36C24518Q0219-001.docx

36C24518Q0219

PAGE 1 OF

1. REQUISITION NO.

2. CONTRACT NO.

3. AWARD/EFFECTIVE DATE

4. ORDER NO.

5. SOLICITATION NUMBER

6. SOLICITATION ISSUE DATE

a. NAME

b. TELEPHONE NO. (No Collect Calls)

8. OFFER DUE DATE/LOCAL

TIME

9. ISSUED BY

CODE

10. THIS ACQUISITION IS

UNRESTRICTED OR

SET ASIDE:

% FOR:

SMALL BUSINESS

HUBZONE SMALL

BUSINESS

SERVICE-DISABLED

VETERAN-OWNED

SMALL BUSINESS

WOMEN-OWNED SMALL BUSINESS

(WOSB) ELIGIBLE UNDER THE WOMEN-OWNED

SMALL BUSINESS PROGRAM

EDWOSB

8(A)

NAICS:

SIZE STANDARD:

11. DELIVERY FOR FOB DESTINA-

TION UNLESS BLOCK IS

MARKED

SEE SCHEDULE

12. DISCOUNT TERMS

13a

. THIS

CONTRACT IS A

RATED ORDER UNDER

DPAS (15 CFR 700)

13b. RATING

14. METHOD OF SOLICITATION

RFQ

IFB

RFP

15. DELIVER TO

CODE

16. ADMINISTERED BY

CODE

17a. CONTRACTOR/OFFEROR

CODE

FACILITY CODE

18a. PAYMENT WILL BE MADE BY

CODE

TELEPHONE NO.

DUNS:

DUNS+4:

PHONE:

FAX:

17b. CHECK IF REMITTANCE IS DIFFERENT AND PUT SUCH ADDRESS IN OFFER 18b. SUBMIT INVOICES TO ADDRESS SHOWN IN BLOCK 18a UNLESS BLOCK BELOW IS CHECKED

SEE ADDENDUM

19.

20.

21.

22.

23.

24.

ITEM NO.

SCHEDULE OF SUPPLIES/SERVICES

QUANTITY

UNIT

UNIT PRICE

AMOUNT

(Use Reverse and/or Attach Additional Sheets as Necessary)

25. ACCOUNTING AND APPROPRIATION DATA

26. TOTAL AWARD AMOUNT (For Govt. Use Only) 27a. SOLICITATION INCORPORATES BY REFERENCE FAR 52.212-1, 52.212-4. FAR 52.212-3 AND 52.212-5 ARE ATTACHED. ADDENDA

ARE

ARE NOT ATTACHED.

27b. CONTRACT/PURCHASE ORDER INCORPORATES BY REFERENCE FAR 52.212-4. FAR 52.212-5 IS ATTACHED. ADDENDA

ARE

ARE NOT ATTACHED

28. CONTRACTOR IS REQUIRED TO SIGN THIS DOCUMENT AND RETURN _______________

29. AWARD OF CONTRACT: REF. ___________________________________ OFFER

COPIES TO ISSUING OFFICE.

CONTRACTOR AGREES TO FURNISH AND

DATED ________________________________.

YOUR

OFFER ON SOLICITATION

DELIVER ALL ITEMS SET FORTH OR OTHERWISE IDENTIFIED ABOVE AND ON ANY

(BLOCK 5), INCLUDING ANY ADDITIONS OR CHANGES WHICH ARE

ADDITIONAL SHEETS SUBJECT TO THE TERMS AND CONDITIONS SPECIFIED

SET FORTH HEREIN IS ACCEPTED AS TO ITEMS:

30a. SIGNATURE OF OFFEROR/CONTRACTOR 31a. UNITED STATES OF AMERICA (SIGNATURE OF CONTRACTING OFFICER) 30b. NAME AND TITLE OF SIGNER (TYPE OR PRINT) 30c. DATE SIGNED 31b. NAME OF CONTRACTING OFFICER (TYPE OR PRINT) 31c. DATE SIGNED

AUTHORIZED FOR LOCAL REPRODUCTION

(REV. 2/2012)

PREVIOUS EDITION IS NOT USABLE

Prescribed by GSA - FAR (48 CFR) 53.212

7. FOR SOLICITATION

INFORMATION CALL:

STANDARD FORM 1449

OFFEROR TO COMPLETE BLOCKS 12, 17, 23, 24, & 30

SOLICITATION/CONTRACT/ORDER FOR COMMERCIAL ITEMS

36C24518Q0219 05-2 -2018 James Whisner 304 326 7984 06-1 -2018 11:00

AM

EST

Department of Veterans Affairs Network Contracting Office 5

X X 541219 $20.5 Million X N/A X See Delivery Schedule

36C245 Department of Veterans Affairs Network Contracting Office 5

Austin Payment Center Department of Veterans Affairs PO Box 149971 Austin TX 78714-8971

(877) 353-9791

(512) 460-5545 See CONTINUATION Page Indefinite-Delivery Indefinite-Quantity Contract for the Provision of Coding Auditing Services for the VHA Compliance and Business Integrity (CBI) Office.

