Product Strategy - Approved JA FINAL redacted.pdf

The Product Strategy BPA Call provides the following services:

1. Strategic recommendations to the Product Steering Committee and leadership in OIT/AMG regarding the MPSM product suite

2. Collaborates with CMS Product Managers to develop Epics and identify Leading Indicators for Minimum Viable Products.

3. Identifies potential dependencies, risks and blockers and assist with mitigation strategies.

4. Supports prioritization of the Program Backlog.

5. Develops and maintains the Product Roadmap with AMG leadership approval

6. Ensures proper maintenance of the overall product backlog

7. Participates in the Scrum of Scrums meetings.

8. Provides expert product management advice to product managers involved in modernization efforts.

This Limited Source Justification contemplates extending the contract for a period of six (6) months following the end of Option Period 4, using the authority under FAR 52.217-8 Option to Extend Services.

This 6-month period will enable the continuity of operations without a lapse or disruption given the respective value, expertise, and technical skill set of services provided. After the six-month extension, CMS will continue this work using government resources. The following table illustrates the BPA calls current contract periods:

Current Order Period of Performance Base Period 09/6/22 – 09/05/23 Option Period 1 09/06/23 – 03/05/24 Option Period 2 03/06/24 – 09/05/24 Option Period 3 09/06/24 – 03/05/25 Option Period 4 03/06/25 – 09/05/25

Additional Period: 09/06/2025 – 03/05/2026

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));

The contract includes FAR clause 52.217-8 Option to Extend Services, which authorizes the Government to extend the contract for up to six (6) months beyond the current period of performance at the rates specified in the contract. However, the price of this option was not evaluated at the time of contract formation.

Insourcing the work associated with this BPA call is a part of CMS’ response to Executive Order (EO) 14222 “Implementing the President's ‘Department of Government Efficiency’ Cost Efficiency Initiative.” However, CMS requires continuity of services beyond the current contract expiration date to ensure uninterrupted mission support and allow sufficient time to transition work with acceptable performance risk. To do otherwise would risk impacting CMS's ability to meet statutory deadlines for Medicare payment updates, as the contractor is managing several high-priority initiatives with significant interdependencies. The MPSM program is currently at a pivotal juncture in implementing key infrastructure changes that will impact multiple Medicare payment systems. Disruption during this phase would jeopardize delivery timelines for mandated program changes scheduled for implementation in Q3 2025.

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:

In accordance with FAR 10.002 (b)(1), market research was completed for this acquisition when the BPA call was awarded in 2022 and determined that the MPSM BPA was the best method to procure agile development services for the modernization of Medicare payment systems. An informal analysis of the current rates established under the Product Strategy BPA call confirm the rates remain fair and reasonable.

5. Actions to Increase Competition:

CMS has no immediate plans for future acquisition of the services contemplated in this justification.

6. Any other facts supporting the 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.

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