LFO LSJ MPMG Tier II Policy Help Desk Redacted.pdf

FEDERAL SUPPLY SCHEDULE LIMITED-SOURCES JUSTIFICATION

Acquisition Title: CCIIO Tier II Policy Help Desk

Agency: Centers for Consumer Information and Insurance Oversight (CCIIO)

Acquisition Year: 2025 (APP 250204)

Authors: Stephanie Bodrick, COR

Cathryn Kim, Contracting Officer

1. Description of Action:

Nature

☐ New Requirement

☒ Follow-On Order

☐ Modification of Existing Purchase Order / Contract Number

Contract Type

☐ Firm-Fixed Price

☒ Time and Materials

☐ Cost Plus Fixed Fee (CPFF)

☐ Term

☐ Completion

☐ Cost Plus Award Fee (CPAF)

☐ Other:

Total Projected Cost / Price:

Funding Source (s): 0511: Federally-Facilitated Exchange_Reimb:Mand

Project#: Funding Source Name:

1955 - Qualified Health Plan (QHP) Management, Oversight

Name of Proposed Vendor(s): LMI Logistics Management Institute Street Address: 7940 Jones Branch Drive

City, State, Zip: Tysons, VA 22102

2. Description of Supplies or Services:

The estimated value of the proposed action, including all options, is:

Base Period:

Transition Out:

The Centers for Medicare & Medicaid Services (CMS) seeks consideration to award a 15-month logical follow-on (LFO) task order consisting of a 12-month Base Year period and a 3-month Transition-Out period with a total potential period of performance of February 9, 2025 through May 8, 2026.

The proposed LFO is for the CCIIO Tier II Policy Help Desk contract GS-00F-0026M, task order 75FCMC20F0011 that was awarded competitively using the GSA Multiple Award Schedule (MAS). The current vendor, Logistics Management

Institute (LMI), provides support services to maintain a Tier II Policy Help desk system and provide operational services to support the full cycle of help desk tickets received from Qualified Health Plan (QHP) issuers, Stand Alone Dental Plan (SADP) issuers, state agencies and other stakeholders as required under the Patient Protection and Affordable Care Act

(PPACA).

To date, has been obligated to the original task order over a five-year contract; a Base Year period with four

(4) Option Year periods.

The current period of performance is:

Base Period: 2/09/2020 – 2/08/2021 Option Period 1: 2/09/2021 – 2/08/2022 Option Period 2: 2/09/2022 – 2/08/2023 Option Period 3: 2/09/2023 – 2/08/2024 Option Period 4: 2/09/2024 – 2/08/2025 Transition Out: 2/09/2025 – 4/08/2025

The proposed LFO period of performance is:

Base period: 2/09/2025 – 2/08/2026 Transition Out: 2/09/2026 – 5/08/2026

Program Background:

The Patient Protection and Affordable Care Act - PPACA (Pub. L. 111–148) was enacted on March 23, 2010 to assist millions of Americans in obtaining affordable health care services and to allow more employers to offer health insurance coverage in a cost-effective manner totheir employees. The Health Care and Education Reconciliation Act of 2010 (Pub.

L. 111–152), which amended and revised several provisions of the PPACA, was enacted on March 30, 2010. We refer to the two statutes collectively as the “PPACA.” The name “Affordable Care Act - ACA” refers to the final, amended version of the law.

CMS is responsible for the management and oversight of the coverage provisions of the PPACA and within CMS, CCIIO oversees this work. CCIIO ensures successful implementation, and adherence to, the specific provisions of the legislation related to private health insurance. CCIIO has promulgated regulations for the establishment and operational practices of the Federally-facilitated Exchange (FFE) and Exchanges in the District of Columbia, States, as well as for the various programs associated with the Exchanges. Section 1311 of the PPACA sets minimum standards for the Exchanges covering key areas of consumer protection. The success of Exchanges and associated programs depends on thecooperation of and coordination with States, health insurance companies, the Federal government and other stakeholders. The QHP certification requirements and processes involve several participants from Federal and State Government, the National Association of Insurance Commissioners (NAIC), and associated consultants with expertise in health policy, clinical practices and applications, and actuarial sciences. Each provides evidence and insight into the certification of individual QHP or SADP issuers and their plan offerings, requiring a high degree of collaboration and information sharing. A State’s Exchange model determines which online system(s) issuers must use to submit their QHP Application, who performs the certification, and who sends certification notifications.

