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* = Required Field FedBizOpps Special Notice Rev. March 2010 R Recovery Audit Services Pre-Proposal Conference Minutes Questions and Answers 63123 36C77618R0051 N 541211 Department of Veteran Affairs

PCAC-ST. LOUIS

11152 South Towne Square Saint Louis MO 63123 Contract Specialist: Angela Perry Contracting Officer: Linda Eley https://www.va.gov/ The Department of Veteran Affairs angela.perry@va.gov Contract Specialist

This FBO notice is associated with 36C776-18-R-0051 for Recovery Audit Services The purpose of this FBO notice is to post the meeting minutes from the Pre-Proposal conference held on 22 August 2018 in St. Louis, MO. As well, this notice disseminates ALL questions asked during the eligible question period and their answers. Slides used at the pre-proposal conference are available upon email request at angela.perry@va.gov . There will be a formal amendment to follow this notice and any below answers that refer to “Amendment 1” will see revisions as stated.

RECOVERY AUDIT SERVICES PRE-PROPOSAL CONFERENCE MEETING MINUTES

Wednesday, August 22, 2018 @ 08:00 AM ET

Participants: PCAC Contracting Office-St. Louis, Office of Community Care, Office of General Counsel and Industry

Contracting Officer: Linda Eley

Contracting Specialist: Angela Perry

Summary: On August 22, 2018 a Pre-Proposal Conference was held by PCAC Contracting Office St. Louis location, the conference began at 08:00 EST and adjourned before 12 noon. During the conference, in order of occurrence:

· Contracting Officer: Provided the agenda, introductions and briefed the rules of engagement for all parties present.

· Office of Community Care (Program Office Team): Presented a program overview and its relation to recovery audit services.

· Contracting Specialist: Provided a complete overview of the solicitation.

· Contracting Officer: Closed the conference, providing reminders of point of contact information, as well as dates and times for period for questions closing, posting of answers and proposal submission.

Topics Discussed/Emphasized:

· Program Background

· Governing Laws

· Performance Work Statement

· CLIN Schedule and Pricing Structure

· Tiered Evaluation

· Evaluation Criteria

◘ 38 USC 1703 authorizes the VA to contract for Recovery Audit services.

◘ Revenue collected by Office of Community Care offsets the Congressional Allocation by 7 to %.

◘ VA medical care includes 3rd Party and 1st Party co-pay.

◘ The VA generally has six years to file a claim, however it is not a blanket time line and there are varying timelines with commercial health care companies through special agreements.

◘ For tasks 6.4-6.10, the order of CPACs and schedule is forecasted based off VA data (types of claims recoverable, volume, opportunity of recoverable costs, etc.).

◘ All printed materials must be printed at the MACPAC location, located in Ashville, NC. A different location can be requested but it is based off of available space and resources.

◘ Data assessed during task 6.3 will be of the most available and current data. At this time, it is FY17.

◘ The Contractor will receive new claims data each year.

◘ This IDIQ contract has a period of eligibility of three years, starting at the time of award of which a task order can be issued for tasks 6.3-6.10. At a minimum a task order will be issued for task 6.3 Feasibility Assessment Report.

◘ CLIN0002 Recovery Audit Services will be performed only after tasks 6.1-6.3. Recovery Audit Services will be assigned by task order. These services are not fully funded up front and will be paid a agreed upon fee percentage of recovered monies send to VA. This CLIN does not require invoicing but will be tracked through monthly reporting.

◘ Proposals will be categorized and placed in order of business concern priority, 1) SDVOSB, VOSB, Small Business (Hubzone and 8(a) have priority) and then Large Business.

◘ The government will only evaluated one category at a time. At the time a technically acceptable offer has been reached who offers the best value in terms of price and is fair and reasonable the evaluation will stop. Any remaining categories left will not be evaluated or considered for award. Example: The government evaluates the SDVOSB category, all three offers were deemed either unacceptable or price is not fair and reasonable. The government moves to the VOSB category to evaluate and reaches an offer that is technically acceptable and the price is both fair and reasonable. The evaluation stops, any offer submitted that was a small business concern of any other type excluding VOSBs and any large business concerns will not be evaluated or considered.

