250269J - JA Limited Source Justification - HEDIS Summary Data.pdf

FEDERAL SUPPLY SCHEDULE LIMITED-SOURCES JUSTIFICATION

Acquisition Title: Healthcare Effectiveness Data and Information Set (HEDIS®) Summary Level Data Collection for Medicare Advantage Agency: Centers for Medicare and Medicaid Services (CMS) Acquisition Year: 2025 Authors: Lauren Popham, Megan Famodu, Dawn Wilkins

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: $3,198,080 Funding Source (s): Project Number 000818

Name of Proposed Contractor(s): National Committee for Quality Assurance (NCQA) Street Address: 1100 13th Street, Suite 1000 NW City, State, Zip: Washington, DC 20005

2. Description of Supplies or Services:

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

Base Period: $599,673 Option Period 1: $619,641 Option Period 2: $639,545 Option Period 3: $659,404 Option Period 4: $679,818 Total: $3,198,080 The Contractor shall provide and maintain an information system and IT infrastructure to collect and support submission of summary-level HEDIS® measures for Medicare Advantage (MA) contracts and generate a database that includes this information for all MA contracts. In addition to providing MA contracts with the data submission tool and instructions with detailed technical specifications for submitting HEDIS® measures, the Contractor must facilitate and provide technical support and assistance to individual MA contracts, as they submit HEDIS® data according to Medicare requirements. The Contractor will be supporting CMS in the collection and management of the annual HEDIS® summary-level data submission files for Medicare Advantage contracts for quality bonus payments and Part C Star Ratings.

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)(1)(i)(B)); or

NCQA owns the proprietary rights to the system that collects HEDIS® data and is the only organization authorized to revise, add, or retire the HEDIS quality measures, and to provide technical assistance to the health plans and NCQA auditors in the collection of these measures. NCQA updates and develops new HEDIS measures by convening a number of interdisciplinary multi-stakeholder panels and groups.

These groups are all widely respected by the managed care industry and have stakeholder representation. Since NCQA develops the measures and makes all of the updates to HEDIS®, it is uniquely qualified to provide the needed technical assistance to health plans and auditors during data collection.

As the organization that maintains and updates HEDIS®, NCQA is the only responsible source for this activity. In 1993, NCQA released HEDIS 2.0 that quickly became the “industry standard” for collecting health plan quality measures. Originally designed for private employers' needs as purchasers of healthcare, HEDIS® has been adapted for use by public purchasers, government compliance monitors, and managed care consumers. All HEDIS® data submission tools and detailed technical specifications are developed and maintained by NCQA. Since 1997, NCQA has been collecting Medicare, Medicaid and commercial HEDIS® results annually from health plans on a nationwide basis.

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

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:

A notice of intent to contract with NCQA on a sole source basis was posted on www.SAM.gov on May 14, 2025. Organizations that wished to challenge the sole source designation were given until May 28, 2025 to respond with a capability statement or other information demonstrating their capability to perform the work.

Vendors were also able to add their names to the Interested Vendors List for this procurement within www.SAM.gov. As of the closing date of the pre-solicitation notice, there were no vendors that expressed an interest in or capability to perform the required services.

5. Actions to Increase Competition:

This action will not be competed. FAR 8.405-6(a)(1)(i)(B) authorizes limiting consideration for a task order to one source when there is only one source that 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. As previously stated, NCQA owns the proprietary rights to the system that collects HEDIS® data and is the only organization authorized to revise, add, or retire the HEDIS quality measures, and to provide technical assistance to the health plans and NCQA auditors in the collection of these measures. Therefore, only NCQA has the necessary capabilities and proprietary rights to successfully perform this work. In accordance with FAR 5.201, CMS posted a notice of intent to contract on a sole source basis with NCQA on the SAM.gov website on May 14, 2025 to see if there are any other organizations that had an interest in this work or believed they were capable of performing the work. CMS received no challenges to the sole source nature of this requirement, and no vendors expressed an interest in or capability to perform the required services.

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

Approvals:

1. Program Office Certification: This is to certify that portions of this justification have been developed by the undersigned program office personnel, including supporting information and/or data verifying the Government’s minimum needs, schedule requirements and other rationale, which form the basis for this Limited Source Justification.

Lauren Popham, Contracting Officer’s Representative (COR) / Date

Sarah Gaillot, Program/Project Manager (P/PM) / Date

2. Contracting Officer Certification and Best Value Determination:

This is to certify that the justification for the proposed acquisition has been reviewed and that to the best of my knowledge and belief, the information and/or data provided to support the rationale and recommendation for approval, is accurate and complete.

By my signature below, after review of the relevant documents, I have determined that the order subject to this Limited-Sources Justification represents the best value for the Government as set forth in FAR 8.404(d), and constitutes a fair and reasonable price. The basis for my determination is as follows:

NCQA has developed, continually updated, and annually collected the HEDIS® performance measurement set for CMS for 28 years. Since 1997, NCQA has been collecting Medicare, Medicaid and commercial HEDIS® results annually from health plans on a nationwide basis. The acronym “HEDIS®” is a registered trademark of NCQA and is a brand name for a set of quality performance measures in managed care, that has become the industry standard in measuring the healthcare quality for health plans. It is essential for the Agency to award this contract noncompetitively to NCQA to continue the summary-level data collection and management of the annual Healthcare Effectiveness Data and Information Set (HEDIS ) submission for Medicare Advantage Organizations (MAOs). As the industry leader in quality assessment and reporting for managed care organizations, as well as the current CMS contractor, NCQA is uniquely situated to provide this continued service to CMS.

Dawn R. Wilkins / Date

I hereby confirm the circumstances described above apply and approve the Limited Source Justification.

Mohammed Islam - DMMC Director / Date

LAUREN E. POPHAM -S Digitally signed by LAUREN E. POPHAM -S Date: 2025.06.06 19:53:07 -04'00'

Sarah J. Gaillot -S Digitally signed by Sarah J. Gaillot -S Date: 2025.06.09 11:11:55 -04'00'

Dawn R. Wilkins -S Digitally signed by Dawn R. Wilkins -S Date: 2025.06.09 12:33:55 -04'00'

Mohammed T. Islam -S Digitally signed by Mohammed T. Islam -S Date: 2025.06.10 08:04:49 -04'00'

I hereby confirm the circumstances described above apply and approve the Limited Source Justification.

Adrienne Holsey – Acting MSCG Group Director / Date

3. CMS Competition Advocate Approval I hereby confirm the circumstances described above apply and approve the Limited Source Justification.

Don Knode – CMS Competition Advocate / Date

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

N/A – Cumulative total is less than $15M Name / Date

5. Office of Small and Disadvantaged Business Utilization

N/A – Cumulative total is less than $15M Name / Date

6. OGC Legal Review

N/A – Cumulative total is less than $15M Name / Date

7. HHS Competition Advocate Approval

06/11/2025

N/A – Cumulative total is less than $15M Name / Date

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.

N/A – Cumulative total is less than $15M

Name / Date