Contract Period of Performance: 4 Years Effective Date: (TBD) Expiration Date: (TBD) The Contractor shall be responsible for the correct title classification of workers and compliance with all applic-able wage and hour laws.

Determined at Task Order Level X X James Whisner

NCO415L2-3498

Table of Contents

SECTION B - CONTINUATION OF SF 1449 BLOCKS

B.1 CONTRACT ADMINISTRATION DATA

1. Contract Administration: All contract administration matters will be handled by the following individuals:

a. CONTRACTOR:

b. GOVERNMENT: James Whisner, Contracting Officer, Network Contracting Office 5

2. CONTRACTOR REMITTANCE ADDRESS: All payments by the Government to the contractor will be made in accordance with:

3. INVOICES: Invoices shall be submitted in arrears:

4. GOVERNMENT INVOICE ADDRESS: All Invoices from the contractor shall be submitted electronically in accordance with VAAR Clause 852.232-72 Electronic Submission of Payment Requests.

Austin Payment Center Department of Veterans Affairs PO Box 149971 Austin TX 78714-8971

B.2 LIMITATIONS ON SUBCONTRACTING-- MONITORING AND COMPLIANCE (JUN 2011)

This solicitation includes FAR 52.219-14 Limitations on Subcontracting. Accordingly, any contract resulting from this solicitation will include this clause. The contractor is advised in performing contract administration functions, the CO may use the services of a support contractor(s) retained by VA to assist in assessing the contractor's compliance with the limitations on subcontracting or percentage of work performance requirements specified in the clause. To that end, the support contractor(s) may require access to contractor's offices where the contractor's business records or other proprietary data are retained and to review such business records regarding the contractor's compliance with this requirement. All support contractors conducting this review on behalf of VA will be required to sign an “Information Protection and Non-Disclosure and Disclosure of Conflicts of Interest Agreement” to ensure the contractor's business records or other proprietary data reviewed or obtained in the course of assisting the CO in assessing the contractor for compliance are protected to ensure information or data is not improperly disclosed or other impropriety occurs. Furthermore, if VA determines any services the support contractor(s) will perform in assessing compliance are advisory and assistance services as defined in FAR 2.101, Definitions, the support contractor(s) must also enter into an agreement with the contractor to protect proprietary information as required by FAR 9.505-4, obtaining access to proprietary information, paragraph (b). The contractor is required to cooperate fully and make available any records as may be required to enable the CO to assess the contractor's compliance with the limitations on subcontracting or percentage of work performance requirement.

B.3 SUBCONTRACTING COMMITMENTS--MONITORING AND COMPLIANCE (JUN 2011)

This solicitation includes VAAR 852.215-70, Service-Disabled Veteran-Owned and Veteran-Owned Small Business Evaluation Factors, and VAAR 852.215-71, Evaluation Factor Commitments. Accordingly, any contract resulting from this solicitation will include these clauses. The contractor is advised in performing contract administration functions, the CO may use the services of a support contractor(s) to assist in assessing contractor compliance with the subcontracting commitments incorporated into the contract. To that end, the support contractor(s) may require access to the contractor's business records or other proprietary data to review such business records regarding contract compliance with this requirement. All support contractors conducting this review on behalf of VA will be required to sign an “Information Protection and Non-Disclosure and Disclosure of Conflicts of Interest Agreement” to ensure the contractor's business records or other proprietary data reviewed or obtained in the course of assisting the CO in assessing the contractor for compliance are protected to ensure information or data is not improperly disclosed or other impropriety occurs. Furthermore, if VA determines any services the support contractor(s) will perform in assessing compliance are advisory and assistance services as defined in FAR 2.101, Definitions, the support contractor(s) must also enter into an agreement with the contractor to protect proprietary information as required by FAR 9.505-4, obtaining access to proprietary information, paragraph (b). The contractor is required to cooperate fully and make available any records as may be required to enable the CO to assess the contractor compliance with the subcontracting commitments.

ACKNOWLEDGMENT OF AMENDMENTS: The offeror acknowledges receipt of amendments to the Solicitation numbered and dated as follows:

B.4 PRICE/COST SCHEDULE

This is an Indefinite-Delivery Indefinite-Quantity Contract (also known as a “Task-order Contract”) for services that does not procure or specify a firm quantity of services (other than a minimum quantity) and that provides for the issuance of orders for the performance of tasks during the effective period of the contract. The contract value (i.e., the value of all task orders that may be placed against this contract during its 4-year effective period) is:

Minimum Value: Equal to the price of a quantity of 1 of Item Number 0001.