◘ The offeror must financial documentation for any resources internal or outside used to determine viability.

◘ This factor is most important due to the fact that the Contractor may not receive payment for CLIN 0002 Recovery Audit Services from six to 12 months due to onboarding, contract start up, lead time on security protocol and the cycle of recovery audit.

◘ The government does not want to overburden a company.

◘ A small business can be the prime contractor.

◘ A subcontracting plan is only required from Large Business concerns and is evaluated on a pass or fail basis. A passing subcontracting plan is one that meets the VA Small Business goals percentages included at 52.212-1 and 52.212-2.

◘ Option year will not be exercised, this is a three year contract. FAR Clause 52.217-8 is included to extend services for the order period up to six (6) months. The period of eligibility of this contract will not exceed 3 years and six months.

◘ FAR clause 52.216-19: The minimum order on this contract is the Feasibility Assessment Report.

◘ Industry was instructed to document questions on provided notecards and any answers received during the conference would be made available to the public via amendment posted to FBO.gov.

◘ All questions received during the eligible period to submit questions from both conference attendees and non-attendees have been combined as an attachment to the amendment.

In Closing:

· Office of Community Care Slides will be made available with the solicitation amendment for documenting questions and answers. If the systems will not allow the document to be embedded due to document format (powerpoint) they made be requested by any party through the closing date of the solicitation.

· Any changes to solicitation 36C776-18-R-0051 will be made via amendment, posted to FBO.gov.

· Questions are due by 1300 EST, 24 August 2018.

· Answers will be posted by close of business, 27 August 2018.

· Proposals are due by 1300 EST, 06 September 2018.

· All correspondence will be electronic via email, to include proposal submissions to both:

· Contracting Specialist: Angela Perry, angela.perry@va.gov

· Contracting Officer: Linda Eley, linda.eley@va.gov

This FBO notice is associated with 36C776-18-R-0051 for Recovery Audit Services The purpose of this FBO notice is to post the meeting minutes from the Pre-Proposal conference held on 22 August 2018 in St. Louis, MO. As well, this notice disseminates ALL questions asked during the eligible question period and their answers. Slides used at the pre-proposal conference are available upon email request at angela.perry@va.gov . There will be a formal amendment to follow this notice and any below answers that refer to “Amendment 1” will see revisions as stated.

Questions and Answers:

1. With such success in collections, what improvements are you anticipating through a partnership with industry?

VA is looking for offerors to identify areas of potential collection opportunities. This contract will ultimately create a diminished earning potential. Once opportunities for improvement are identified by the Offeror, VA will implement process changes through the change management process. The goal of the initial feasibility study is to identify claims that have additional potential recovery based on vendor industry experience and analysis and that could change the tasks from 6.4 to 6.10 based on which CPAC would be first, however currently it is expected to be NCCPAC.

2. Will there be only one award or multiple?

Answer: There will be only one award.

3. Are there any contractors currently supporting this work? If so, who and under what contracts?

Answer: No, there are no contractors currently supporting this work.

4. Can the Government confirm whether or not this is a new requirement? If not, can the Government provide the incumbent name and contract number?

Answer: This is a new requirement, there is no incumbent.

5. Is there any work that is being performed at VA that would be a conflict of interest with performing this contract, including VA billing support, Veterans choice, the future community care network contracts, etc.?

Answer: VA would have to evaluate conflict of interest at the time of proposal review. There is a separation of duties for billing versus accounts receivable. If an Offeror is currently performing billing work for the VA, the same staff cannot do audit recovery actions.

6. Are there concurrent reviews necessary or in place in addition to prior authorization?

Answer: VA participates in concurrent reviews and prior authorization with third party payers as necessary per the payer’s requirements. There are some cases in which VA sends a veteran for a service before the prior authorization is sought from the payer if VA has the service available in the facility. VA performs treatment based on the needs of the veteran, not the requirements of the third party insurance company.

