Attachment_1_-_PFS_Public_Comment_SOW.docx

Attachment 1 – Statement of Work

RFQ 191552

Medicare Physician Fee Schedule (PFS) Public Comment Support

Medicare Physician Fee Schedule (PFS) Public Comment Support

Statement of Work

I. Purpose/Background

The purpose of this task order is to provide support services in the development of the PFS proposed and final rules. The Contractor shall triage public comments received in response to the Calendar Year (CY) 2020 and future proposed rules and provide technical assistance where necessary. Due to the tight deadlines and multiple competing priorities during the rulemaking season, having a Contractor fulfill support roles will allow analysts to focus on regulatory and policy matters.

A. General Medicare Physician Fee Schedule Background

Since January 1, 1992, Medicare has paid for physicians’ services under section 1848 of the Act, “Payment for Physicians' Services” through notice and comment rulemaking. The system relies on national relative values that are established for work, practice expense (PE), and malpractice (MP), which are then adjusted for geographic cost variations. These values are multiplied by a conversion factor (CF) to convert the relative value units (RVUs) into payment rates. The concepts and methodology underlying the PFS were enacted as part of the Omnibus Budget Reconciliation Act of 1989 (OBRA ’89) (Pub. L. 101 239, enacted on December 19, 1989), and the Omnibus Budget Reconciliation Act of 1990 (OBRA ’90) (Pub. L. 101 508, enacted on November 5, 1990). The final rule published on November 25, 1991 (56 FR 59502) set forth the first fee schedule used for payment for physicians’ services.

B. Scope

The Contractor shall provide services to the Centers for Medicare & Medicaid Services (CMS) to support the retrieval, review, triage, and summarization of public comments and provide technical assistance in the development of PFS proposed and final rules.

II. Requirements

A. Tasks

Independently and not as an agent of the Government, the Contractor shall furnish all the necessary services, qualified personnel, material, equipment, and facilities, not otherwise provided by the Government, as needed to perform the requirements of this statement of work (SOW) as set forth below. Note: All references to days below are assumed to be calendar days unless specifically noted otherwise.

Task 1. Project Management

1.1 Kickoff Meeting

The Contractor shall participate in an initial in-person kickoff meeting within one week after award of the task order. The intent of this meeting is to discuss the purpose and goals of the project, scope of work, data sources, study methodology, project schedule, project deliverables, project management, and other issues as needed.

1.2 Periodic Status Calls

The Contractor shall arrange for periodic status calls with the Contracting Officer’s Representative (COR) to discuss work activities, timelines, and any concerns or problems. These meetings shall occur on a biweekly basis and last approximately one hour. During peak periods, CMS may require additional ad-hoc meetings, up to ten additional meetings annually, which should also last approximately one hour.

1.3 – Monthly Progress & Financial (PF) Report The contractor shall provide a monthly PF report to ensure that the expenditure of resources is consistent with and shall ensure successful completion of all tasks within projected cost and schedule limitations. At a minimum, the reports will include:

· A full report of the contractor’s activities (may be contained in the Monthly Progress Report);

· Summary of costs incurred during the previous month;

· Cumulative costs incurred to date;

· Funds remaining to be incurred;

· Itemization of Travel incurred;

· A narrative report of expenditures that exceed 10% either above or below the estimated expenditures for the period of time that is being reported;

· Report of any continuous quality/improvement activities and findings (may be contained in the Monthly Progress Report);

· Any challenges or risks associated with the administration of the contract (may be contained in the Monthly Progress Report); and

· Provide any ad-hoc cost reports or presentation for management as requested by CMS.

The contractor shall submit the report to the COR, Contracting Officer (CO), and Contract Specialist (CS) within 15 calendar days of the month following the performance.