The CCIIO Tier II Policy Help desk support services are crucial to the successful management of the annual Qualified Health Plan (QHP) Certification cycle, providing guidance and assistance for issuers, state agencies, CMS and other stakeholders to resolve issues and questions related to QHP Certification as required by the PPACA program. The QHP and SADP certification cycles are time-sensitive processes and workflows integrated with related, but separate, CCIIO and external functionality and processes. A Logical Follow-On (LFO) to the existing task order is critical to ensure continuity of operations to support required Pre-Certification cycle activities, which lay the foundation for a successful QHP Certification cycle and the successful implementation of two (2) concurrent multi-year technical modernization initiatives that are underway; Marketplace Plan Management System (MPMS) and System for Electronic Rate and Form Filing (SERFF).

Pre-Certification activities include (but not limited to) resolving Tier II Policy Help desk tickets resulting from information provided in the annual QHP Issuers conference, the publishing of the Letter to Issuers, Payment Notices and other certification-related guidance for the up-coming QHP Certification Cycle. In addition, Pre-Certification cycle activities also include onboarding activities to train issuer staff new to the QHP Certification processes and any new issuers or states that have transitioned to a different state model (which requires the issuers and states to use different process submissions and certification requirements based on their new state model). LMI’s Tier II Policy Help Desk subject matter experts established relationship with CCIIO’s subject matter experts ensures seamless integration, routing and resolving tickets between the Tier II Policy Help desk, CMS Tier I Help Desk, other CCIIO Division Help desks and a Salesforce-based system containing issuer-specific communications for QHP Certifications. And as the Marketplace Plan Management Group (MPMG) progresses through development for the Plan Management Modernization (PM Mod) initiative, it is critical that supporting tasks, such as Tier II Help Desk management, sustain an optimal level of efficiency. A LFO maintaining the current level of support will alleviate potential risks (for example: possible disruption during the most important timeframe, significant cost and time in setting up new IT system and compounding workload due to delayed response) that would significantly disrupt continuity of operations dedicated to ensuring the integrity of the QHP Marketplace and pertinent system development.

3. Authority:

☒ ORDER AGAINST FSS: Authority of the Multiple Award Schedule Program, Title III of the Federal Property and

Administrative Services Act of 1949 (41 U.S.C. 251, et seq.); Title 40 U.S.C. 501, Services for Executive Agencies; and Section 803 of the National Defense Authorization Act of 2002 (PL 107-107) and implemented by FAR 8.405-6. Mark the applicable exception and for each discuss how the cited authority applies in accordance with FAR 8.405-6(c)(2)(iv).

☐ An urgent and compelling need exists, and following the procedures would result in unacceptable delays (FAR 8.405-6(a)(1)(i)(A));

☐ Only one source is capable of providing the supplies or services required at the level or quality required because the supplies or services are unique or highly specialized (FAR 8.405-6(a)(i)(B)); or

☒ In the interest of economy and efficiency, the new work is a logical follow-on to an original Federal

Supply Schedule order provided that the original order was placed in accordance with the applicable

Federal Supply Schedule ordering procedures. The original order or BPA must not have been previously issued under sole-source or limited sources procedures (FAR 8.405-6(a)(1)(i)(C)); or

As detailed above, CCIIO requires the continuation of services with Vendor LMI to ensure a seamless continuation of ongoing Tier II Policy Help desk operations through the Pre-Certification cycle activities, the QHP Certification cycle and the implementation of two concurrent multi-year modernization efforts; Marketplace Plan Management System (MPMS) and System for Electronic Rate and Form Filing (SERFF).

CCIIO requires LMI’s ability to quickly adjust its Tier II Policy Help Desk support as needed to reflect quick moving systematic and process changes due to systematic modernization efforts for CCIIO’s on-going multi-year PM Mod initiative which is migrating all systems and applications that support the QHP Certification process into the Health Insurance Oversight System (HIOS) Marketplace Plan Management System (MPMS) module, a new environment of CMS owned tools, data stores and processes. As MPMS implements new review processes and functionality, information in the Tier II Policy Help desk knowledge database must be revised or supplemented with new content to support the successful resolution of Tier II Policy Help desk ticket submissions within the established Service Level

Agreement (SLA) listed in the current contract. All revised and new Tier II ticket responses require CCIIO clearance, which requires a very short timeframe.