7. For large prime offeror subcontracting with small business, does the VA provide any preference, points or other considerations to the prime offeror based on its subcontracting commitments?

Answer: No, the tiered evaluation is outlined in the solicitation.

8. Does VA reserve the right to cancel the solicitation if no technically acceptable bids received for tiers 1 through 3?

Answer: Yes, VA reserves the right to cancel the solicitation at any time.

9. How would contractor attain access to program office tools such as the Payer Compliance Tool that was described? Would it be through Vista?

Answer: Access to each information technology system required will be provided by the Government.

10. Is the 9-12 month collection payment period for payment changed depending in prime business status (e.g. SDVOSB, VSOB, HUB, large)?

Answer: No,this is the potential estimated time frame before the contractor may see dollars from collection, given the study, access to VISTA, clearance and actual beginning of performance of each task order.

11. For CLIN 2, can the offeror provide different percentages for different year periods?

Answer: No, the contingency percentage must be the same for all eligible tasks for the duration of the contract.

12. Is the feasibility study data issued on a per CPAC basis per task order?

Answer: No, the initial feasibility assessment is a one-time assessment for all CPACs for a full fiscal year worth of data. Data for all CPACs will be included in the data extract for the initial feasibility assessment.

13. As payment goes to VA, is the monthly payment report based on VA’s own collection data?

Answer: A monthly report from the contractor will include the claims the contractor was successful in identifying additional collections. Once the claim payment comes to VA from the third-party payer, VA will compare the claim payment to the report and prepare a payment to the contractor for the contingency fee based on the amount collected.

14. Will financial capability be evaluated on the prime only if its small business with a large business partner?

Answer: Offeror’s financial capability will be evaluated to determine financial viability during the contract. Whatever arrangements/outside financial support the offeror enters into to secure financial viability, it should be included in their submission and will be evaluated. A revision will be made to this section of the solicitation via Amendment 1.

15. Is it more desirable to the government if the prime alone can meet this requirement?

Answer: There is no preference. The Government needs to ensure the offeror can support the contract for the 9-12 months until the claims payments are made to VA. Any information to support the offeror’s financial capability should be included in the proposal.

16. Will the EDI information be available from the Payer Compliance Tool?

Answer: Yes

17. What level of FISMA is required?

Answer: High, reference Amendment 1.

18. Are both VA provided care and community care (Veterans Choice, etc.) claims in scope? Or only care provided directly by VA facilities?

Answer: The scope would include all claims billed to a third-party payer (both VA and Community Care) that are collected/closed.

19. Will the contractor work on all claims or only those 10% or less that VA did not collect?

Answer: The contractor will determine the claims that have additional recovery potential based on the feasibility assessment.

20. On page 19 of the solicitation, it states that “the contractor shall not auto-generate mass mailing or appeal requests”:

a. What is your definition of “auto-generate” in this context?”

Answer: Auto-generate means the use of template correspondence that is generated automatically by a system and is used in a mass mailing without any analysis conducted to determine the collection potential of each claim.

b. Can a contractor use computers or information technology and electronic interface to accomplish the appeal related work envisioned in the solicitation, or must the work be accomplished only manually?

Answer: Yes. Example1: Contractor determines X insurance carrier underpaid X number of claims. Contractor can use information technology to produce number of appeal letters equal to number of claims determined to be underpaid. Example 2: Contractor utilizes its data analytic tool to assess collection potential.

c. If computers and electronic interface are permissible, please describe the permissible uses of computers and electronic interface to identify and collect revenues due to the Department of Veterans Affairs from TPP commercial health insurance carriers.

Answer: Refer to Section B.2 IT Contract Security

d. Please describe the impermissible uses of computers and electronic interface to perform the work under this procurement.

Answer: Refer to Section B.2 IT Contract Security

21. The auto-generation of mass mailing and appeals is a process used successfully by some of the largest hospital facilities in the country and one which was successfully employed by the VA in the past resulting in collections of over $80 million of collected closed claims. What is the rationale for not allowing “auto-generation of mass mailing or appeal requests” for this procurement?

