CMS Presolicitation Notice: Unified Program Integrity Contract (UPIC)

On June 5, 2015 CMS issued a presoliciation notice indicating that they will be issuing a Request for Proposal (RFP) to solicit services for the Unified Program Integrity Contract (UPIC).  As per the notice, “the UPIC will combine and integrate existing CMS program integrity functions carried out by multiple contractors and contracts into a single contractor to improve its capacity to swiftly anticipate and adapt to the ever changing and dynamic nature of those involved in health care fraud, waste, and abuse across the Medicare and Medicaid program integrity continuum.” The solicitation will be available on or about June 22, 2015, and will be distributed solely through the Federal Business Opportunities (FBO) website. Proposals are expected to be due 30 days from the RFP issue date.

The notice that CMS plans to issue an RFP for Unified Program Contracts comes almost two years after CMS put forth their strategy for contractor consolidation under the Unified Program Integrity Contract.  On July 2, 2013, CMS posted a Special Notice inviting interested industry representatives to participate in the Center for Program Integrity (CPI) Industry Day.  The objective of the Industry Day was stated to be “to introduce the CPI’s vision and goals for strengthening the integrity of the Medicare and Medicaid Programs through improved contracting approaches and strategies.” The Notice indicated that “CPI seeks to integrate the program integrity functions for audits and investigations across Medicare and Medicaid.”

During the Industry Day, Craig Gillespie, currently Director of the Contract Management Group at CPI, presented a conceptual overview of UPICs and CMS’s strategy as they related to contractor consolidation under the program .  The strategy was aimed toward a “holistic and coordinated Medicare/Medicaid program integrity strategy” that included cooperation and communication between regional program integrity contractors, leverage of CPI’s centralized tools nationally and a strengthening of CMS’ national level oversight of contractors.  At that time, the “Fundamental Contractor Activities” were stated to be the following:

1. Identify and Prioritize Leads
2. Data Analysis and Managing Leads
3. Conduct Investigations
4. Protect Program Dollars
5. Identify Medicare and Medicaid Overpayments
6. Support to the Administrative Appeals Process
7. Support to CMS
8. Support to Law Enforcement

In conjunction with the Special Notice, CMS issued a draft Request for Information (RFI) Requirements Document for the Unified Program Integrity Contractor. The RFI notice sought feedback from industry representatives regarding the draft Requirements Document.  Each of the “fundamental activities” listed above is presented in more detail in the draft document.

Further to the above, on May 1, 2014, CMS issued a Sources Sought Notice (SSN) related to the UPIC program.  The SSN states that CMS currently relies on a network of contractors to carry out program integrity work and that they are seeking to combine the functions of various contractors under the UPIC.  Specifically, the SSN identifies the functions of the Zone Program Integrity Contractors (ZPICs) and Program Safeguard Contractors (PSCs), the Medicaid Integriy Contractors (MICs) and the Medicare-Medicaid Data Match (Medi-Medi) incorporated under the ZPIC scope of work as functions which would be combined under the UPIC.  As part of the SSN, CMS included a Draft Statement of Work for the UPIC.  The draft SOW totals 86 pages and includes the scope, applicable statutes, regulations and documents, program goals, implementation and transition requirements, functional requirements, expected outcomes and administrative requirements related to the UPIC.

The draft requirements document issued in conjunction with the Industry Day Notice, as well as the RFI Questions posted alongside the draft, combined with the Draft SOW issued as part of the SSN provide a comprehensive overview of the development of CMS’ UPIC strategy and may provide detailed insight into the forthcoming RFP from CMS.