MSS_Draft_RFP_Questions_and_Comments_-_8_May_17.docx

1. Addendum to FAR 52.212-2, 2.1.3.4, Table 2 – Under the definition for “Highly Relevant” it is required that a contract must demonstrate performance in at least two states and that the customer must be either DHA or AFMS. This seems to significantly limit the types of contracts that small businesses can submit in response to this proposal that will achieve the highest possible relevancy score.

We would recommend that the Government change “Performs in at least two (2) states” to “Performs in at least two (2) performance locations”. This change would allow offerors who have contracts that require performance at two separate performance locations under a single contract, but that may only fall under a single state (i.e. Enhanced Multi-Service Markets) to achieve a “Highly Relevant” rating for these services. In many cases, performance under these contracts is equally as complex as performance in multiple states owing to differences between service branches in the marketplace.

We would recommend that the Government change “Customer is DHA or AFMS” to “Customer is DoD” to allow for the inclusion of Army Medical Command and Navy Medical contracting. Technical Exhibit 3 includes performance at Air Force, Navy and Army installations, so it would be logical to expand this definition to encompass these customers on a “Highly Relevant” rating.

Government Response: The criteria you described is for Relevant. To meet the “Highly Relevant” rating, the experience must be more than relevant. No change is anticipated to the Highly Relevant definition.

2. Addendum to FAR 52.212-1, 3.1, Tab 5 – As currently written, the draft RFP states that the Letter of Credit must be for the Prime Offeror. We recommend that this be altered to include teaming partners. In many Mentor-Protégé agreements, access to the Mentor’s larger financial resources are one of the primary benefits to small businesses who form a Joint Venture under the terms of their Mentor-Protégé Agreement.

Additionally, in many cases it is difficult for small businesses to obtain this letter of credit prior to being awarded a contract. If the Government will not consider expanding the Letter of Credit for teaming partners, we recommend that the Government make this Letter of Credit be due after award but before the start of services and not with the proposal submission.

Government Response: Thank you for your comment. The Letter of Credit requirement will remain the same. It is already authorized for the $2M Letter of Credit to be contingent upon award of the contract. The Letter of Credit should be issued to the prime offeror alone and not the proposed partnerships.

3. Performance Work Statement, 5.1.1 – In many cases, offerors may have Organizational Conflicts of Interest (OCI) stemming from other unrelated services that may hamper their ability to bid on certain issued task orders. We recommend that the Government clarify this 85% participation rate to exclude OCI-related non-participation from the calculation of participation rate.

Government Response: The Government will relook at this requirement. It may be clarified in the final RFP.

4. Technical Exhibit 5, Service Type II – We recommend that the Government provide the expected average number of transactions per FTE for the Service Type II billing to allow offerors to provide more accurate design of Service Type II project levels of effort.

Government Response: The estimate provided is the number of billable transactions for that particular service. We will not provide a transaction per FTE—the Government is identifying the number of workers to be placed—only the workload to be done.

5. We are requesting the following revision to the draft: Addendum to FAR 52.212.-2, section 2, subsection 2.13.1, please consider adjusting the “recency” definition to 5 years rather than 3 years. This would be consistent with the recent DHA procurement for medical services and would most likely increase participation in the procurement.

Government Response: There is no way to validate past performance in PPIRS farther back than 3 years, thus this shall remain as is consistent with the official past performance repository.

6. NAICS Code (Reference: Draft PWS pg. 68: Addendum to FAR 52-212-1 (a)) Recommends that the government issue this procurement under NAICS code 621498, All Other Outpatient Centers ($20.5M) with a Small Business set aside. This will allow larger, more established small businesses to be the prime contractor. In our experience providing Medical Support Services for DoD and the current incumbent, we have found smaller businesses (<$15M) struggle handling the size and scope of the IDIQ requirements. For example, we have seen smaller business without the sufficient infrastructure in place to handle all contract requirements, resulting in staff pay fluctuations, lack of strong program management, and high staff turnover rates.

Government Response: After two surveys and market research efforts, it has been determined that the assigned NAICS code is most appropriate for this acquisition.

7. Funding Allocation (Reference: Draft PWS pg. 68: Addendum to FAR 52-212-1 (d)) Does the government anticipate fully utilizing the funding allocated ($969M) in support of 20 IDIQ awards? If not, will there be sufficient requirements to support the 20 awarded vendors?

Government Response: Although the Government does anticipate sufficient requirements to require the support of 20 vendors, the exact expected funding expenditure is unknown, hence the usage of the multiple award IDIQ contract vehicle.

8. Excluding Medical Coding (Reference: Draft PWS pg. 101: Description of Services) Medical record coding is now highly specialized and technical in this era of ICD-10, and less of an administrative function as it was previously. Given these recent industry changes and coding complexities, we recommend coding not be included in this administrative IDIQ and issued as a stand-alone professional contract that can successfully be vetted through experienced coding vendors.

