250282_Data Modeling and Analysis Sources Sought Notice.pdf

Sources Sought Notice (SSN) 250282 Centers for Consumer Information and Insurance Oversight Data Modeling and Analysis

THIS IS NOT A FORMAL REQUEST FOR PROPOSAL (RFP) AND DOES NOT COMMIT THE

CENTERS FOR MEDICARE & MEDICAID SERVICES (CMS) TO AWARD A CONTRACT

NOW OR IN THE FUTURE

This is a SOURCES SOUGHT NOTICE (Notice) issued for the purpose of planning and performing market research. The purpose of this Notice is to determine the availability of small businesses (e.g., 8(a), Service- Disabled Veteran Owned Small Business, HUBZone Small Business, Small Disadvantaged Business, Veteran-Owned Small Business, and Women-Owned Small Business) on the General Services Administration (GSA) Multiple Award Schedule (MAS), Category 541611 Management and Financial Consulting, Acquisition and Grants Management Support, and Business Program and Project Management Services or 541990 All Other Professional, Scientific and Technical Services that have the capability to support CMS in maintaining minimum standards for ensuring that all Marketplaces will be competitive and serve the interests of individuals and small businesses by developing tools and models and conducting various analyses.

No reimbursement will be made for any costs associated with providing information in response to this Notice. Respondents will not be notified of the results of the capability assessment. All information submitted in response to this Notice must arrive on or before the closing date for responses.

The information gathered from this market research will help the Government determine an appropriate acquisition strategy, including whether a small business set-aside is possible. Interested contractors must submit a capability statement to demonstrate their ability to perform the requirements stated below.

A. General Background

The Patient Protection and Affordable Care Act (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 to their employees. The Health Care and Education Reconciliation Act of 2010 (Pub. L. 111–152), which amended and revised several provisions of the Patient Protection and Affordable Care Act, was enacted on March 30, 2010. We refer to the two statutes collectively as the Patient Protection and Affordable Care Act or the “PPACA.”

CMS, and specifically, the Centers for Consumer Information and Insurance Oversight (CCIIO), is broadly responsible for the Exchange, or Marketplace, implementation. CCIIO has promulgated regulations for the establishment and practices of Marketplaces in the District of Columbia, States, as well as for the various programs associated with the Marketplaces. Section 1311 of the Affordable Care Act (ACA) sets minimum standards for the Marketplace covering key areas of consumer protection. These standards help ensure that all Marketplaces will be competitive and serve the interests of individuals and small businesses. By pooling people together, reducing transaction costs, and increasing transparency, Marketplaces create more efficient and competitive health insurance markets for individuals and small employers. CCIIO requires support to conduct various analyses pertaining to Actuarial Value, Risk

Adjustment, Risk Corridor, Standard Population, User Fees, Cost Sharing Reductions, etc.

CMS seeks the services of a qualified vendor to support certain analytical and financial management functions of the Marketplace, which will help to ensure the financial sustainability of the health insurance exchanges created by the PPACA. Work contemplated to be performed includes actuarial services, projecting changes in insurance market composition, premiums, subsidies, behavior, as well as simulating the effects of policy decisions and setting payment parameters. Key technical aspects of the work include:

Actuarial Value Calculator: The Essential Health Benefits, Actuarial Value, and Accreditation final rule (EHB Final Rule) that was published in the Federal Register at 78 FR 12834 on February 25, 2013, requires the Department of Health and Human Services (HHS) to use an Actuarial Value (AV) Calculator for issuers of non-grandfathered health insurance plans offered in the individual and small group markets, both inside and outside of the Affordable Insurance Exchanges (also called “Exchanges”) for the purposes of determining levels of coverage.

Section 1302(d)(2)(A) of the PPACA stipulates that actuarial value (AV) be calculated based on the provision of essential health benefits (EHB) to a standard population. The AV Calculator represents an empirical estimate of the AV calculated in a manner that provides a close approximation to the actual average spending by a wide range of consumers in a standard population.

The standard population used in the AV Calculator uses a representative population of individuals under age 65 who generally participate in the individual or small group private health insurance market. A standard population represents a projection of those who are expected to participate in the individual market and the small group market. Potential assumptions for a standard population used to define AV include demographics and health risk profile, average utilization, standard unit prices, and other factors.

State Based AV Calculator: Under 45 CFR 156.135(d) and (e), states have the option to submit state-specific data that, if approved by HHS, can be used as the standard population in a state-specific AV Calculator for a given benefit year.

Essential Health Benefits (EHB) Analysis: Involves the performance of various actuarial analyses related to health insurance benefits and plan designs as dictated by current policy and research needs. Using CMS-provided data sources as well as third party data sources where appropriate, this task will focus on EHB analyses on topics such as prescription drugs, pediatric dental benefits, and benchmark plans, exploring questions on cost of care, pricing, utilization, and actuarial value.

