Request for Information - Fraud Defense Contracts

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Confidentiality:

No proprietary, classified, confidential, or sensitive information should be included in your response. The Government reserves the right to use any non-proprietary technical information in any resultant solicitation(s).

Protection of Privileged or Confidential Commercial or Financial Information:

The Freedom of Information Act (FOIA), 5 U.S.C. § 552, provides individuals with a right to access certain records in the possession of the Federal government, subject to certain exemptions. Exemption 4 of the FOIA permits information to be withheld that is in the nature of "trade secrets and commercial or financial information obtained from a person and privileged or confidential." The term "person" refers to a wide range of entities, including corporations, banks, state governments, agencies of foreign governments, and Native American tribes or nations, who provide information to the government. Information that does not qualify withholding under the Exemption will be disclosed. CMS may invoke Executive Order 12600 in accordance with FOIA Regulation 45 C.F.R. § 5.42. Information provided by entities to CMS in response to this notice may be subject to FOIA disclosure requirements unless protected under Exemption 4 of the Freedom of Information Act. Should entities wish to protect any trade secret or confidential information under Exemption 4, they should mark their submission accordingly citing applicable redactions and non-disclosure rationale. Pre-disclosure redactions and non-disclosure rationale shall be sent via e-mail to the requesting contracting officer with a copy to the CMS FOIA Office at 12600@cms.hhs.gov.

If an entity’s submission is not marked and CMS receives a FOIA request related to this notice, the CMS Contracting Officer will notify the entity. The entity will have 10 working days to object to the release of any part of their information submitted to CMS citing relevant case law. Final determination on the applicability of Exemption 4 of the FOIA are made on a case-by-case basis by CMS.

The statutory language of the FOIA is codified at 5 U.S.C. § 552(b). Additional information and resources, including the 9 FOIA Exemptions and HHS FOIA Regulation, and examples, can be found on the HHS FOIA Website.

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 1. Overview

        1.1 Introduction

The Centers for Medicare & Medicaid Services (CMS) works diligently to crush fraud in federal health care programs, including Medicare and Medicaid. A cornerstone of CMS’ program integrity (PI) strategy is focused on using advanced analytics and other investigative techniques to identify potentially problematic actors and stopping them in their tracks.  CMS has traditionally contracted with private entities to bolster our investigative capabilities and take appropriate administrative action, including imposing payment suspensions, revoking Medicare billing privileges, and referring potential fraud cases to states and appropriate law enforcement entities. Through this Request for Information (RFI), we are seeking creative ideas and solutions as to how a contractor might best address the draft Statement of Objectives (SOO) (see Attachment 3.1). The draft SOO reflects the direction of the proposed future operating model, including a greater CMS role in lead development, prioritization, and direction of investigations. We encourage commenters to recommend innovative approaches for accomplishing the objectives within that framework and to identify where the framework creates risk. Within that framework, responses should not be constrained by traditional policies and processes, such as those in the current Unified Program Integrity Contractor (UPIC) Statements of Work or the Medicare Program Integrity Manual. We have also developed a list of specific questions for which we are seeking input; however, all ideas are welcome.

Please note that this RFI is for informational purposes only, and no contract will be awarded as a result. A firm or organization’s response to the RFI⁠—or lack thereof—will have no impact on the evaluation of responses to any subsequent Request for Proposals (RFP),  Request for Quote (RFQ), or Solicitation released. Responses will be used solely for information and planning purposes. No reimbursement will be made for any costs associated with providing information in response to this Request.

        1.2 RFI Contact

We have designated the following individual to serve as the official point of contact for this RFI. This individual is the only authorized contact permitted to communicate on behalf of CMS about this RFI.

               Jennifer Kuhn, Contracting Officer

               Office of Acquisition and Grant Management/ CMS

               Jennifer.Kuhn@cms.hhs.gov

        1.3 Submission Details

Please submit ONLY your completed Attachment 3.2, Request for Information – Interested Vendor Response, via email to the RFI point of contact no later than 11 AM EST on November 4, 2026.  THIS IS NOT A REQUEST FOR CAPABILITY STATEMENTS. 

   2. Information Requested

Interested Vendors are asked to complete the attached fillable PDF (Attachment 3.2, Request for Information – Interested Vendor Response).  Vendors must complete all entity related information, but may respond to some or all questions.  Please note that there is a 4,000-character limitation for each question.

Following review of the RFI responses, CMS reserves the right to follow-up with individual respondents to further discuss information provided in their submissions and obtain additional industry feedback relevant to the Fraud Defense Contracts.

   3. Attachments

          3.1 Draft Fraud Defense Contracts Statement of Objectives

          3.2 Request for Information – Interested Vendor Response