Government Response: The scope of this vehicle is not only administrative. It includes Clerical, Certified, Specialized and Technical services. Medical Coding will remain in the contract because we have allowed each ordering location the opportunity to tailor standard position descriptions/statement of objective or add a separate, new performance work statement during the ordering process. It is our desire that Prime Offerors’ build their teaming structure to be “experienced” in the full scope of this program.

9. Standardized Electronic Mechanisms for Monthly Reporting. Current similar IDIQs do not have standardized electronic mechanism for the vast monthly reporting requirements by MTF. We recommend web-based reporting that automatically tracks requirements and supports hundreds of task orders in an easier to utilize fashion by both the vendor and the government reviewers.

Government Response: Thank you for your suggestion.

10. As part of Attachment 2 of the Technical Self-Scoring Worksheet, please clarify if the Offeror may reference the same contract if contracted personnel are serving in dual positions (i.e. line 24 (medical appointment clerks) and line 26 (medical office clerks).

Government Response: The numbers listed in on the worksheet are full-time equivalent personnel. Therefore, personnel serving in dual positions would not be meeting the objective to demonstrate capability.

11. As part of Technical Exhibit 3 Performance Locations of the Draft Solicitation, please clarify under the Regional Health Contracting Offices that this includes medical support services to all U.S. Army medical treatment facilities, dental facilities, public health centers and subordinate units of each Regional Health Command.

Government Response: Yes, the Army can order services under this vehicle for any Army location in the 50 United States and its territories.

12. Attachment 2 Technical Self Scoring Sheet Section 7. Section 7 of the Technical Scoring Sheet states that the supporting documentation must be from the “Prime contractor.” Please clarify if this is the Prime Offeror on the MSS opportunity or can be a subcontractor who served as a Prime Offeror on a referenced contract be used.

Government Response: Section 7 on the Technical Worksheet is for you to demonstrate your capability as either a Prime Contractor or Subcontractor, but you may not do both. Since performance as a Prime Contractor carries more points, you would be wise to include documentation that supports the offeror as the Prime Contractor.

13. PROPOSAL ORGANIZATION (Draft P. 71) Supporting Documentation. For submitted Supporting Documentation, does the government wish us to circle the item that is being validated on Attachment 2 Technical Self Scoring Sheet?

Government Response: The instructions state: “Offerors will highlight (by color or circling) the information in the document(s) that validate their claimed technical capability.” To state another way, Offerors should circle/highlight the data/information on the supporting documentation before it is scanned to be included in the volume. For example, if you are claiming Prime Contractor Experience (Section 7 of the Worksheet), the supporting documentation (SF33, DD1155, CPARS), would have a circle or highlight of the “contractor name” field on the supporting documentation.

14. Attachment 2 Technical Self Scoring Sheet Section 5 and 6. Would the government consider adding North Dakota to either Section 5 or 6 of the Technical Self Scoring Sheet?

Government Response: No, the Government did thorough analysis to identify high demand and hard-to-fill locations on current requirements. While there may be other requirements procured, we only used known requirements to develop the list.

15. Attachment 2 Technical Self Scoring Sheet Section 5 and 6. Would the government consider removing Minnesota as a Hard to Fill Location and replacing it with New Mexico? There are a small handful of DoD locations and Military Treatment Facilities in Minnesota. As such, only a small % of business will be able to have Past Performance there.

Government Response: See response to #14.

16. Attachment 2 Technical Self Scoring Sheet Section 6. Would the government consider allocating Alaska with a 15 Point score on par with Hawaii for a Hard-to-Fill Location?

Government Response: See response to #14.

17. 2.1.3.5.7.1. P. 99 of Draft Response. 2.1.3.5.7.1. states “Offerors with adverse past performance will be afforded an opportunity to address alleged performance issues if the offeror has not already been provided an opportunity to comment on the issues IAW FAR 15.306(a)(2) and FAR 15.306(b)(4).” Where in the response, are offerors allowed to respond to adverse past performance? Will it be through the PPI tool?

Government Response: Typically, if the Government receives adverse past performance, an Evaluation Notice will be issued for the company to respond to.

18. 2.1.3.5.7.1. P. 99 of Draft Response. If the submitted Past Performance Questionnaire (Attachment 5) does not reflect adverse past performance but a separate source that is not submitted (i.e. CPAR) reflects adverse past performance, will the government expect a response at the time of submission? Will the offeror be given the opportunity to respond after proposal submission?

Government Response: Offerors will not be given a second opportunity to address adverse past performance from a CPARS. Companies were afforded that opportunity during the Contractor Input step of the CPARS process.

19. Attachment 2 Technical Self Scoring Sheet Rows 34-40, Healthcare Setting. Clerk or beneficiary representative roles can occur in a nonclinical setting such as a call center. Will the government allow offerors to use Supporting Documents for self-scoring that may show alternative settings Offerors cannot get credit for?

