies/gao-coi-sustained-issues-with-firewall-plans-in-proposal/ Fri, 11 Oct 2024 21:26:13 +0000 https://mjsimonandcompany.com/?p=2314 In a recent protest decision (B-421792.2,B-421792.3, A Square Group), GAO determined that CMS did not consider the impact a proposed firewall would have on other bidder’s technical approach. The Request for Quotes sought a contractor to analyze activities in the Federally Facilitated Exchange (including reconciliation and validation of enrollment and payment data). Cogent People Inc., purposed a …

The post GAO COI Sustained, Issues with Firewall Plans in Proposal appeared first on Simon&Co., LLC.

]]> In a recent protest decision (B-421792.2,B-421792.3, A Square Group), GAO determined that CMS did not consider the impact a proposed firewall would have on other bidder’s technical approach. The Request for Quotes sought a contractor to analyze activities in the Federally Facilitated Exchange (including reconciliation and validation of enrollment and payment data). Cogent People Inc., purposed a subcontractor that supports the FFE under a separate contract, but with a firewall between the work of this contract and the payments data generated by the subcontractor in its FFE contract.  

In its decision, the GAO found fault in CMS evaluation of how Cogent would establish and handle the firewall. For instance, the GAO found Cogent did not show the staff separation in its organizational chart and proposed the subcontractor’s staff to perform aspects of the work subject to Organizational Conflicts of Interest. GAO also found CMS failed to evaluate the effect of the fire on the proposed technical approach. GAO recommended CMS reassesses its OCI analysis. This decision could mean that CMS contracting officers will be more stringent in their OCI and firewall reviews in the future.  

The post GAO COI Sustained, Issues with Firewall Plans in Proposal appeared first on Simon&Co., LLC.

]]> Independent Assessment Of Medicaid Beneficiaries Receiving HCBS https://mjsimonandcompany.com/program-integrity/conflicts-of-interest-policies/independent-assessment-of-medicaid-beneficiaries-receiving-hcbs/ Thu, 12 Oct 2023 16:09:14 +0000 https://mjsimonandcompany.com/dev/?p=1904 Read the full assessment here.

The post Independent Assessment Of Medicaid Beneficiaries Receiving HCBS appeared first on Simon&Co., LLC.

]]> Read the full assessment here.

The post Independent Assessment Of Medicaid Beneficiaries Receiving HCBS appeared first on Simon&Co., LLC.

]]> Survey of Organizational Conflicts of Interest In Government Contracting https://mjsimonandcompany.com/program-integrity/conflicts-of-interest-policies/survey-of-organizational-conflicts-of-interest-in-government-contracting/ Thu, 12 Oct 2023 16:08:19 +0000 https://mjsimonandcompany.com/dev/?p=1900 Read the full COI review here.

The post Survey of Organizational Conflicts of Interest In Government Contracting appeared first on Simon&Co., LLC.

]]> Read the full COI review here.

The post Survey of Organizational Conflicts of Interest In Government Contracting appeared first on Simon&Co., LLC.

]]>