Estimated Maximum Value: $975,000

QUANTITY

Contract Period: Months 1 - 12

Contract Period: Months 1 - 12

Contract Period: Months 1 - 12

Contract Period: Months 1 - 12

Contract Period: Months 1 - 12

Contract Period: Months 13 - 24

Contract Period: Months 13 - 24

Contract Period: Months 13 - 24

Contract Period: Months 13 - 24

Contract Period: Months 13 - 24

Contract Period: Months 25 - 36

Contract Period: Months 25 - 36

Contract Period: Months 25 - 36

Contract Period: Months 25 - 36

Contract Period: Months 25 - 36

Contract Period: Months 37 - 48

Contract Period: Months 37 - 48

Contract Period: Months 37 - 48

Contract Period: Months 37 - 48

Contract Period: Months 37 - 48

GRAND

TOTAL

36C24518Q0219

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B.5 STATEMENT OF WORK

Title of Project Veterans Health Administration (VHA) Office of Compliance and Business Integrity (CBI) Inpatient and Outpatient Coding Claims Audits.

A. Background VHA CBI National Compliance Auditing supports oversight of business activities at all levels of the organization and related financial, administrative, and health information management operations within medical facilities, Consolidated Patient Account Centers (CPACs), and nationally operated community care entities. Monitoring activities are essential in the prevention and correction of fraudulent transactions. Continuous monitoring helps in the identification of faulty or ineffective internal controls and is reported to management. CBI Officers, CPAC Liaisons, and national Community Care personnel are responsible for auditing revenue cycle, and community care business process activities. Auditing verifies that processes and procedures are consistent with VA and VHA directives, handbooks, and manuals. The performances of regular, periodic audits are an effective tool to promote and ensure compliance. Effective auditing programs include the development of annual audit plans; auditors that are independent, knowledgeable, and capable of performing in-depth reviews of business processes; and audits that are risk based and designed to minimize the risks associated with improper payments, claims, and billing practices.

Coding audits provide validation of the integrity, quality, and assignment of codes to the data contained in the Patient Care Encounter and inpatient Patient Treatment File at each medical center as evidenced by proper documentation of the care or service provided to the patient. Audits of coded data will be performed on any of the VHA required coding activities (e.g., inpatient, outpatient, surgery). These audits will address accuracy of coded data, health record documentation issues, to include recommended remediation of specific documentation deficiencies, process improvement and identify educational needs.

B. General Objectives and Requirements

1. Purpose The VHA Office of Compliance and Business Integrity is seeking a contractor to conduct coding audits of VHA inpatient and outpatient encounters, both unbilled and billed to third party payers; and claims billed to the VA through the VA Community Care Program. VHA CBI is also seeking a contractor with the ability to perform clinical documentation audits of both inpatient stays and outpatient encounters to determine if the encounter was documented accurately and completely. VHA CBI is currently undergoing a transformation and may discontinue supporting the oversight of certain business activities (e.g., coding audits) for VHA. If that happens, another VHA program office may be tasked to oversee this function within VHA, including the oversight of this contract.

2. Scope and Objectives

· The claims and health records, in either electronic format or hard copy, to be audited include codes at all levels of complexity for both inpatient and outpatient claims.

· In total, there will be approximately 5000 to 7000 coding encounters to be audited per year. Size and frequency of audits will be discussed with the contractor at the beginning of each year or as needed. Potential audits may be in the format of any of the following:

· A primary coding audit – which is the main focus of a quarter and other audits which are smaller in scope

· Multiple small audits and no primary coding audit

· Quarterly audits

· One annual audit

· All necessary records will be made available to the contractor in electronic format on VHA systems where all documentation will reside. Personally identifiable information and personally identifiable health information shall not be copied onto contractor systems.

· Specific elements to review for coding audits may include, but shall not be limited to:

· Whether the Evaluation and Management (E&M) code level is supported by the documentation in the medical records for which the code is assigned.

· Whether the complexity of the visit meets the medical necessity criteria for the code level assigned.

· Whether modifiers are assigned correctly.

· Whether all documented CPT procedures are captured and coded correctly.

· Whether the diagnoses ICD-10-CM (or later versions of coding guidance) support the medical necessity of the services provided.

· Whether DRG and/or HCPCS codes are captured and coded correctly.

· Possible coding audits will include, but shall not be limited to, coding audits related to Inpatient hospitalizations, ambulatory surgery, diagnostic tests (endoscopy, bronchoscopy, cardiac catheterization, Percutaneous Transluminal Coronary Angioplasty, pulmonary function, radiology, laboratory, etc.), primary care, mental health, medicine sub-specialty, surgery, observation, neurology, and Non-Veterans Affairs care records, prosthetics, and DME services. It is estimated that there could be 5600 outpatient encounters, 500 inpatient facility encounters, and 500 inpatient professional encounters (including surgery) for each full performance period.