Government Response: A call center is often considered an extension location of the medical facility; however, it can be credited under the Other category.

20. Attachment 2 Technical Self Scoring Sheet CPARS. If a contract has CPARS but does not specifically identify position or # of FTEs claimed, should offeror submit a signed copy of the SF 1449, SF33 or DD1155 along with other contract pages that show the claimed item (labor category, FTE, location, dollar value, etc.)?

Government Response: Yes, per Instructions on Row 45 of the Technical Self Scoring Worksheet, offerors should provide a signed copy of the SF 1449, SF33 or DD1155 along with other contract pages that show the claimed item (labor category, FTE, location, dollar value, etc.).

21. Reference Past Performance Questionnaire (Attachment 5). If a contract has a CPARs but CPARs does not verify positions and FTEs, should the Offeror submit a Past Performance Questionnaire?

Government Response: Per the instructions, Paragraph 3.3 VOLUME III, PAST PERFORMANCE, “The offeror is responsible for initiating Past Performance Question (PPQ) only if the past performance reference is not available in CPARS.”

22. TAB 2 – References for Teaming Partner/Subcontractor. Reference states “Five references should be for the teaming partners/subcontractors, if applicable.” Are five references required for subcontractors?

Government Response: If you propose teaming partners, three references should be for the Prime contractor and 5 for the partners.

23. 4.2 Technical and 2.1.3.1. Past Performance. The technical scoring sheet allows past performance with the last 5 years per 4.2. However, for 2.1.3.1, past performance is only considered recent within the last 3 years. Please clarify if these recency requirements were intended to match or can be different.

Government Response: The Government is aware of the difference and will look into it for consistency. PPIRS only contains evaluations in the past three (3) years. However, the intent of the Technical Volume is to assess capabilities; while Past Performance is evaluating how well you performed.

24. 4.2 VOLUME II – TECHNICAL 3.3VOLUME III – PAST PERFORMANCE. In the final solicitation, can the government clarify whether the experience presented in Volume II-Technical as part of the Self-Scoring Process has to match the Past Performance presented in Volume III.

Government Response: Intuitively, if you are claiming capability in the Technical Section, an offeror would want to demonstrate their past performance history. Additionally, Addendum to 52.212-1, Instructions, Paragraph 4.2.a states: “Offerors should consider their past experience to attest to future technical capabilities for this solicitation.”

25. 4.2 VOLUME II – TECHNICAL 3.3 VOLUME III – PAST PERFORMANCE. Several clinical positions and credentialed requirements are currently part of the MSS contract. Will the government consider allowing and giving credit/relevancy for clinical past performance as part of the Past Performance and Technical response?

Government Response: The DHA MSS is assessing certified, specialized/technical, and clerical services for both Technical and Past Performance. You may submit clinical services (i.e., doctors, nurses, ancillary, etc.) in your proposal; however, you should consider the relevancy definitions in ADDENDUM TO 52.212-2, Paragraph 2.1.3 and Table 2.

26. Attachment 2 Technical Self Scoring Sheet. Other Labor Category/Service - Points: 1,1,1,2. Can the government provide a list of “Other Labor Category” to be used in the Technical Response?

Government Response: We will not define “Other”. However, the Instructions state: “If the offeror never placed those types of labor categories/services, leave blank and complete Other Labor Category/Service in Row 17, Element e. Offerors may not complete Row 17, Element e if they have placed an “X” in the Columns for Certified (Row 9, Section 1, Element a), Specialized/Technical (Row 10, Section 1, Element b), Administrative/Clerical (Row 13, Element c), and Other Medical Support FTEs (Row 15, Element d). “ Therefore, if the capability is not one of the MSS categories, it would fall into Other. If you claim one of the MSS categories, you may not submit an “Other” capability.

27. Table 2 - PAST PERFORMANCE RELEVANCY ASSESSMENT. As a comment, will the government please reconsider the Highly Relevant standard to include DHA or AFMS? Given that DHA is relatively new organization, it is unnecessarily restrictive and should include any DoD Past Performance.

Government Response: See response to #1 above.

28. 4.2 VOLUME II – TECHNICAL 3.3 VOLUME III – PAST PERFORMANCE. Can a technical self-scoring sheet and past performance reference be defined by the offeror as a single master contract and a single task order to allow the use of multiple task orders against a single Master Contract?

Government Response: No, instructions state: “Do not provide a contract-level CPARS if the item claimed was provided under a task order (provide either that Task Order CPARS or task order contract documents to attest your claim. The Offeror shall not consolidate requirements on multiple task/delivery orders to obtain a higher point value since task orders are considered a single contract under this solicitation. Likewise, the Offeror shall not consolidate requirements for different option periods on the same contract to obtain a higher point value as part of their supporting documentation.”

