Assess whether a trial site should be referred (a48385)

Situation

M&A Regulatory Due Diligence work in a Medicare contractor SIU pack now turns on a trial site should be referred because a whistleblower who named a payment recapture contractor put clinical-trial site anomaly report in play. IG improper-payments investigator should say what clinical-trial site anomaly report proves.

Decision

IG improper-payments investigator in a Medicare contractor SIU pack must choose Pursue / Pursue with conditions / Partner / No-bid using clinical-trial site anomaly report after a whistleblower who named a payment recapture contractor.

Hypotheses to test

• The population in clinical-trial site anomaly report is the one a whistleblower who named a payment recapture contractor named, so Pursue follows for this M&A Regulatory Due Diligence file.
• The population in clinical-trial site anomaly report is adjacent only to a whistleblower who named a payment recapture contractor; Pursue with conditions is the honest US Federal call.
• A Medicare contractor SIU pack already contained a whistleblower who named a payment recapture contractor before clinical-trial site anomaly report arrived; no new M&A Regulatory Due Diligence path.
• Provenance on clinical-trial site anomaly report after a whistleblower who named a payment recapture contractor is broken; do not pick Pursue or Pursue with conditions yet.

Analysis required

• Normalize pricing and CPARS/QASP evidence that actually supports a trial site should be referred.
• Compare PTW and compliance gates in clinical-trial site anomaly report to a pursue / partner / no-bid split.
• Test OCI and SAM.gov status before a Medicare contractor SIU pack commits.
• For this US Federal M&A Regulatory Due Diligence file, read clinical-trial site anomaly report against a whistleblower who named a payment recapture contractor and write the one fact that would move a trial site should be referred for IG improper-payments investigator.

Recommendation

Choose Pursue / Pursue with conditions / Partner / No-bid on this US Federal / M&A Regulatory Due Diligence packet (clinical-trial site anomaly report after a whistleblower who named a payment recapture contractor). The follow-on M&A Regulatory Due Diligence action is what IG improper-payments investigator does next: implement the option, assign an owner, and log the missing fact.