· For clinical documentation audits, the medical record documentation, including provider queries, shall be reviewed to validate the specific reason for the encounter. Additionally, auditors will be responsible for verifying medical record documentation appropriately reflects the diagnosis and procedure selection(s) in addition to monitors and/or evaluation all of which must be in accordance with VHA written policies or guidelines. It is estimated that 200 inpatient encounters and 200 outpatient encounters could be reviewed for documentation completeness and accuracy in a full performance period.

3. Requirements

· Auditors must possess all licenses, permits, accreditation, and certificates as required by law

· Auditors shall possess formal training in anatomy and physiology, medical terminology, pathology and disease processes, pharmacology, health record format and content, reimbursement methodologies and conventions, rules and guidelines for current classification systems (International Classification of Diseases, Common Procedural Terminology, and Healthcare Common Procedural Coding System).

· Auditors must have at least three years of experience in reviewing records in a large hospital and outpatient health care organizations having all subspecialties and primary care as well as completed the baseline International Classification of Diseases 10th edition with experience and training as required to hold a current/active credential listed below.

· Auditors shall be credentialed and have completed an accredited program for coding certification, an accredited program for health information management or health information technician. For the purpose of this contract, a certified coder/auditor is someone with one of the following active credentials listed below.

· Auditors shall hold a current/active American Health Information Management Association or American Academy of Professional Coders credential. Acceptable credentials are: American Health Information Management Association credentials as a Registered Health Information Administrator, Registered Health Information Technician, Certified Coding Specialist, and Certified Coding Specialist–Physician, or American Academy of Professional Coders as a Certified Professional Coder or Certified Professional Coder–Hospital.

· Auditors must have knowledge of regulations that define healthcare documentation requirements, including the Joint Commission, CMS, and VHA guidelines.

· Auditors must be able to obtain and maintain access to VA electronic health records systems and other necessary VA systems.

· Auditors must obtain the ability to encrypt records in a compatible format with VA capabilities. All personally identifiable information, personal health information or individually identifiable health information must be encrypted when exchanged during email communications.

· Contractor must perform regular quality/accuracy reviews of work performed by its auditors for each audit performed with a statistical sample size determined with parameters of at least 90% confidence level and margin of error of 10%. Results of review will be provided to CBI. Target of accuracy reviews will be 95% accuracy. CBI may request the replacement of auditors with consistent accuracy rates below 95% for 2 consecutive audits.

· The auditor shall have knowledge and experience with performing coding audits for the VHA.

· The auditor shall have knowledge and experience with performing documentation audits for the VHA.

· The auditor shall have knowledge and experience with VHA coding and documentation practices, guidelines, and rules.

· The auditor shall not code for any VHA facility while conducting an audit and the auditor should not have coded for any VHA facility for the 12 months prior to the audit being conducted in order to maintain independence and objectivity.

· The contractor shall adhere to all coding guidelines as approved by the Cooperating Parties (American Hospital Association, American Health Information Management Association, Centers for Medicare and Medicaid Services, and the National Center for Health Statistics), as mandated by Health Insurance Portability and Accountability Act and accepted Veterans Affairs regulations, including the following applicable documents:

· The Official Guidelines and Reporting as found in the Common Procedural Terminology Assistant, a publication of the American Medical Association for reporting outpatient ambulatory procedures and evaluation and management services

· The current Official Guidelines for Coding and Reporting in the Coding Clinic for International Classification of Diseases, a publication of the American Hospital Association

· The current Veterans Health Administration guidelines for coding as found in the Veterans Health Administration Health Information Management Coding Guidelines, Health Information Management, and Department of Veterans Affairs. This workbook is updated at least once per year with new codes and guidance. The contractor must ensure that it has the current version and the guidance is followed. Note: While Veterans Health Administration does ask for reimbursement from third party payers, the Veterans Health Administration coding policy is to code only according to coding guidelines. VHA’s own compliance audits use only this definition when determining if any encounter or Patient Treatment File is coded correctly.

· The Correct Coding Initiative the Common Procedural Terminology Evaluation and Management codes assure documentation substantiates the code level assigned.

· Veterans Health Administration Directive 1082 Patient Care Data Capture: http://vaww.va.gov/vhapublications/ViewPublication.asp?pub_ID=3091

· Veterans Health Administration Handbook 1400.01 Resident Supervision: http://vaww.va.gov/vhapublications/ViewPublication.asp?pub_ID=2847

· Veterans Health Administration Directive 1401Billing for Services Provided by Supervising Practitioners and Physician Residents:

http://vaww.va.gov/vhapublications/ViewPublication.asp?pub_ID=3221

· Veterans Health Administration Health Information Management Clinical Coding Guide V1.2: https://vaww.vha.vaco.portal.va.gov/sites/HDI/HIM/vaco_HIM/subsite5/subsite3/HIM%20Handbooks/Forms/HIM%20Document%20Library.aspx

· Veterans Health Administration Handbook 1907.01 Health Information Management and Health Records: http://vaww.va.gov/vhapublications/ViewPublication.asp?pub_ID=3088

· Veterans Health Administration Directive 1233 Closeout of Veterans Health Administration Corporate Patient Data Files including Quarterly Patient Census: http://vaww.va.gov/vhapublications/ViewPublication.asp?pub_ID=5425 h

· Other directives that Veterans Affairs may issue from time to time.