29. 2.2 Position Descriptions: Unique Military Health Care Systems/Procedures - It is currently not clear if the Government or the contractor is responsible for providing training for these systems. Additionally, some processes and/or systems require additional training and/or equipment which is not designated as contractor or Government responsibility such as:

Medical Evaluation Board Nurse Liaison – PD Section 2.2……In addition, preliminary training is required. The preliminary training includes spending at least two weeks working with an experience Government individual before assuming full duties. Is this in a paid and/or billable status?

Government Response: Yes, once the worker starts, all MTF-specific training or training outlined in the standard position description or modified position description in the task order performance work statement would be billable to the Government. This may not apply for Service Type II orders.

30. 2.2 Position Descriptions: Unique Military Health Care Systems/Procedures - It is currently not clear if the Government or the contractor is responsible for providing training for these systems. Additionally, some processes and/or systems require additional training and/or equipment which is not designated as contractor or Government responsibility such as:

Concern/Question/Suggestion: Table 1 - Proposal Organization specifically lists that Attachment 1 should be included in Volume I, at Tab 2c. However, this paragraph states that it should also be included in Volume IV, Tab 6 but there is no listing of the tabs to be included in Volume IV. Please note, Table 1 does show that Attachment 1 should also be included in Volume III, Tab 4. Could the Government please clarify in which volumes that Attachment 1 should be included?

Government Response: Thank you for identifying our oversight. The Teaming/Organizational Structure (Attachment) is required in Volume 1, Tab 2c, and Volume III, Tab 4.

32. 3.1 ADDENDUM TO FAR 52.212-1, Pages 69-100, Reference: Page 73, Para 3.1 Volume I – Contract Administration, Tab 5 Letter of Credit. Quote: Offerors must include a Letter of Credit to demonstrate the offeror’s financial health and capacity to cover startup expenses for this requirement. The document, issued by a bank or other financial institution, shall provide the offeror a line of credit for a minimum of $2 million.

Concern/Question/Suggestion: As this solicitation is aimed at small businesses with average revenue of $15M, some of the smaller companies may experience difficulties in obtaining the Letter of Credit without an award. Would the Government consider making this requirement contingent upon award?

Government Response: See response to #2.

33. 3.2 PWS Pgs 100-267, Introduction/General Information Sections 1-1.28, Reference: Draft RFP, Performance Work Statement, para 1.5.4.3. Quote: The contractor shall ensure coordination of any planned MSS personnel absences in accordance with procedures outlined at the task order level, no notification will occur less than 60 calendar days prior to the planned absence.

Concern/Question/Suggestion: Planned absences include doctor's appointments, school events, or personal time which is rarely known 60 days in advance. Would the Government consider revising this requirement to clarify the length of planned absence (I.E. one week, two weeks, etc.) which requires a 60 day notice?

Government Response: The intent of this requirement is to ensure the planned absences (vacations, military tours, etc.) are coordinated with the customer. The Government will relook at the timeline and revise in the final RFP.

34. 3.2 PWS pgs 100-267, Introduction/General Information Sections 1-1.28, Reference: Draft RFP, Performance Work Statement, para 1.5.10.1. Quote: …The HCW shall not transport patients (or their family members) or Government personnel in his/her personal or government issued vehicle without prior approval from the COR and ordering KO.

Concern/Question/Suggestion: Does this requirement include transporting Government personnel in Contractor purchased rental vehicles during temporary duty assignments?

Government Response: Yes.

35. 3.2 PWS Pgs 100-267, Introduction/General Information Sections 1-1.28, Reference: Draft RFP, Performance Work Statement, para 1.5.15, Health Requirements. Quote: The contractor shall ensure MSS personnel are immunized annually with the seasonal influenza vaccine and any other vaccine recommended by the Advisory Committee on Immunization Practices (ACIP) of the Centers for Disease Control (CDC) for health care workers or service/MTF specific requirements.

Reference: Draft RFP, Performance Work Statement, para 1.5.15.1, Annual Immunizations. Quote: The contractor shall ensure MSS personnel are immunized annually with the seasonal influenza vaccine and any other vaccine recommended by the Advisory Committee on Immunization Practices (ACIP) of the Centers for Disease Control (CDC) for health care workers or service/MTF specific requirements.

Reference: Draft RFP, Performance Work Statement, para 1.5.15.1.2 – Tuberculosis. Quote: In those areas where there is a high risk of transmission of tuberculosis, MTF policy may direct MSS personnel to be tested more frequently at no cost to the Government.

