Organizational Conflict of Interest
UPIC Investigation
SafeGuard Services LLC
Peraton
Gainwell Technologies
Connecticut ABI Waiver
Medicaid Fraud Waste and Abuse
Olmstead Act Violations
Documented Organizational Conflict of Interest – SafeGuard Services (Peraton UPIC) and Gainwell Technologies Share Exact Same Building During Investigation of Connecticut ABI Medicaid Whistleblower Complaint (March 26, 2026)
MEMORANDUM FOR FEDERAL INVESTIGATORS
Subject: Apparent Organizational Conflict of Interest Between SafeGuard Services LLC / Peraton (Northeastern UPIC) and Gainwell Technologies During Investigation of Connecticut Medicaid ABI Waiver Whistleblower Complaint
Date: March 26, 2026
Summary
On March 25, 2026, the Northeastern Unified Program Integrity Contractor (UPIC) SafeGuard Services LLC / Peraton contacted me regarding my whistleblower complaint alleging systemic Medicaid fraud and Olmstead violations in Connecticut’s ABI Waiver & MFP programs.
The same day and the following day, Gainwell Technologies (the fiscal agent and claims processor for Connecticut Medicaid’s CMAP system) sent official system alerts to my provider account.
Both contractors operate from the exact same physical building at 1250 Camp Hill Bypass, Camp Hill, PA 17011 (SafeGuard / Peraton in Suite 200; Gainwell in Suite 100).
This physical co-location creates a clear appearance of organizational conflict of interest, which may compromise the independence required of a UPIC investigation.
Roles of the Parties
SafeGuard Services LLC / Peraton Acts as the Northeastern Unified Program Integrity Contractor (UPIC) for CMS. Responsible for independent audits, investigations, and enforcement of Medicaid fraud, waste, and abuse.
Gainwell Technologies Serves as the fiscal agent and Medicaid Management Information System (MMIS) contractor for the State of Connecticut. Processes and pays all Medicaid claims for the ABI Waiver program. ABI Resources has experienced what may appear to be whistleblower retaliations from Gainwell Technologies.
Documented Evidence of Co-Location
Annotated Google Maps satellite image showing both entities in the same building, with red arrows and Eric Bischof’s email overlaid for clarity.
Public evidence page (with downloadable PDFs and viewer):
https://david-medeiros.com/2026-upic-safeguard-gainwell-conflict-of-interest-evidence
Timeline of Contact
March 25, 2026 Eric M. Bischof, Project Coordinator, SafeGuard Services / Peraton UPIC, sent official email acknowledging my whistleblower complaint and requesting additional incident details (email attached).
March 26, 2026 Gainwell Technologies sent CMAP E-Delivery Alert to my ABI Resources provider account.
Legal and Regulatory Basis
This arrangement violates the independence standards required for UPIC contractors:
FAR Subpart 9.5 (Organizational Conflicts of Interest)
42 CFR § 455.238 (Conflict-of-Interest Rules for Contractors)
CMS Program Integrity Manual (Chapter 4 – Contractor Requirements)
The UPIC’s role demands complete independence from any entity whose operations it is investigating. Shared physical facilities create an unavoidable appearance of bias and potential improper influence.
Impact
The conflict directly affects the integrity of the investigation into my whistleblower allegations of systemic fraud, waste, abuse, and unnecessary institutionalization under the Olmstead Act. It also raises serious concerns about the handling of federal Medicaid funds in Connecticut.
Current Status
ZERO corrective action has been taken by CMS, HHS-OIG, or the contractors. The conflict remains unresolved.
Public Record and Evidence
All documents, emails, maps, and filings are permanently archived and indexed for immediate review at:
https://david-medeiros.com/2026-upic-safeguard-gainwell-conflict-of-interest-evidence
Prior related filings include my March 13, 2026 Olmstead Whistleblower Report, 2024 Federal Intervention Report, and 2024 OSC disclosures.Documented Organizational Conflict of Interest – SafeGuard Services (Peraton UPIC) and Gainwell Technologies Share Exact Same Building During Investigation of Connecticut
ABI Medicaid Whistleblower Complaint (March 26, 2026)
⚠️ ZERO CORRECTIVE ACTION TAKEN CONFLICT REMAINS UNRESOLVED
2026 Major Organizational Conflict of Interest Confirmed
SafeGuard Services LLC (Peraton Northeastern Unified Program Integrity Contractor) and Gainwell Technologies (Connecticut Medicaid Claims Processor) operate from the exact same physical building at 1250 Camp Hill Bypass, Camp Hill, PA 17011 while SafeGuard was actively investigating my whistleblower complaint on systemic Medicaid fraud and Olmstead violations.
Direct Evidence (March 25–26, 2026)
• March 25, 2026 SafeGuard Services (Peraton UPIC) Official Response from Eric M. Bischof, Project Coordinator
Email: eric.bischof@peraton.com | Phone: (571) 508-2367
• March 26, 2026 Gainwell Technologies CMAP E-Delivery Alert sent to ABI Resources account
• March 26, 2026 Annotated Google Maps Proof showing both entities in the same building with Eric Bischof’s email overlaid
ZERO CORRECTIVE ACTION TAKEN by any federal or state agency.
Conflict Analysis
SafeGuard’s role as UPIC requires independent investigation. Gainwell runs the entire Connecticut Medicaid portal (CMAP). Shared facilities create an undeniable appearance of organizational conflict of interest under FAR Subpart 9.5, 42 CFR § 455.238, and the CMS Program Integrity Manual.
This directly impacts my March 13, 2026 Olmstead Whistleblower Report and all prior 2023–2024 filings.
Federal Filings Already Made
• HHS-OIG Grant/Contract Fraud Complaint
• DOJ Civil Rights Division Record #747218-WZZ
• FBI Public Corruption Tip
All evidence is permanently archived and publicly indexed on this site.
Related Reports
→ 2026 UPIC Conflict of Interest Evidence Page
→ 2026 Olmstead Whistleblower Report
→ 2024 OSC Whistleblower Disclosures
→ 2024 Federal Intervention Report
ADA / TBI Accommodation
Due to my Acquired Brain Injury, all communication must be in writing only. I will not speak with or reply to any non-federal entities.
Demand for Federal Action
HHS-OIG, CMS, and DOJ must immediately investigate and resolve this organizational conflict of interest.
Related evidence references
Verified Offline Evidence Vault
The following 11 raw files have been forensically matched to this case timeline via physical filename chain-of-custody.