· CMS 1995 and 1997 evaluation and management guidelines C. Tasks and Associated Deliverables All tasks, associated deliverables and approaches must align with appropriate and applicable Federal Government regulations and policies, including privacy and Health Insurance Portability and Accountability Act of 1996 (HIPAA) privacy and security rules, as well as industry benchmarks.

This contract consists of four major tasks with associated deliverables:

1. Kick-off Meeting will be conducted via online web/teleconference, which will include representatives from the CBI Office and development of a work plan for project implementation. The target audience will include representatives from the CBI Office and development of a work plan and audit plan by the contractor, for contract implementation;

2. Complete review of all records and claims in the time period specified;

3. Final reports of audit results for each audit to be presented to the Chief CBI Officer at the completion of each audit.

4. Detailed spreadsheets showing claim findings and a point of contact which will allow the CBI Office to ask questions with respect to audit methodology, analysis techniques, and review of disputed results.

Government Acceptance/Rejection of Deliverables: Individual deliverables related to the tasks below will be accepted or rejected on a routine basis. Upon receipt of any one deliverable, the government will generally have ten (10) working days to approve or reject the deliverable. Expanded timelines may be required for some deliverables. In these cases, the government will notify the contractor of the adjusted acceptance timeframes.

Contractor documentation: After the contract is awarded, the contractor must provide the following items for each potential auditor before services can begin:

· Resumes of the actual auditors and two current client references specific to each auditor;

· Proof of current coding credentials;

· Proof of completion of mandatory VA security/privacy training to include: VA Privacy and Information Security Awareness and Rules of Behavior [TMS Course ID #: VA 10176]; Privacy and HIPAA Training [TMS Course ID #: 10203]; and Compliance and Business Integrity Compliance Awareness Mandatory Education Course [TMS Course ID #: VA 7318].

· Statement of Independence (to include the names of any VHA Medical Centers each auditor may have coded for in the past); and

· Each auditor will need to apply for and receive a government issued Personal Identify Verification (PIV) card from the auditor’s nearest VA medical center in order to access electronic records in the VA computer system. PIV card issuance requires satisfactory completion of a background check and obtaining a VA email account, VA username, and VA encryption certificates.

Contractor Deliverables 1 through 5 above will be supplied to the VHA Contracting Officer’s Representative (COR) for approval at least 30 days prior to the audits beginning and after that, within 30 days of the next audit, in the event an auditor needs to be replaced.

Task 1: Kick-off meeting.

The contractor will meet with the necessary VHA CBI personnel at the initiation of the contract via an online web/teleconference. The meeting will include the development of a work plan for project implementation addressing types and frequencies of audits, potential subjects, sampling methodology, report format and content, and results spreadsheet format and content. Within five (5) days after this kick-off meeting, the contractor will develop and submit a project work plan and an audit plan. This plan will include resource allocation and timelines for completion of each task and deliverable. The contractor should also be able to develop a sampling methodology as part of the audit plan.

Deliverables 1 & 2: Project Work Plan and Audit Plan within five (5) days after the initial kick-off meeting.

Task 2: Complete audit of all records and claims in the specified time frame.

Multiple types of audits may be conducted, including 1) One main coding audit which is the main focus for a quarter and other audits which are smaller in scope; or 2) Multiple small audits and no main audit ; or 3) Quarterly audits or 4) One annual audit. In total, there will be approximately 5000 to 7000 coding encounters to be audited during the year. Audits must be completed within 60 days of receipt of documentation for each audit with up to 1750 samples. Each audit will require a formal report upon completion; therefore multiple reports are expected. Reports are due 5 days following completion of the audit.

Upon receipt of the necessary records from VHA, the contractor will execute the audits of all claims and records provided. The audits will be conducted in accordance with official sources including, but not limited to: CMS 1995 and 1997 evaluation and management guidelines, American College of Emergency Physicians (ACEP) clinical coding criteria, AHA Coding Clinic for ICD-10-CM (or later versions, when applicable), AHA Coding Clinic for HCPCS, AMA CPT assistant, CCI Edits, the Health Information Technology for Economic and Clinical Health (HITECH) Act, all applicable VHA Directives, Handbooks, guidelines, and Reasonable Charges Group to include VHA Handbook 1907.01, Veterans Health Administration Health Information Management Clinical Coding Guide V1.2, Health Information Management Clinical Coding Program Procedures; VHA Handbook 1907.04, Patient Treatment File (PTF) Coding Instructions. CBI Office will request written documentation showing whether the 1995 or 1997 coding standards are used by each facility for all claims reviewed and will include this information with the sample given to the contractor.