1.4 Quarterly Progress Report (QPR)

The Contractor shall provide a quarterly progress report to the COR, CO, and CS within 15 calendar days after the close of the quarter. An electronic copy of the QPR shall be provided to each of these individuals. At a minimum, such reports shall cover the following items:

-- Activities during the quarter (problems encountered and potential future problems, actual and possible delay in deliverables, etc.).

-- Activities planned for the forthcoming quarter.

-- Contractor expectations of the COR or other CMS staff during the forthcoming quarter (e.g., review of deliverables submitted, delivery of data, analytic programs or other items).

-- Data on planned versus actual expenditures by major Task area (discrepancies greater than ten percent shall be noted).

-- Review accomplishments to date, remaining activities to be completed and the status of the project compared with the delivery schedule;

-- Discuss significant problems encountered or that are anticipated and their impact on the project schedule, or if severe enough, on the overall ability to accomplish the project’s goals;

-- Include the Contractor’s plans to address or resolve any identified, significant problem(s) and, if appropriate, new delivery or completion dates shall be proposed and revised resource estimates included;

-- Include data on planned versus actual expenditures by major task area (discrepancies greater than 10 percent shall be noted);

1.5 Quality Assurance Plan

The contractor shall provide quality assurance (QA) for work produced for this SOW in accordance with the current version of the Quarterly Quality Assessment, as produced by the COR.

1.5.1 Quality Assessments

Upon completion of each fiscal quarter, the contractor shall conduct a quality assessment for each task to ascertain the overall quality of the contractor’s work. The initial quality assessment for a project is conducted after it has been active for at least 2 months. The final quality assessment is conducted at the end of the fiscal quarter during which a project is completed.

1.6 Project Value Summary

The contractor shall provide CMS with quarterly assessments of the contractor’s performance. To satisfy this requirement, the contractor shall create and update a Project Value Summary (PVS) summarizing the purpose, outcomes, and value delivered by the project.

Task 2. Project Work Plan

The Contractor shall develop and submit a draft project work plan within 10 days after award. The project work plan shall, at a minimum, discuss in detail the data (collection and/or acquisition) and methodology to be used for each task and will include the project timetable for tasks and deliverables. If no COR comments are received within five business days, the draft work plan shall become final. If COR comments are received, the Contractor shall revise the plan accordingly and submit the final work plan within 10 business days of receipt of COR comments. The work plan shall be revised as necessary based on major changes. A major change is something that alters the work plan by 30 calendar days or more.

Task 3. Public Comment Triage Support

Public comments on the proposed rule are expected to be received from June through mid-September of each year. The Contractor shall identify, review, and provide a summary of every individual comment received using a comment tracker log, including all topic(s) addressed, specific down to the issue and Current Procedural Terminology (CPT) Healthcare Common Procedure Coding System (HCPCS) CPT/HCPCS code number, as defined by CMS. The Contractor shall also identify whether each individual comment is a form letter and whether each individual comment is submitted by a major stakeholder (identified by CMS).

The Contractor shall quantify the number of comments received for each subject matter area, as defined by CMS. The Contractor shall submit to CMS granular comment log reports and usable summaries of comments, as specified by CMS, on a rolling basis throughout the public comment period.

The Contractor shall provide daily and weekly reports on status of comment triage and comment summary to the COR.

In addition, the Contractor shall submit reports including granular comment log reports and usable summaries:

a. Once per week for the first 6 weeks of the public comment period;

b. Once per day during the final 2 weeks of the comment period through completion of triage of all comments received;

c. 3 business days after close of the public comment period for the priority/major stakeholders (as defined by CMS) which will attribute to the majority of comment volume;

d. 3 business days after close of the public comment period for all comments received; and

e. Upon CMS request.

At a minimum, such reports shall include the following information:

a. The number of comments received and triaged that day or week,

b. Total number of comments received and triaged to date,

c. The number of comments received for each subject matter area, and

d. Granular comment log reports and usable summaries of comments received.

The Contractor shall complete review and summarization of all comments received during the public comment period within 3 business days, but no later than 5 business days (or timeframe agreed upon by CMS and the Contractor) after the close of the public comment period.