NAIC is also scheduled to begin its modernization effort of System for Electronic Rate and Form Filing - SERFF (their SERFF Modernization) during the Fall of 2024 through 2025. This modernization will transform how issuer submit data through SERFF and then electronically forwarded to CCIIO for ingestion into MPMS. The SERFF Modernization effort is expected to increase the number of Tier II Policy Help desk ticket submissions and will also require new (or revised) content for inclusion in the Tier II Policy Help desk knowledge database. LMI’s team of Tier II Policy Help desk subject matter experts have a deep understanding of issuer / state activities and process when using SERFF for issuer data submission and will definitely be a key resource to help CMS bridge the gap between current process and new changes based on the SERFF Modernization effort.

In addition, the current vendor also has unique and detailed knowledge of the ongoing Help Desk support services efforts that cannot be replaced without unknowable amounts of time and additional costs. A break in support to find a different vendor to provide this still needed service will further delay the ongoing implementations. Furthermore, the knowledge and familiarity of working with the CMS SMEs over the last five years cannot be simply replaced. The learning curve required by changing the vendor of this specialized contract support would further delay the overall CMS QHP Certification process.

Furthermore, LMI’s institutional knowledge supports the delivery of high-quality draft messaging that consistently meets CCIIO’s expectations and enables communications to flow through the approval process. And their experience as the CCIIO Tier II Policy Help desk incumbent reflects their SME’s deep understanding of the end-to-end QHP and SADP certification process, which includes submissions and processes of issuer data through the CMS systems and submissions flowing through the System for Electronic Rate and Form Filing (SERFF), an automated system from the National Association of Insurance Commissioners (NAIC).

With a LFO award, LMI can provide continuity of operations and minimize CCIIO’s operational risk by maintaining its comprehensive and high-quality support for Tier II policy in several capabilities: 1) managing-related ticket surges, providing ticketing support for onboarding of issuers and state staff new to QHP Certification process, and triaging ambiguously worded tickets; 2) drafting content to support various types of policy to include support for onboarding content to reflect systematic and process changes; and 3) guidance and process changes to reduce clearance turnaround times. LMI’s excellence in providing these capabilities helps to ensure CCIIO correctly resolves issuers, states and CMS staff’s tickets in a timely manner.

And as CMS CCIIO continues with plan management modernization activities, the goal of integrating MPMS with SERFF will create a potentially unprecedented volume of help desk tickets from both issuers and states – as most of the modernization efforts thus far have largely avoided the SERFF issuers. If a vendor is not familiar with MPMS, SERFF, or the history of the submission process for QHP Applications, they will be unable to streamline the questions to prevent delays in turnaround times. As a result, if a new vendor is awarded this re-compete at the height of CMS’ QHP certifications and is unable to decipher vague inquires or draft effective messaging, then MPMG risks the ability to quickly address volatile issues in a timely manner and compromises the integrity of the overall QHP Certification program.

The months of April through October are historically considered to be critical months, when the QHP Certification period is in peak activity mode and issuers are required to meet mandatory deadlines for CMS to review and certify plans prior to Open Enrollment on November 1st. The Tier II Policy Help Desk plays a key role in the support of QHP Certification, triaging and resolving tickets in a timely manner to ensure success of the Exchanges. The volume of tickets received and supported by the Help Desk is highest each year following the release of the Patient Protection and Affordable Care Act, HHS Notice of Benefit and Payment Parameters (Final Payment Notice) and the Final Letter to Issuers in the Federally-facilitated Exchanges (Final Letter to Issuers). An additional volume increase in tickets is again managed in correlation with the key dates aligned to the QHP Application activities (opening of the submission window, optional early bird submission deadline, initial application submission deadline, and secondary application submission deadline). Specific to 2023 – 2024, the Help Desk facilitated numerous tickets submitted in response to new submission requirements with the implementation of the Marketplace Plan Management System (MPMS). A previous change in submission criterion also witnessed a significant increase in ticket submissions with the mandatory Post-Certification Compliance and Monitoring Program (PCM) relating to the Essential Community Provider (ECP) and Network Adequacy (NA) reporting requirements. Surges in tickets submitted to the Tier II Policy Help Desk are inevitable when there are large-scale updates and changes made to the QHP Certification processes or supporting systems. When issuers do not have their questions addressed in a timely manner, key deadlines are missed which impact the overall process, review, analytics, and certification for plans impacting consumers across the country. This ripple effect makes the mission of CMS CCIIO more difficult to meet key internal goals and deadlines. If a newly awarded vendor does not understand what is required to triage and resolve tickets during key periods of activity, significant delays may occur in plans seeking certification, which may create a larger risk to the entirety of the Open Enrollment process.