Concern: ACIP and CDC recommendations include many considerations for special populations and/or individual health situations. In some cases, this necessitates an in- depth knowledge and/or review of a personal medical history to make a medical determination of whether a vaccination is required and/or recommended for a specific individual. This raises several concerns for the contractors and/or applicants during this pre-hire phase of the process including: 1) Cost. This is a significant and potentially large unknown. We have seen costs as high as $800 for an individual needing a full complement of vaccines not to include additional tests such as a physical exam and/or additional TB testing. 2) Time constraints – an applicant who may require the full complement of vaccines must take them in order and cannot take them simultaneously (may need as much as 30 days between types of shots and/or doses) limiting the ability to complete prior to placement and 3) Applicants who are currently unemployed may not have access to regular medical care and/or a primary care physician knowledgeable about their health and therefore lack the ability to properly advise the patient on the safety of obtaining all vaccines.

Suggestion: 1. Recommend the Government consider a program to provide vaccinations for contractors based on: 1) Cost – contractors will be forced to include a “risk” amount to each position and location in order to assist those applicants without the means to obtain prior to placement thereby inflating pricing for all positions unnecessarily 2) Public Health resources within the MTF are qualified and current with the latest CDC and/or military/service guidelines and are the most qualified to assist the applicant with medical decision making determinations. 2. Recommend allowing for this to be an ODC cost bid at the TO level based on the specific requirements of the position, location and listed in the PWS.

Government Response: The pre-placement immunization and health requirements will remain. Due to the non-personal nature of the requirements, the Government should not provide such immunizations or bear the burden of making workers qualified to work in the MTFs. Therefore, the offerors should consider all associated cost and risk in their pricing whether at contract level or task order level.

36. 3.2 PWS pgs 100-267, Introduction/General Information Sections 1-1.28, Reference: Draft RFP, Performance Work Statement, para 1.6.1.5 pg 106. Quote: Review, revise as needed and resubmit to the government annually.

Concern/Question/Suggestion: Can the Government please clarify that the contractor is to provide the Government with an updated QCP annually?

Government Response: Per Part I, Paragraph 1.6.1 – the task order level Quality Control Plan deliverable should be updated at least annually on the anniversary of the order unless otherwise stated in the task order. The Government will accept the QCP in writing within 30 calendar days of receipt.

37. 3.2 PWS pgs 100-267, Introduction/General Information Sections 1-1.28, Reference: PWS Section 1.8 – 1.8.4 – Security Investigation Requirements. Quote: MSS personnel will not be able to begin physical performance at the location until the required forms have been completed, accepted by the Government and forwarded to the office of primary responsibility AND the fingerprints have cleared the initial review OR full adjudication of the security investigation is complete.

Concern/Suggestion: Due to the wide variation of requirements of the services and/or MTF location and time to complete, suggest that this be tied to the time to fill requirements.

Concern/ Suggestion: While contractors may perform due diligence with an independent background check to identify potential areas of concern, we are forbidden from discriminating against those with a criminal history therefore cannot make the determination to remove the candidate from consideration and/or submit for consideration based on this information alone.

Government Response: The Government recognizes the variation by performance location for security. Therefore, Per Part I, Paragraph 1.8.1 - The task order will outline the local security requirements and procedures for contractor consideration. Because the ordering process also determined the time allotted to fill positions/services, it is our expectation that lengthy process at the local level have considered that in the fill window established at the task order level.

38. 3.2 PWS pgs 100-267, Introduction/General Information Sections 1-1.28, Reference: Draft RFP, Performance Work Statement, para 1.9. Quote: The contractor agrees to attend any post award conference convened by the procuring contracting office IAW Federal Acquisition Regulation Subpart 42.5.

Concern/Question/Suggestion: If requested by the Task Order Contracting Officer would a site level Post Award Conference be billable to the Government?

Government Response: Per Part I, Paragraph 1.10 - Task Order Post Award Meetings are authorized and shall be detailed in the task order proposal request package and will be scheduled no more than 10 calendar days after task order award and will be conducted within 30 calendar days from contract award. Therefore, billable status of such task order level requirements will be identified during the order process.

39. 3.2 PWS pgs 100-267, Introduction/General Information Sections 1-1.28, Reference: Draft RFP, Performance Work Statement, para 1.13. Quote: Task Order Participation: The Government expects maximum participation and competition for task order proposal requests under this contract. Contract holders are required to submit a competitive proposal for no less than 85 percent of the task order proposal request packages received with valid and funded requirements.

Concern/Question/Suggestion: We understand that this contract allows additional labor categories, if necessary, after initial award. However, when new labor categories are added, not all Contractors are able to effectively recruit and place for the new labor category. Would the Government consider not including TOPRs for new labor categories in the 85% requirement.

Government Response: The Government will take that into consideration and decision will be in the final RFP.

40. 3.3 Definitions & Acronyms 2-2.2, Reference: Draft RFP, Definitions & Acronyms, para 2.1.18, pg 113. Quote: FULL-TIME EQUIVALENT – The ratio of the required number of hours the MSS personnel should perform in a 12-month period. The hours can be 1880, 1920, 2000 or 2080 as defined in the task orders.

Concern/question/Suggestion: With the recent Executive Order, contractors will be required to provide employees with an additional 56 hours of paid sick leave. With this requirement in mind, will the Government provide clarification on the total hours for a Full Time Equivalent?

