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A conflict of interest may exist when a contractor has an interest, financial or otherwise, in the outcome of its services or a relationship with an individual or contractor that could influence the outcome of its services. Conflicts of interest, whether real or perceived, can undermine the effectiveness of government programs as well as public confidence and trust in the programs’ integrity.

Maximus is firmly committed to offering conflict-free services to government, which is critical for our work as the largest independent administrative services organization, supporting 70 percent of all Medicaid and CHIP beneficiaries in the country and as the largest Qualified Independent Contractor of Medicare appeals.

Which regulations require conflict-free services?

Government Rule


Balanced Budget Act of 1997

Covers state Medicaid managed care enrollment brokers

42 Code Federal Regulations § 438.810

Requires independence of state Medicaid managed care enrollment brokers

Federal Acquisition Regulation Subpart 9.5

Medicare Compliance Program Guide for Medicare Fee-for-Service Contractors that prevents the existence of conflicting roles that might bias a contractor’s judgment and precludes unfair competitive advantage

The Sarbanes-Oxley Act of 2002

Strengthens financial oversight of corporations by ensuring that corporations accurately certify their financial reporting and adhere to key provisions on disclosures, controls and improper influence

LTSS Regulation of March 2014

Requires separation of assessment and care planning from direct service delivery

Medicaid and CHIP Managed Care Rule (June 2016)

Contains definitions and codifies COI in the assessment and care planning process for LTSS

State “Sunshine Laws”

Encourage transparency by requiring full and open disclosure of services procured by governments

Balanced Budget Act of 1997

Covers state Medicaid managed care enrollment brokers

The Importance of Delivering Conflict-Free Services to Government