For example: Historical data does reflect an issue when a new Vendor was awarded a Help Desk contract. The LMI Tier II Policy Help desk experienced major inconsistencies when the Help desk contract was awarded, which impacted their overall support of QHP Certification process. Upon award, LMI began to experience major issues almost immediately with the way in which the new Vendor provided the data LMI required to develop one of their deliverables

– Weekly Status Reports. After several months of meetings with both Technical teams and CORs, it was finally determined that the software system the new Vendor was using was incompatible with the report version LMI required.

It was later agreed upon by the CORs at that time that LMI would no longer provide this valuable report to CMS CCIIO.

This report in question was a high-level review of the tickets being triaged at each Help Desk level and the assignment volume given to the Tier II Policy Help desk. This information provided CMS CCIIO with visibility into the overall volume of tickets and how they were being assigned.

In addition, the Help desk still continues to rely on the Tier II Policy Help desk to develop, edit and provide subject matter expertise (SME) support as it relates to the nuances of the QHP ecosystem. For example, each year the LMI Tier II Policy Help desk is tasked with reviewing the materials that Help desk uses to make assignment determinations. This involves a heavy level of effort in coordinating among various stakeholders to confirm processes and business flow. Unfortunately, tickets are still consistently being misassigned to the LMI Tier II Help desk queues with the assumption that their team will be able to quickly identify the correct Vendor due to their historical knowledge and rapport with CMS members.

While the Tier II Help desk has continued to support CMS CCIIO in operational success, the volume of tickets being sort through and redirected is incalculable because many remain in CMS’ ServiceNow, which does not allow the Tier II Help desk to track those tickets that were flagged and reassigned correctly in the ServiceNow system. However, the Tier II Help desk can successfully identify those tickets pulled into the Jira Working environment. For example:

tickets were misassigned during 2024 to the Tier II Policy Help desk.

As a result, the Help Desk does continue to improve each day. However, there is a learning curve for all newly awarded Vendors and CMS can not afford to work through similar issues with a new Tier II Help Desk Vendor while trying to successfully complete the implementation of MPMS. We will require Help Desk vendors to successfully complete their assigned tasks in the most cost-efficient and timely manner.

Other Potential Transition Risks

Throughout the entirely of the period of performance, the Tier II Policy Help Desk is continuously reviewing, editing and developing materials to support the entirety of the QHP Certification process. LMI tracks, monitors and makes recommendations on Standard Operating Procedure (SOP) development and refinement to support multiple activities such as: Data Correction Requests (DCRs), Federally-Facilitated Exchange (FFE) Inquiries, Eligibility and Enrollment (EE) Inquiries, public-facing Frequently Asked Questions (FAQs) as well as DCR Instructions. To date, LMI manages over 220 FAQs that have been developed and posted to the public-facing, QHP Website since the inception of this project on behalf of CMS CCIIO. The Tier II Policy Help Desk completes primary Vendor reviews and facilitates all necessary subsequent reviews, to include LMI SME, other support contractors, CCIIO SME and CCIIO Division Director (or Manager) reviews of all iterations of materials. Additionally, refinement to the materials remains dynamic to account for changes and iterations to new submission processes, systems and tools. If a new vendor is not familiar with the nuances of these various projects, or the documents used to maintain standardization, requirements may be overlooked and projects may not follow the correct workflow; thus, required processes may not be performed correctly until valuable lessons are learned.

In addition, the final versions of Help Desk Ticket reports are provided to various members within CMS CCIIO on a weekly basis by LMI, to include CCIIO SMEs, Managers and Division Directors. These files pull analytical information specific to the intended audience, giving a deeper review into the metrics of topics, issuers and individuals involved with tickets at any given point in time. The information to develop these reports is pulled directly from Jira, ensuring real-time data accuracy. If the new vendor is not familiar with these types of reports and/or how to utilize the functionality of Jira, they will not be unable to relay to CMS personnel the details of the tickets being received, providing potentially inaccurate information to CMS SMEs and Leaders, which may greatly impact further messaging and decision making.