Task 3: Final reports of audit results for each completed audit is to be presented to the CBI Office, within 5 days of the completion of each audit.

Upon completion of each audit, the contractor will prepare a final audit report in the English language detailing all necessary and relevant information pertaining to the scope and objectives provided; the methodology; findings and recommendations of the auditor and other contract personnel. Each report will include, at a minimum, analysis of the accuracy of all coder (and possibly non-coder) supported codes within the claims, use of all modifiers, and the percentage of claims likely to be denied for payment due to any of these inaccuracies.

Reports should also include any other analyses, identified trends, or opinions that the reviewers, auditors, or other staff find relevant and useful to the government. Report results, analysis, opinions, observations, etc., should be based upon the scope of the audit as discussed with the CBI Office; this may lead to a break down by region, facility, national results, or some combination of each. Reports may also require the results of the statistical samples to be projected into a population estimate, indicated percentage of population affected, volume of population affected, financial impact on population, etc. as determined prior to the initiation of the audit. Audit reports will be delivered at the end of the 5 days following the completion of each audit; in electronic format. File containing Personally Identifiable Information (PII) must be sent in an encrypted format compatible with VHA format.

In addition, depending on the scope of the audit, the report may also need to include the contractor’s opinion regarding whether a third party payer may question the medical necessity of the care provided, and therefore challenge payments made and number of claims for which medical necessity may be an issue.

The contractor will furnish the CBI Office the final reports (via email that is encrypted if PII is contained in the file) of audit results with the following structure: An Executive Summary with Purpose, Findings and Recommendations; a Background with Objectives, Scope and Methodology; Results of the audit with a Conclusion, Recommendations and associated VA/VHA Handbooks, Directives or VHA Chief Business Office Revenue Guides or referenced Coding Guidelines; and an Acronym/Definitions section. The reports are to be formatted with one (1) inch margins at the top, bottom, left and right; all acronyms should be spelled out at the first use and in the Acronym section; single spacing, page numbers and proper use of terminology, for example ICD-10-CM instead of ICD-10. Detailed spreadsheets showing audit results, the data reviewed, and a point of contact’s name and phone number are to accompany each report.

Deliverable 3: Audit reports detailing results for each completed audit, within 5 days of completion.

Task 4: Detailed spreadsheets showing audit findings and a point of contact which will allow the CBI Office to ask questions with respect to audit methodology and analysis techniques.

Each report will be accompanied with detailed spreadsheets showing the claim findings, errors, correct codes and the reasons for the errors found. The CBI Office will work with the contractor on the format and content of the coding audit worksheet to be used by the contractor. Each facility may have its own spreadsheet which distinguishes its performance and/or there may be a consolidated worksheet of all claims reviewed. Additionally there will be a summary tab showing overall coding accuracies, coding accuracy by types of code (E/M, CPT, ICD, modifiers, etc.), types of errors and any other types of data requested by the CBI Office. Files containing PII must be sent in an encrypted format.

A point of contact name and phone number will be provided for each audit which will allow the CBI Office to speak to an auditor on the review in order to answer any questions on methodology, analysis techniques, or review of disputes with audit results. Auditors should be able to provide specific reasons and references for all decisions made during the course of the audit. Auditors may need to contact particular auditees to resolve questions and/or disputes. Any questions or review of specific decisions on a sample that reveal a mistake and results in a change in decision will be reflected in a revised spreadsheet and report.

Deliverable 4: Spreadsheets detailing audit results (for each audit), within 5 days of audit completion, and a point of contact’s name and phone number.

D. Deliverables and Performance Summary Matrix

E. Period of Performance The contract period of performance is 4 years from the date of award. Task orders issued under this contract will identify their own specific period of performance.

F. Place of Performance The contract work will be performed at the contractor’s place of business utilizing electronic health records provided by the CBI Office. This will require utilization of contractor’s computer equipment supplemented by VA-issued CAG (Citrix Access Gateway) remote access along with a VA-issued PIV card.

G. Confidentiality and Disclosure

a. The Contractor shall agree that:

· All deliverables, associated working papers, and other material deemed relevant by VA generated by the Contractor in the performance of this task order are the property of the United States Government.

· All individually identifiable health records shall be treated with the strictest confidentiality. Access to records shall be limited to essential personnel only. At the conclusion of the contract all copies of individually identifiable health records shall be the property of VHA CBI. The contractor shall comply with the Privacy Act, 38 USC 5701, and 38 USC 7332.

· Any physical transportation of medical records must be sent using a secure and overnight mail status.