Government Response: The number of productive hours needed by the Government are identified at task order level during the ordering process.

41. 3.4 PWS pgs 100-267, Specific Tasks 5-5.3.5, Reference: Draft RFP, Performance Work Statement, para 5.1.3. Quote: (The Contractor must ensure)…A clear business process to perform at least 50 percent of the overall services annually.

Concern/Question/Suggestion: Is the 50% calculated by the dollar value or by the number of FTEs?

Government Response: FAR 52.219-14, Limitations on Subcontracting is applicable to services and is based on cost of contract performance.

42. 3.4 PWS pgs 100-267, Specific Tasks 5-5.3.5, Reference: Draft RFP, Medical Coding and Auditing Services, Statement pf Objectives, para 5.a. Performance Outcomes. Quote: Ensure contractor coding representation from each MTF at the annual Uniform Business Office/Unified Biostatistical Utility (UBO/UBU) conference in accordance with DoD requirements.

Concern/Question/Suggestion: Can the Government please clarify if the Uniform Business Office/Unified Biostatistical Utility (UBO/UBU) conference still occurs?

Government Response: This conference is not held as frequently as was done in the past.

43. 3.5 PWS pgs 100-267, Technical Exhibit (Job Descriptions) Section 8, Reference: Page 158, 1.3 Outpatient Medical Coder Job Description. Quote: Experience. A minimum of three year experience in the outpatient setting (physician’s office or ambulatory surgery centers) within the last five years, including assignment of E&M, CPT, and HCPCS codes. Multiple specialties encompass different medical specialties (i.e. Family Practice, Pediatrics, Gastroenterology, OB/GYN, etc.) that utilize ICD, E&M, CPT, and HCPCS codes. Ancillary specialties (PT/OT, Radiology, Lab, Nutrition, etc.) that usually do NOT use E&M codes do not count as qualifying experience. Additionally, coding, auditing and training exclusively for specialties such as home health, skilled nursing facilities, and rehabilitation care will not be considered as qualifying experience. Coding experience limited to making codes conform to specific payer requirements for the business office (insurance billing, accounts receivable) is not a qualifying factor. Two years of outpatient/ambulatory surgery experience may be qualifying if received in a military medical facility.

Concern/Question/Suggestion: This past year we have had 13 of 15 Equivalency Determinations (ED) approved. Of those 13 approved, 11 were for lack of experience. The ED process lengthens the time involved in placing a candidate. If a qualified certification is in place which proves the theory and application of coding, would you consider lowering the experience requirement in the actual job description for Outpatient Medical Coders?

Government Response: While the standard position descriptions will be available in the DHA MSS contracts, they will be tailored at the task order level during the ordering process. This enables the ordering location to consider specific workload requirements, accuracy needs and market availability for that geographic location.

44. 3.5 PWS pgs 100-267, Technical Exhibit (Job Descriptions) Section 8, Reference: Page 226, Job Description, Medical Coding Compliance Specialist (AFMOA Only), para 1.3.1.1 and para 1.3.2.1.

Quotes: 1.3.1.1. A minimum of ten years of medical coding experience within the past ten years, in more than 4 medical and surgical specialties. A minimum of two years of inpatient facility coding experience must be included in the required ten years of experience. A minimum of two years of ambulatory surgery facility coding experience must be included in the required ten years of experience. Multiple specialties encompass different medical specialties (i.e. Family Practice, Pediatrics, Gastroenterology, OB/GYN, etc.) that utilize ICD, E&M, CPT, and HCPCS codes. Ancillary specialties (PT/OT, Radiology, Lab, Nutrition, etc.) that usually do NOT use E&M codes do not count as qualifying experience. Additionally, coding, auditing and training exclusively for specialties such as home health, skilled nursing facilities, and rehabilitation care will not be considered as qualifying experience. Coding experience limited to making codes conform to specific payer requirements for the business office (insurance billing, accounts receivable) is not a qualifying factor.

1.3.2.1 - minimum of four years of auditing, training, and/or compliance functions within the last ten years is required.

Concern/Question/Suggestion: 1.3.1.1 - Instead of ten (10) years’ experience within the past ten (10), please consider ten (10) years’ experience within the past 15 years and instead of requiring two (2) years’ experience in ambulatory surgery facility coding and two (2) years’ experience in inpatient facility coding, please consider and/or

In Section 1.3.2.1 – Instead of four (4) years’ auditing, training and compliance functions, please consider two (2) years.

Both requests are based on the proven ability to find strong, qualified candidates with lessor experience. In the civilian sector this type of job description would equal that of a Management position. The current job description is compounding an already tough and depleted workforce market. The government is marketing itself out of the competition for qualified candidates that can perform the actual day to day duties of this position. And, to add to this, an Equivalency Determination (ED) is not always the answer because of the time restraints built into the response time (7 days).