Pending Implementation of LMI’s Innovation and Creativity ideas

LMI has also introduced two (2) key creative ideas that we are currently considering for implementation to enhance our current CMS Policy Help Desk’s tasks. 1. – LMI will complete regular reviews of internal policies with the implementation of a in order to provide CMS CCIIO with optimized operational service support for effective Tier II Policy Help Desk ticket resolutions. With their proposed approach, LMI shall be able to quickly identify and eliminate redundancies, streamline processes and implement automation where appropriate, ultimately enhancing efficiency and productivity across all support teams. This effort will also ensure LMI is aligned with CMS’s best practices, adapting to changing requirements, enhancing efficiency and productivity, mitigating risks, fostering a culture of continuous improvement, optimizing resource allocation and enhancing the overall customer experience, LMI’s is committed to their drive for excellence and success in all aspects of their service delivery efforts. Possible deliverables: An repository of all policies, laws, regulations and other related documents for rapid assessments. In addition, a validated list of dispositions to retire, realign and/or update all policies. 2. - LMI recognizes the power of and has begun adapting it throughout their own organization. LMI has created an internally tools known as and built numerous practical tools around this technology.

Integrating LMI’s into the current platform will allow innovation and modernization opportunities to best support the Tier II Policy Help Desk and continue CMS’ legacy of excellence. It is extremely important for LMI to continue to support CMS’ goals of recognizing the efficiencies and capabilities for inquiry resolutions. The inclusion of will not remove the oversight and approval process built-in the current workflow, but rather allows CMS personnel the comfort and security in knowing that draft responses have been vetted at a higher level of accuracy giving valuable time back to CMS personnel to perform mission critical tasks. LMI understands that CMS believes in the importance of continuous learning and improvement. Encouraging the adoption and implementation of into supporting work within the organization supports innovative improvements in customer service overall to the American public.

A summary of Key points is the following:

• Disruption during important timeframe. The number of tickets is greatest each year after the Payment Notice and Letter to Issuers is released and again when the submission window opens. When there are significant system changes, such as those happening within MPMS, this number increases even more. For PY26, seven (7) review areas are planned to be transitioned into MPMS. It is inevitable that there will be a large uptick in help desk tickets relating to these updates. If issuers’ questions are not resolved quickly, they can miss important deadlines, delaying significant processes, reviews and analytics; making it more difficult for CMS to certify all plans per the prescribed timeline. Any delay in certification or required data products (such are those used to facilitate batch-auto reenrollment) could risk open enrollment opening on time.

• Important to have subject matter experts. When the number of tickets is high, itis important to have a proven system and team in place to be able to triage and answer the questions quickly and accurately. When the Help Desk Vendor is unfamiliar with the subject matter, it is difficult to discern the topic of the question and move the ticket to the appropriate CCIIO or Vendor’s subject matter expert (SME). This results in misallocation of resources creating additional labor hour costs in pursuing the correct path forward for tickets instead of timely responses to issuer and state inquiries. When tickets are assigned incorrectly, this adds unnecessary burden to other vendors, increasing their cost to CMS. LMI also has an established working relationships with the CCIIO SMEs, resulting in optimized communication for rapid ticket resolution.

• Significant cost and effort to stand up a new IT system. A new vendor would be required to stand up a new IT solution for routing tickets. Standing up this system and getting all required CMS and Vendor staff access will take a significant amount of time, effort and resources. Once the system is stood up, as users are adjusting to the processes in new system, there will likely be delays as new processes are adopted and users become familiar with them. LMI has a system and processes already in place, so there would be no ramp-up required during this key timeframe.

• Familiarity with MPMS and SERFF. Within the next few years, MPMS plans to integrate with SERFF, which will cause an extraordinary number of help desk tickets to come through from both issuers and states. Having a vendor who is familiar with both MPMS and SERFF will help streamline these questions and allow for better resolutions with shorter turnaround times.

• Compounding workload due to delayed response. When an issuer or state submits a ticket and does not receive a prompt response, they often ask questions on webinars and submit additional tickets to follow up or ask repeating questions. This increases the workload for the Tier I Help desk, Tier II Help desk and CCIIO and Vendor SMEs which then pass additional cost to CMS.

• Historical information: Prior evidence of disruption due to new Help Desk vendor. The Help desk contract transitioned to a new vendor and when certification began for PY24 several months later, there were still significant problems. Hundreds of tickets were not routed properly and it took weeks for all the tickets to be reviewed and triaged by the Help desk. This all occurred during a critical time and was disruptive to the overall QHP Certification process.

• CCIIO relies heavily on LMI’s understanding of the many components within their ecosystem and the complexity of the routing system to route tickets in time for resolutions that fully resolve a ticket. LMI’s ability to navigate through implicit and explicit complexities is imperative as MPMG develops and deploys PM Mod capabilities for the upcoming plan year.

