MAS LSJ 07162025 Final Approved Signed_Redacted.pdf

claim appeals for Medicare Fee-for-Service programs. It integrates with internal and external organizations through web services and interfaces with other CMS systems to access critical beneficiary, provider, and claims data. MAS provides unified case tracking, reporting capabilities, and supports data-driven policy decisions. MAS now includes data collection for Medicare Level 1 Part B and Durable Medical Equipment (DME) appeals, and integration with Medicare Administrative Contractors (MAC) portals for appeal requests, status checking, documentation submission, and correspondence review.

current contract is a General Services Administration (GSA) Multiple Award Schedule

(MAS) order ( ) awarded using fair opportunity to CGI Federal, Inc. with a total period of performance from November 1, 2020, to September 14, 2025. The current contract period runs from November 1, 2024, to September 14, 2025. To date, the total financial obligations under this contract amount to .

This justification seeks approval to issue a logical follow-on for MAS to standardize the appeals workflow process by integrating Level 1 Part B/DME appeals adjudication and storage within the existing system, creating a unified platform for Medicare appeals management.

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

CGI has maintained the Medicare Appeals System (MAS) since 2005 and is currently developing software for Medicare Level 1 Part B/DME appeals. The system integration requires major architectural changes to support a six-fold workload increase and "big box" appeals containing up to claims (vs. current single claim appeals), requiring redesigned file management, batch services, and enhanced web service interfaces.

Replacing the contractor prior to completion of this large, complex change to the design and operation of MAS creates significant performance risks. This is because if the system isn’t properly redesigned this could lead to performance degradation that directly impacts CMS's ability to serve the Medicare stakeholder community and fulfill its mission. The program could also suffer with maintaining system availability, managing security vulnerabilities, and ensuring data integrity which could present problems with serving beneficiaries, providers, and stakeholders

The one-year extension enables CGI to complete this work by June 2026, building on the development efforts. The approach will standardize Level 1 appeals processing across all Medicare appeal types, create a central repository for Level 1-3 appeals data, improve system stability and documentation for future competition and deliver ongoing operational cost savings.

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:

Market research was not conducted for this action as it would not alter the technical reality that CGI Federal is currently performing the Medicare Appeals System (MAS) application and developing the Level 1 Part B/DME appeals functionality. CGI's performance throughout the current contract has been , demonstrating their unique expertise with the system. Based on this experience and the specialized nature of the work, the program office is confident that no information from market research would change the contracting approach or justify the risks associated with transition at this critical stage of development. Market research shall be completed for the recompete of this requirement in accordance with FAR 10 procedures.

5. Actions to Increase Competition:

This acquisition is a logical follow-on to an original Federal Supply Schedule order that was awarded through fair opportunity procedures, and the original order was not previously issued under sole-source or limited-source procedures, thus meeting the requirements of FAR 8.405- 6(a)(1)(i)(C). Following this follow-on order, CMS plans to conduct a competitive acquisition.

The completion of this work will position CMS to effectively recompete the requirement as the system will offer enhanced functionality and more efficient performance. Additionally, by that time, requirements should be mature enough to establish a steady-state environment, enabling increased competition among qualified vendors. Finally, the program will ensure the appropriate data & documentation is collected to ensure a level playing field for the follow-on, competitive acquisition to come.

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

Name / Date

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

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5. Office of Small and Disadvantaged Business Utilization

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6. OGC Legal Review

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7. HHS Competition Advocate Approval

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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