· Electronic transmission of all personally identifiable information, personal health information or individually identifiable health information must be encrypted per VA guidelines.

b. Security:

· The C&A requirements do not apply and a Security Accreditation Package is not required.

H. Service Contract Labor Standards The Service Contract Labor Standards (formerly known as the Service Contract Act of 1965) applies to this contract. Contractor will be responsible for compliance with the Service Contract Labor Standards and determining which of its workers are performing on or in connection with the contract and properly segregating their hours for purposes of pay and recordkeeping. The Department of Labor’s Wage Determination is provided as an attachment in Section D; it specifies the minimum wages and fringe benefits for workers performing on or in connection with this contract.

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SECTION C - CONTRACT CLAUSES

C.1 52.212-4 CONTRACT TERMS AND CONDITIONS—COMMERCIAL ITEMS (JAN 2017)

(a) Inspection/Acceptance. The Contractor shall only tender for acceptance those items that conform to the requirements of this contract. The Government reserves the right to inspect or test any supplies or services that have been tendered for acceptance. The Government may require repair or replacement of nonconforming supplies or reperformance of nonconforming services at no increase in contract price. If repair/replacement or reperformance will not correct the defects or is not possible, the Government may seek an equitable price reduction or adequate consideration for acceptance of nonconforming supplies or services. The Government must exercise its post-acceptance rights—

(1) Within a reasonable time after the defect was discovered or should have been discovered; and

(2) Before any substantial change occurs in the condition of the item, unless the change is due to the defect in the item.

(b) Assignment. The Contractor or its assignee may assign its rights to receive payment due as a result of performance of this contract to a bank, trust company, or other financing institution, including any Federal lending agency in accordance with the Assignment of Claims Act (31 U.S.C. 3727). However, when a third party makes payment (e.g., use of the Governmentwide commercial purchase card), the Contractor may not assign its rights to receive payment under this contract.

(c) Changes. Changes in the terms and conditions of this contract may be made only by written agreement of the parties.

(d) Disputes. This contract is subject to 41 U.S.C. chapter 71, Contract Disputes. Failure of the parties to this contract to reach agreement on any request for equitable adjustment, claim, appeal or action arising under or relating to this contract shall be a dispute to be resolved in accordance with the clause at FAR 52.233-1, Disputes, which is incorporated herein by reference. The Contractor shall proceed diligently with performance of this contract, pending final resolution of any dispute arising under the contract.

(e) Definitions. The clause at FAR 52.202-1, Definitions, is incorporated herein by reference.

(f) Excusable delays. The Contractor shall be liable for default unless nonperformance is caused by an occurrence beyond the reasonable control of the Contractor and without its fault or negligence such as, acts of God or the public enemy, acts of the Government in either its sovereign or contractual capacity, fires, floods, epidemics, quarantine restrictions, strikes, unusually severe weather, and delays of common carriers. The Contractor shall notify the Contracting Officer in writing as soon as it is reasonably possible after the commencement of any excusable delay, setting forth the full particulars in connection therewith, shall remedy such occurrence with all reasonable dispatch, and shall promptly give written notice to the Contracting Officer of the cessation of such occurrence.

(g) Invoice.

(1) The Contractor shall submit an original invoice and three copies (or electronic invoice, if authorized) to the address designated in the contract to receive invoices. An invoice must include—

(i) Name and address of the Contractor;

(ii) Invoice date and number;

(iii) Contract number, line item number and, if applicable, the order number;

(iv) Description, quantity, unit of measure, unit price and extended price of the items delivered;

(v) Shipping number and date of shipment, including the bill of lading number and weight of shipment if shipped on Government bill of lading;

(vi) Terms of any discount for prompt payment offered;

(vii) Name and address of official to whom payment is to be sent;

(viii) Name, title, and phone number of person to notify in event of defective invoice; and

(ix) Taxpayer Identification Number (TIN). The Contractor shall include its TIN on the invoice only if required elsewhere in this contract.

(x) Electronic funds transfer (EFT) banking information.

(A) The Contractor shall include EFT banking information on the invoice only if required elsewhere in this contract.

(B) If EFT banking information is not required to be on the invoice, in order for the invoice to be a proper invoice, the Contractor shall have submitted correct EFT banking information in accordance with the applicable solicitation provision, contract clause (e.g., 52.232-33, Payment by Electronic Funds Transfer—System for Award Management, or 52.232-34, Payment by Electronic Funds Transfer—Other Than System for Award Management), or applicable agency procedures.

(C) EFT banking information is not required if the Government waived the requirement to pay by EFT.

(2) Invoices will be handled in accordance with the Prompt Payment Act (31 U.S.C. 3903) and Office of Management and Budget (OMB) prompt payment regulations at 5 CFR part 1315.