Summary of Benefits and Coverage Calculator: Section 2715 of the Public Health Services Act, as added by the PPACA, directs the Departments of Labor, HHS, and the Treasury (the Departments) to develop standards for use by a group health plan and a health insurance issuer offering group or individual health insurance coverage in compiling and providing a summary of benefits and coverage (SBC) that ‘accurately describes the benefits and coverage under the applicable plan or coverage.’ The SBC calculator provides an estimated out of pocket cost for individual market policy.

Ad-Hoc Analysis: Involves the performance of various actuarial analyses, evaluations, options development and strategic guidance for CCIIO leadership. The nature of this task is variable and there may be fluctuations in workload due to policy changes or other circumstances that impact work request volume as well as the data, systems, and expertise needed to meet those requests.

Examples include but are not limited to:

• Analyses of market behavior to determine potential enrollment impact (e.g. of new policies) on all segments of the health insurance market, such as small groups, large groups, Medicare, Medicaid, individual market, and uninsured population.

• Reviews of 1332 waiver submissions and supplemental ideas for improvement.

• Impact of Health Reimbursement Arrangements (HRA) on risk pools.

• Simulations of the health insurance market in support of research initiatives, e.g., the capability to determine policy impacts to enrollment by income level, geographic area, age, morbidity, claims, premiums, and premium tax credits, etc.

Technical and management support is required for the development and sustainment of the Federal AV calculator, State based AV Calculator, SBC Calculator, all interrelated claims data and analysis in support of these tools as well as ad hoc analyses requested by CMS.

B. Required Knowledge and Experience

The following knowledge and experience are required:

• An understanding of the PPACA as well as related regulations, sub-regulatory guidance, and related CMS policies.

• An understanding of the current CMS Health Insurance Exchanges and the attributes of the different types of Exchanges.

• An understanding of the concepts related to the purpose and determination of actuarial value (AV) for marketplace plans as well as familiarity with the data, methods, and models used calculate actuarial value.

• Experience in delivering actuarial and related technical services in a highly regulated market including the ability to build statistical models and conduct complex simulations and analyses that consider multiple variables related to health care costs across standard populations.

• Experience in developing, implementing, and operating actuarial and statistical tools and services.

• An understanding of Public Health Information (PHI) rules and regulations.

• Experience in working with and supporting a broad range of marketplace stakeholders including health insurers, state-based exchanges, and CMS.

• Experience in effective project management that includes a proven track record of keeping to a schedule and managing multiple tasks.

C. Capability Statement Requirements

In response to this SSN, CMS is seeking capability statements. Capability statements are NOT quotes and do not address price/cost. Industry is merely asked to provide information which may demonstrate that they have expertise and capacity to meet the requirements of this work as a prime contractor, with subcontractors as they deem necessary.

CMS requests that the respondent specifically address the requirements listed below. Respondents should provide enough information for CMS to make an informed determination of their capability to perform the work as identified below. Please remember that the potential offeror or prime contractor must be able to perform at least 50% of the labor associated with this effort. Please provide a list of contract numbers that your organization has had (if applicable) and your role on the contract (prime contractor or subcontractor) per capability statement and in accordance with the instructions in Section C. If you were a subcontractor on a particular contract, please clarify the work that you did on that contract.

Please describe your capabilities and detailed experience performing activities similar to those described below:

1. The capabilities to support all the items listed in Section B. Required Knowledge and Experience.

2. The capability to develop, test, and maintain the Actuarial Value (AV) Calculator or a tool equivalent to it. This includes the capability of building an actuarially appropriate standard population based on analyses and trends of a compilation of healthcare industry claims databases.

3. The capability to develop and maintain the AV Calculator or a tool equivalent to it without conflicts of interest or previous relationships within the past calendar year with potential AV Calculator users, including health insurance issuers to avoid a competitive advantage when designing and pricing plans for the future year.

4. The capability to update and maintain the Summary of Benefits and Coverage (SBC)

Calculator or an equivalent tool. This includes the capability of ensuring that the SBC Calculator is functioning correctly, troubleshooting when required, providing user assistance, updating the underlying data set, and maintaining conformity with HHS supplied current benefits scenarios.

5. The capability to provide varying analysis and evaluations for CCIIO as needed, such as, providing analysis to conduct ad hoc actuarial analyses, analyze market behavior, modeling enrollment and budgetary impacts of proposed 1332 waivers and other state level policy.

6. The capability to support policy development by providing analyses, including cost analyses, of proposed policies. Examples include estimating aggregate premiums and/or medical costs per State and nationally; developing and implementing modeling options to assess market impact of policy proposals.

7. The capability to identify potential Qualified Health Plan (QHP) change indicators by analyses and projections based on issuer Marketplace participation and enrollment trends and other data.

8. The capability to analyze QHP claims data to better understand the enrollee population and how plan design affects enrollment and premiums

9. The capability of providing market analysis. Examples include, estimating the enrollments and premiums in the individual and small group market inside/outside Exchange based on prior years’ effectuated enrollment; estimating the fluctuations in market wide enrollment for respective benefit years for user fee policy and budget exercises.

