The OIG recently examined potential conflicts of interest that could affect the impartiality of Zone Program Integrity Contractors (ZPIC) — Medicare contractors that perform program integrity activities designed to fight Medicare fraud, waste, and abuse. The OIG found that most companies that submitted proposals for ZPIC contracts (offerors) and/or their subcontractors had business and contractual relationships with CMS and/or other contractors (such as Medicare Advantage and Part D drug plan sponsors or program integrity or claims processing contractors). For instance, seven offerors were subsidiaries of health insurance companies that offered Medicare Part C or Part D plans, two-thirds of offerors either were Medicare claims processors or had financial ties to claims processors; and half of the offerors had existing Medicare program integrity contracts. Offerors, subcontractors, and CMS identified 1,919 business and contractual relationships as “possible conflicts” and 16 as actual “impaired objectivity” conflicts out of a total 1,935 reported conflicts, meaning the work to be performed under the ZPIC contract by the offeror could potentially involve the scenario of evaluating itself. CMS considered all of the actual conflicts to be mitigated, such as through the imposition of restrictions on information sharing within the company. In addition to these identified potential conflict-of-interest relationships, the OIG found that offerors and their subcontractors did not always provide to CMS all of the required information regarding their financial interests in other entities. The OIG offers a series of recommendations to encourage transparency and accountability among contractors, including clearer guidance on the contracts and relationships that must be disclosed and the creation of a written policy outlining how CMS will review conflict-of-interest information.