• LMI is also the existing Vendor to support the Issuer Management Operations and Plan Analytics & Review contract, which performs the QHP Certification reviews, their ability to work Tier II Policy Help desk tickets in conjunction with the certification support is essential to CCIIO successfully executing the QHP Certification cycle on time and with minimal issues as critical components of the MPMS are deployed for the upcoming plan year.

• And per the current re-compete schedule, the base period of the LFO task order will also begin as MPMG opens the QHP submission window for PY26 certification. MPMG is scheduled to deploy a host of essential features for its Marketplace Plan Management System (MPMS) during this same timeframe. In addition, the Tier II Policy Help desk has also historically received a high volume of inquiries during this exact timeframe and the ability to effectively manage tickets from receipt through resolution is key to resolving issues that may otherwise disrupt various aspects of the QHP certification process. If a different vendor is awarded the contract, the new vendor will be required to stand up a new Tier II Policy Help desk ticketing system and quickly transition into the role of service provider, in addition to learning the help desk ecosystem, various QHP Certification policies, guidance and processes during MPMG’s busiest season (Open Enrollment).

• Innovation and Creativity: The pending implementation of LMI’s two (2) key creative ideas that will greatly enhance CMS’ Legacy of Excellence and the quick resolution of Tier II Policy Help Desk tickets

For the reasons listed above, LMI is considered the only source on the GSA Schedule capable of meeting this limited source action requirement and issuing this order to LMI represents the best value consistent with FAR 8.404(d) because it results in the lowest overall cost alternative (considering price, special features, administrative costs, etc.)

to meet CMS’ tasks/mission. LMI has been an above satisfactory performer on the current task order. In addition, the hourly rates for LMI (GS-00F-0026M) have also been determined to be fair and reasonable by GSA under its Federal Supply Schedule contract. In addition, this LFO extension represents the best value to the Federal Government because: 1) it is the least costly approach from an administrative perspective and 2) provides the greatest overall benefit in response to the Help Desk support services requirement. Considering the ability of LMI to meet the needs of CMS at a fair and reasonable price – this logical follow-on extension represents an overall best value to the Federal Government

And we also anticipate the quoted price(s) will be fair and reasonable based on historical costs, market research, published price lists which includes a comparison (and potential discounts) to the Vendor’s GSA Federal Supply Schedule rates.

☐ An item peculiar to one manufacturer can be a particular brand name, product, or a feature of a product, peculiar to one manufacturer). A brand name item, whether available on one or more schedule contracts, is an item peculiar to one manufacturer. (FAR 8.405-6(b);

4. Market Research:

The original GSA task order (75FCMC20F0011) was competed on GSA for all GSA Multiple Award Schedule (MAS) vendors in 2019. GSA has already determined the prices of supplies and fixed price services (and rates for services offered at hourly rates) under schedule contracts to be considered fair and reasonable. Therefore, ordering activities are not required to make a separate determination of fair and reasonable pricing, except for a price evaluation as required by 8.405-2(d).

Since the original award was in accordance with the competitive procedures and based on the inability for another vendor to satisfy the technical requirements in the midst of the on-going implementation efforts while achieving a successful QHP Certification process, it was determined that no further market research was required at this time.

Vendor LMI has a strong track record of providing outstanding Help Desk service with this work. As a result, CMS has high confidence that LMI is still capable of completing this work to ensure successful execution of both the Tier II

Policy Help desk and the Issuer Management Operations and Plan Analytics & Review contracted work. The Contracting Officer will ensure the level of effort, mix of labor proposed and total price is reasonable for the requested modification.

5. Actions to Increase Competition:

Once the logical follow-on is complete, there will no longer be any barriers that lead to the exception to fair opportunity. CCIIO plans to re-compete the task order under the GSA MAS Schedule with an anticipated award at the end of the 12-months of the logical follow-on including the three-month option period.

6. Any other facts supporting the justification: N/A

4. Head of Contracting Activity (HCA) Approval I hereby confirm the circumstances described above apply and approve the Limited Source Justification.

_N/A Name / Date

5. Office of Small and Disadvantaged Business Utilization

6. OGC Legal Review

7. HHS Competition Advocate Approval

8. Senior Procurement Executive (SPE) Approval

Based on the foregoing justification, I hereby confirm the circumstances described above apply and approve the Limited Source Justification.