10. The capability to provide all work products to include analysis reports, meeting minutes, software code and algorithms in a designated software development and collaboration repository within the CMS environment.

D. Instructions for Submitting Responses to CMS

Please submit your response no later than 12:00 pm EST on July 26, 2024 to Tricia Dunchak, Contract Specialist at tricia.dunchak1@cms.hhs.gov and cc: Kelly Housein, Contracting Officer at kelly.housein@cms.hhs.gov in the following format:

• Microsoft Word (or PDF) document with page size 8.5 by 11 inches, with a minimum of 1" margins.

• Times New Roman Font Size 12, with no less than single-spacing between lines.

• Submissions shall not exceed 10 pages. Cover Page is not included in the total page count.

Cover Page

a. DUNS

b. Company Name

c. Company Address

d. Company Point of Contact, Phone, and Email address

e. Current GSA Schedules appropriate to this Notice

Disclaimer and Important Notes

Respondents should be aware that this Notice is for market research purposes only and any responses thereto, or lack thereof, will not constitute a commitment by CMS to treat any potential offeror more or less favorably in the anticipated forthcoming solicitation and/or ultimate award. The Notice does not obligate the Government to award a contract or otherwise pay for the information provided in the response.

Respondents are advised that the Government is under no obligation to acknowledge receipt of the information received and will not respond directly to organizations to provide feedback with respect to any information submitted.

Teaming Arrangements

Contractors responding to this Notice as a team or that rely on subcontractors to perform any portion of the work must include the above-requested information and certifications for each entity on the proposed team or each proposed subcontractor. Responses must clearly indicate the nature of the teaming arrangement.

The contractor and any subcontractors must not have any relationships or arrangements through business operations or its employees that could be considered as lessening the company’s objectivity concerning any aspect of the proposed tasks. If such relationships or arrangements exist, contractors or subcontractors shall be required, during the procurement process, to identify potential conflicts of interest and discuss how the conflicts will be addressed and mitigated.

Similar Situated Entities

Prime contractor respondents must be able to perform at least 50% of the labor associated with this effort, including indirect charges. Provide a list of contract numbers that your organization has had (if applicable) and the role on the contract (prime contractor or subcontractor). If work was performed as a subcontractor on a particular contract, describe the specific work your company performed on that contract. In the event of conflict between FAR clause 52.219-14 and 15 U.S.C. § 657s, for purposes of the limitations on subcontracting, CMS will follow 15 U.S.C. § 657s.

Protection of Privileged or Confidential Commercial or Financial Information

The Freedom of Information Act (FOIA), 5 U.S.C. § 552, provides individuals with a right to access certain mailto:tricia.dunchak1@cms.hhs.gov mailto:malissa.shin@cms.hhs.gov https://uscode.house.gov/view.xhtml?req=(title:5%20section:552%20edition:prelim)%20OR%20(granuleid:USC-prelim-title5-section552)&f=treesort&edition=prelim&num=0&jumpTo=true records in the possession of the Federal government, subject to certain exemptions. Exemption 4 of the FOIA permits information to be withheld that is in the nature of "trade secrets and commercial or financial information obtained from a person and privileged or confidential." The term "person" refers to a wide range of entities, including corporations, banks, state governments, agencies of foreign governments, and Native American tribes or nations, who provide information to the government. Information that does not qualify withholding under the Exemption will be disclosed.

CMS may invoke Executive Order 12600 in accordance with FOIA Regulation 45 C.F.R. § 5.42.

Information provided by entities to CMS in response to this notice may be subject to FOIA disclosure requirements unless protected under Exemption 4 of the FOIA. Should entities wish to protect any trade secret or confidential information under Exemption 4, they should mark their submission accordingly citing applicable redactions and non-disclosure rationale. Pre-disclosure redactions and non-disclosure rationale shall be sent via e-mail to the requesting contracting officer with a copy to the CMS FOIA Office at 12600@cms.hhs.gov.

If an entity’s submission is not marked and CMS receives a FOIA request related to this notice, the CMS Contracting Officer will notify the entity. The entity will have 10 working days to object to the release of any part of their information submitted to CMS citing relevant case law. Final determination on the applicability of Exemption 4 of the FOIA are made on a case-by-case basis by CMS.

The statutory language of the FOIA is codified at 5 U.S.C. § 552(b). Additional information and resources, including the 9 FOIA Exemptions and HHS FOIA Regulation, and examples, can be found on the HHS FOIA Website.

https://www.archives.gov/federal-register/codification/executive-order/12600.html https://www.govinfo.gov/content/pkg/CFR-2019-title45-vol1/xml/CFR-2019-title45-vol1-part5.xml#seqnum5.42 mailto:12600@cms.hhs.gov https://www.cms.gov/Regulations-and-Guidance/Legislation/FOIA https://www.hhs.gov/foia/index.html