Government Response: See response to #43.

45. 3.5 PWS pgs 100-267, Technical Exhibit (Job Descriptions) Section 8, Reference: Page 232, 1.2 Education/Certification for Medical Coding Modernization Specialist Job Description.

Quote: 1.2.1. Successful completion of academic requirements, at least at an associate's degree level from a health information management program is required.

1.2.2. A Registered Health Information Technician (RHIT) or equivalent certification is required.

1.2.2.1. Other coding certifications may be considered but will require Government acceptance in accordance with the Equivalency Determination Request process outlined in Section H.3.f.(3) of the main contract.

Concern/Question/Suggestion: After pooling information from the Modernization Study Coding Compliance Specialists (MSSCS) (6), all are performing the same work as required for the Medical Coding Modernization Specialist (MCMS). Our recommendation is to utilize the job description for the MSSCS for all positions such as this with the exception of those at AFMOA. The MCMS have all required Equivalency Determinations due to the strict criteria requiring RHIT or equivalent and at least an associate's degree. It is proven that a CPC with no degree can perform this job above expectations. Please consider loosening the educational criteria and type of certification for the MCMS if it remains an applicable job description.

Government Response: See response to #43.

46. 3.5 PWS pgs 100-267, Technical Exhibit (Job Descriptions) Section 8, Reference: Technical Exhibit 4 – Pg 248 of 267 – Referral Management Services. Quote: A complete referral is defined as a provider-generated referral that has been sent either to MTF or network for the specialty care AND the initial referral result have been received and documented in Composite Health Care System (CHCS) to close the referral in the computer system OR two attempts to request/retrieve the referral results with a 10-day waiting period between requests a 60 calendar day period following the patient’s final medical encounter authorized on the referral is complete.

Concern: Incomplete direction of the timeline. ….with a 10 day waiting period between requests a 60 day calendar day period? Within a 60 day period? After 60 days following?

Concern: Phase In / Phase Out - Based on the above definition of a completed referral, a new contractor will not complete any referrals in the beginning days of performance. Similarly, they would not receive credit for referrals initiated and not completed at the end of the performance period.

Suggestion: Phase In / Phase Out - Based on the above definition of a completed referral, a new contractor will not complete any referrals in the beginning days of performance. Similarly, they would not receive credit for referrals initiated and not completed at the end of the performance period.

Government Response: For Service Type II orders, the performance location will provide workload history which should include pending referrals partially through the process as billable units.

Concern: In some instances based on specific clinic protocols, clerks are required to conduct multiple searches of provider(s) and/or teams of providers to secure an appointment. These protocols significantly increase call/talk time and result in 1) longer talk times affecting service availability and 2) workload which would support multiple transactions. For example, a clerk who is required to survey multiple providers and/or teams to secure an appointment would record, “No appointment available” on the first search before conducting the second search where they may find an appointment and book it. This should be considered two billable transactions due to the necessary steps, time and the definition of a billable transaction however it occurred during a single phone call allowing only one disposition of the call through the ACD system. Additional reports are available to properly account for this workload.

Suggestion: Allow additional flexibility to define the accounting of transactions at the MTF level based upon the resources in use such as the Automated Call Distribution (ACD) system and other system reports which reflect the actual workload and/or time considerations when following clinic protocols.

From our extensive experience in providing Patient Appointing Services, we have learned that regardless of efforts to filter unbillable calls through the phone tree, the appointing center still receives a large number of calls not meeting the above definition. However, these calls are still required to be answered and often times can have an impact on providing the required service levels. Would the Government consider allowing the Contractor to bill for all incoming calls regardless of whether they result in an appointment or documentation that an appointment is not available.

Government Response: No, task order proposal requests will identify the workload for Service Type II orders. Part of the package must include the MTF ordering protocols for offeror consideration of the MTF’s standard operating procedures and expectations to secure a viable appointment for the caller. Since you will price workload and risks of extra steps during the ordering process, offerors should take all information into consideration when developing their unit rates.

48. 3.5 PWS pgs 100-267, Technical Exhibit (Job Descriptions) Section 8, Reference: Technical Exhibit 4 – pg 241 of 267 – Medical Coding and Auditing Service. Quote: A complete, coded medical encounter is defined as an encounter with signed supporting documentation, that was coded according to rules as defined by AFMS, DoD, and current coding classification systems. Other coding related fields are to be included (modifiers, units of service, etc.). These records will be annotated in the Government computer systems and flagged as “transmitted completed” or “complete.” Encounters on “hold” are not considered complete. The number of medical encounters to be completed per year will be specified on each task order proposal request.

Concern: The above definition may require reliance on outside sources which the contractor may not control.