Task 4. Quality Check (Preamble Text and Regulations Text)

The Contractor shall provide a thorough review of preamble text and regulations text for spelling, grammar, formatting, and correct references and citations, along with accurate nomenclature (CPT code, HCPCS code, etc.), and appropriateness of response (including tone/sentiment) to public commenters. Review shall be completed no later than 2 business days after each document is received.

Task 5. Quality Check (Sub-Regulatory Documents and Roll-Out Documents)

The Contractor shall review existing CMS publications and sub-regulatory guidance (such as: Internet-Only Manuals (IOMs), frequently asked questions documents, Medicare Learning Network publications, and CMS websites) and identify any documents that may need to be updated due to recent policy changes.

The Contractor shall review documents (such as: roll out documents, press releases, fact sheets, internal question and answers) developed by CMS to ensure that new policy changes are described consistently across all documents, Reviews shall be completed no later than 5 business day after each document is received, or as specified by CMS.

Task 6. Resource Box and Roll-Out Documents Support

The Contractor shall manage a CMS resource mailbox for processing, tracking, and responding to incoming inquiries. The Contractor shall develop a process to:

1. Identify the subject(s) addressed in each incoming inquiry,

2. Submit each inquiry to appropriate CMS staff and subject matter experts (SMEs) (both internal and external to DPS),

3. Receive draft responses from SMEs, and

4. Send responses to the entity that submitted the inquiries via the resource box.

The Contractor shall work with CMS subject matter experts (SMEs) to identify frequently asked questions received through the resource mailbox, and to develop base internal QA documents and other related roll-out/educational materials for proposed and final rules. Additionally, the Contractor shall provide note taking and logistic support as requested by CMS staff to support roll-out of proposed and final rules, and stakeholder meetings and events.

Task 7. Transition Plan

The Contractor shall adhere to the minimum requirements set forth in this section for transitioning workloads to another Contractor at the close of the contract. The Contractor and incoming Contractors shall actively participate in all Medicare PFS Contractor transition activities, including all required meetings, during the transition period.

A. Transition-Out

During performance of this contract should termination or non-renewal of contract occur, or at the end of the final option period, CMS may require the Contractor to provide transition services beginning at the earliest mutually agreeable date. During this period, the Contractor shall work with the new contractor (successor) to establish and sign a Joint Operating Agreement (JOA). The JOA shall be established within 10 calendar days of award. The purpose of the JOA is to establish a process for managing the workload while both task orders are in place and to establish a process for fully transitioning the workload from the incumbent contractor. The JOA shall illustrate the manner in which the two entities will maintain support during the transition of the work from the incumbent, including methods that will be used to communicate and coordinate activities and personnel. The JOA shall also clearly provide distinction between the roles, responsibilities, and functions to be performed by the commercial contractor. The JOA shall be reviewed and approved by CMS.

The Contractor shall work with CMS staff, as well as other identified CMS contractors to ensure continued operation of the Program. Prior to commencement of transition, CMS will request a transition plan from the Contractor. The Transition Plan shall provide adequate coverage to ensure uninterrupted service to the Program, be effectively and efficiently administered, and be completed within a reasonable timeframe. The Contractor shall prepare a Transition Plan for the new contractor to follow as an outline. At a minimum, the Transition Plan shall provide detailed methods that will be used to ensure a smooth transition to the successor contractor.

The Contractor shall cooperate fully with the successor contractor, to ensure that all services continue without interruption and the incumbent contractor can assume that the successor contractor is aware of its roles and responsibilities with regards to transitioning.

III. Deliverables

ITEMS TO BE FURNISHED AND DELIVERABLE SCHEDULE

The Contractor shall submit all required reports and deliverables in accordance with the following schedule. Reports and/or deliverables submitted under this contract shall be in accordance with this Statement of Work.

close of the quarter