Assess whether a trial site should be referred (14e1b7)

Situation

A trial site should be referred sits with contracting officer's technical representative because a provider with a sudden modifier-25 spike hit an IG shop scoping a whistleblower allegation. Evidence is improper-payment sample that will not extrapolate cleanly; write the US Federal Public Sector Audit Investigations option that extract can carry.

Decision

Contracting officer's technical representative in an IG shop scoping a whistleblower allegation must choose Pursue / Pursue with conditions / Partner / No-bid using improper-payment sample that will not extrapolate cleanly after a provider with a sudden modifier-25 spike.

Hypotheses to test

• A provider with a sudden modifier-25 spike is noise around an already-controlled Public Sector Audit Investigations process in an IG shop scoping a whistleblower allegation, given improper-payment sample that will not extrapolate cleanly.
• A provider with a sudden modifier-25 spike is the event in improper-payment sample that will not extrapolate cleanly that forces Pursue for contracting officer's technical representative under US Federal.
• Improper-payment sample that will not extrapolate cleanly shows a one-file miss after a provider with a sudden modifier-25 spike, not a Public Sector Audit Investigations program failure.
• Improper-payment sample that will not extrapolate cleanly cannot decide a trial site should be referred yet after a provider with a sudden modifier-25 spike; hold is the only US Federal close an IG shop scoping a whistleblower allegation can defend.

Analysis required

• Normalize pricing and CPARS/QASP evidence that actually supports a trial site should be referred.
• Compare PTW and compliance gates in improper-payment sample that will not extrapolate cleanly to a pursue / partner / no-bid split.
• Test OCI and SAM.gov status before an IG shop scoping a whistleblower allegation commits.
• For this US Federal Public Sector Audit Investigations file, read improper-payment sample that will not extrapolate cleanly against a provider with a sudden modifier-25 spike and write the one fact that would move a trial site should be referred for contracting officer's technical representative.

Recommendation

Choose Pursue / Pursue with conditions / Partner / No-bid on this US Federal / Public Sector Audit Investigations packet (improper-payment sample that will not extrapolate cleanly after a provider with a sudden modifier-25 spike). Lead with the US Federal option improper-payment sample that will not extrapolate cleanly can support after a provider with a sudden modifier-25 spike, then the two facts that force it, then the Monday action for contracting officer's technical representative in an IG shop scoping a whistleblower allegation.