Suggestion: 1) Include an alternative status “In Dispute” or “Pending Resolution outside Coder Control” 2) Allow for a time frame in which the coder must document attempts to resolve and close and with that proper documentation, close out the encounter allowing payment for completion. An example is provided in the Referral Management SOO which allows for a referral to be closed after two (2) attempts, ten (10) days apart after sixty (60) days following the patients final medical encounter authorized by the referral.

Suggestion: 3) In an effort to make Service Type II successful for both the government and the contractor, would you consider adding an accompanying job description for Clinical Documentation Improvement Practitioner (CPIP) through AHIMA or Certified Documentation Expert-Outpatient (CDEO) through AAPC. Service Type II coding's success is dependent on the ability to have accurate and complete documentation prior to the record being coded. If the Contractor is not successful, the government program will not be successful. This Documentation Improvement Specialist positions could streamline and mitigate ongoing documentation issues hindering a successful Type II coding venue.

Per AHIMA to sit for the CDIP (Clinical Documentation Improvement Practitioner) one must meet one of the eligibility requirements below:

An RHIA®, RHIT®, CCS®, CCS-P®, RN, MD or DO and two (2) years' experience in clinical documentation improvement

An Associate’s degree or higher and three (3) years of experience in clinical documentation improvement (candidates must also have completed coursework in Medical Terminology and Anatomy and Physiology) from http://www.ahima.org/topics/cdi

Per AAPC -

The CDEO credential validates a documentation professional’s expertise in reviewing outpatient documentation for accuracy in the support of coding, quality measures and clinical requirements. CDEO professionals provide feedback to providers to improve clinical documentation and facilitate ongoing documentation improvement to meet all requirements of the medical record. To become a CDEO, documentation professionals must demonstrate knowledge of pathophysiology, coding and billing guidelines, and quality measures.

The Certified Documentation Expert-Outpatient abilities include:

Expertise in reviewing medical documentation for accuracy.

Ability to identify and communicate documentation deficiencies to providers to improve documentation for accurate risk adjustment coding

A sound knowledge of medical coding guidelines and regulations including compliance and reimbursement – allowing a CDEO to understand the impact of coding on payment models.

Knowledge of anatomy, pathophysiology, and medical terminology necessary to correctly code CPT®, ICD-10-CM, and HCPCS Level II.

From https://www.aapc.com/certification/cdeo/

Government Response: Thank you for the information. For Service Type II orders, the offeror will propose in their Statement of Work (based on the Government’s Statement of Objective) the staffing model needed to successfully meet performance standards and task order objectives.

49. 3.6 Attachment 4 DHA Instructions for Contractor Access, Reference: Attach 4 DHA Instructions for Contractor Access, Para III.A.1, para C., para III.H., para III.I.9. Quote: All paragraphs reference duties and requirements for the Contractor Facility Security Officer (FSO).

Concern/Question/Suggestion: Historically, these IDIQ contracts have not required the contractor to have an officially designated FSO as most small companies do not have a cleared facility. Can the Government please clarify whether the Contractor is required to have a cleared facility and to which level? Can the Government also please clarify whether a FSO is required?

Government Response: Thank you for identifying this issue. The Government will make the needed changes in the final RFP.

50. General Questions – Not referenced in Draft RFP.

Concern/Question/Suggestion: When preparing pricing responses for Service Type II TOPRS, it is imperative that accurate calculations for the number of estimated billable transactions be provided. Will the Government please emphasize to the Ordering Contracting Office the importance of accurate estimates in order to avoid claims that may arise as a result of unrealized transactions?

Government Response: The DHA MSS will have a comprehensive ordering guide or portal for ordering locations.

51. General Questions – Not referenced in Draft RFP.

Concern/Question/Suggestion: We've learned from our past experiences on the MASS & MSS, that the 30 day replacement requirement leaves very little time to identify, recruit and place the candidate while meeting the 14 day security appointment and QD submission requirements. In many instances, in order to meet the required deadlines, the Contractor must identify a replacement in only two weeks, often requiring us to accept the first qualified candidate identified versus "the most qualified candidate". We've found this practice contributes to high turnover rates. Although we understand that the replacement timeline will be defined at the task order level for this contract, would the Government consider a longer replacement window of 45 days?

Government Response: Per Part I, Paragraph 5.2.1 & Part 8, Technical Exhibit 1.b, all required timelines will be identified in the individual task order as well as the local security requirements and due dates (Paragraph 1.8.4). Therefore, if questions exist during the ordering process, offerors can seek guidance from the ordering location subject matter experts.

52. General Questions – Not referenced in Draft RFP.

Concern/Question/Suggestion: When the Department of Labor increases labor category rates or Health and Welfare rate, often the Contractor must submit a Price Adjustment to offset these increases. Most contracting offices are very slow in processing these requests. As we have 30 days to submit, would the Government consider including verbiage in the Contract which defines the amount of time that a Contracting office must respond to these requests?

Government Response: Per Part I, Paragraph 1.19 - Applicable wage determinations will be provided at the task order level.