(h) Patent indemnity. The Contractor shall indemnify the Government and its officers, employees and agents against liability, including costs, for actual or alleged direct or contributory infringement of, or inducement to infringe, any United States or foreign patent, trademark or copyright, arising out of the performance of this contract, provided the Contractor is reasonably notified of such claims and proceedings.

(i) Payment.—

(1) Items accepted. Payment shall be made for items accepted by the Government that have been delivered to the delivery destinations set forth in this contract.

(2) Prompt payment. The Government will make payment in accordance with the Prompt Payment Act (31 U.S.C. 3903) and prompt payment regulations at 5 CFR part 1315.

(3) Electronic Funds Transfer (EFT). If the Government makes payment by EFT, see 52.212-5(b) for the appropriate EFT clause.

(4) Discount. In connection with any discount offered for early payment, time shall be computed from the date of the invoice. For the purpose of computing the discount earned, payment shall be considered to have been made on the date which appears on the payment check or the specified payment date if an electronic funds transfer payment is made.

(5) Overpayments. If the Contractor becomes aware of a duplicate contract financing or invoice payment or that the Government has otherwise overpaid on a contract financing or invoice payment, the Contractor shall—

(i) Remit the overpayment amount to the payment office cited in the contract along with a description of the overpayment including the—

(A) Circumstances of the overpayment (e.g., duplicate payment, erroneous payment, liquidation errors, date(s) of overpayment);

(B) Affected contract number and delivery order number, if applicable;

(C) Affected line item or subline item, if applicable; and

(D) Contractor point of contact.

(ii) Provide a copy of the remittance and supporting documentation to the Contracting Officer.

(6) Interest.

(i) All amounts that become payable by the Contractor to the Government under this contract shall bear simple interest from the date due until paid unless paid within 30 days of becoming due. The interest rate shall be the interest rate established by the Secretary of the Treasury as provided in 41 U.S.C. 7109, which is applicable to the period in which the amount becomes due, as provided in (i)(6)(v) of this clause, and then at the rate applicable for each six-month period as fixed by the Secretary until the amount is paid.

(ii) The Government may issue a demand for payment to the Contractor upon finding a debt is due under the contract.

(iii) Final decisions. The Contracting Officer will issue a final decision as required by 33.211 if—

(A) The Contracting Officer and the Contractor are unable to reach agreement on the existence or amount of a debt within 30 days;

(B) The Contractor fails to liquidate a debt previously demanded by the Contracting Officer within the timeline specified in the demand for payment unless the amounts were not repaid because the Contractor has requested an installment payment agreement; or

(C) The Contractor requests a deferment of collection on a debt previously demanded by the Contracting Officer (see 32.607-2).

(iv) If a demand for payment was previously issued for the debt, the demand for payment included in the final decision shall identify the same due date as the original demand for payment.

(v) Amounts shall be due at the earliest of the following dates:

(A) The date fixed under this contract.

(B) The date of the first written demand for payment, including any demand for payment resulting from a default termination.

(vi) The interest charge shall be computed for the actual number of calendar days involved beginning on the due date and ending on—

(A) The date on which the designated office receives payment from the Contractor;

(B) The date of issuance of a Government check to the Contractor from which an amount otherwise payable has been withheld as a credit against the contract debt; or

(C) The date on which an amount withheld and applied to the contract debt would otherwise have become payable to the Contractor.

(vii) The interest charge made under this clause may be reduced under the procedures prescribed in 32.608-2 of the Federal Acquisition Regulation in effect on the date of this contract.

(j) Risk of loss. Unless the contract specifically provides otherwise, risk of loss or damage to the supplies provided under this contract shall remain with the Contractor until, and shall pass to the Government upon:

(1) Delivery of the supplies to a carrier, if transportation is f.o.b. origin; or

(2) Delivery of the supplies to the Government at the destination specified in the contract, if transportation is f.o.b. destination.

(k) Taxes. The contract price includes all applicable Federal, State, and local taxes and duties.

(l) Termination for the Government's convenience. The Government reserves the right to terminate this contract, or any part hereof, for its sole convenience. In the event of such termination, the Contractor shall immediately stop all work hereunder and shall immediately cause any and all of its suppliers and subcontractors to cease work. Subject to the terms of this contract, the Contractor shall be paid a percentage of the contract price reflecting the percentage of the work performed prior to the notice of termination, plus reasonable charges the Contractor can demonstrate to the satisfaction of the Government using its standard record keeping system, have resulted from the termination. The Contractor shall not be required to comply with the cost accounting standards or contract cost principles for this purpose. This paragraph does not give the Government any right to audit the Contractor's records. The Contractor shall not be paid for any work performed or costs incurred which reasonably could have been avoided.

(m) Termination for cause. The Government may terminate this contract, or any part hereof, for cause in the event of any default by the Contractor, or if the Contractor fails to comply with any contract terms and conditions, or fails to provide the Government, upon request, with adequate assurances of future performance.