Answer: Refer to answer 20b above.

22. Has the agency conducted a market survey to ascertain its minimum needs for this procurement?

Answer: Yes, market research was accomplished per VA policy and Federal Law.

a. If so, what is the basis for excluding “auto generation” of mass mailing and appeal requests?

Answer: Please refer to answer 20b above.

23. We believe the use of auto-generation of mass mailing and appeal requests significantly improves the cost effectiveness of recovery audit services. Did the agency review the most cost effective processes for performing recovery audit services before deciding to exclude “auto generation” of mass mailing and appeal requests?

Answer: The VA determined its needs and has defined them in the PWS accordingly.

24. We believe the exclusion of “auto-generation” of mass mailing or appeal requests may be unduly restrictive of competition. Will the agency consider removing the exclusion of “auto-generation of mass mailing and appeal requests?”

Answer: No, the PWS is compliant with VA policy and Federal law.

25. In this solicitation why did the agency appear to ignore a clear mandate from Congress? Referenced and Stated by Contractor: The prohibition on “auto-generation” appears to contradict legislative language that appears in the Consolidated Appropriations Act, 2016 (Public Law 114-113), specifically the language in HR 2029, Third Party Fee Collection: The committees have urged VA for several years to improve its systems for collection of 3rd party payments that are owed to VA for non-service connected care for Veterans at both VA and non-VA facilities. The Congress instructed the VA to conduct a pilot similar to the one described in the Senate report and to place emphasis on the use of automated solutions, as recommended in the September Independent Assessment, but also on the use of private sector revenue cycle management techniques and small balance recovery and appeal processes. For reference purposes, we are including below the relevant legislative history instructing the VA to take these steps.

Answer: The VA complies with all Congressional mandates and Federal laws.

a. How is the prohibition against “auto-generation” of appeal requests in the solicitation consistent with these Congressional mandates?

Answer: VA complies with all Congressional mandates and Federal laws.

b. Is this current solicitation being conducted consistent with these Congressional mandates?

Answer: VA complies with all Congressional mandates and Federal laws.

26. In Subfactor – C, Corporate Experience the Solicitation requests the Offeror demonstrate recent (within three years) and relevant work and similar review of 17 million claims over at least 3 geographic areas. In the data provided in the Solicitation there is data on 432,134 claims representing denial data for a fiscal year.

a. How did the agency derive the requirement for 17 million claims over at least 3 geographic areas? We believe this requirement may be unduly restrictive of competition.

Answer: Upon further review the Government will make changes via Amendment 1 to reflect only the denied claims.

b. The Solicitation indicates a preference for small business. We do not believe there is a small business that has handled 17 million claims over at least 3 geographic areas. Did the agency’s market research identify small businesses that have handled the volume of 17 million claims in three years?

Answer: Upon further review the Government will make changes via Amendment 1 to reflect only the denied claims.

c. How did the agency determine that the requirement for 17 million claims over at least three geographic areas represents a minimum need of the agency in light of the significantly smaller data set of 432,134 claims representing denial data for a fiscal year?

Answer: Upon further review the Government will make changes via Amendment 1 to reflect only the denied claims.

27. Did the agency consider whether or not a contractor can perform the feasibility assessment of each CPAC without actually performing the collections work to see if the claims can be collected?

Answer: Yes

28. How can the feasibility of collecting claims be determined without actually performing the collections work to see if the claims can be collected?

Answer: The Government has designed its PWS considering business risk to the contractor and the benefit to the VA.

29. What is the need for the agency to pay for a feasibility assessment if the collection of claims for revenues due to the Department of Veterans Affairs from TPP commercial health insurance carriers will be completed at no cost to the agency?

30. Answer: The Government has designed its PWS considering business risk to the contractor and the benefit to the VA.

31. Please confirm that the feasibility assessment is to be performed on each one of the CPACs before the recovery audit services on CLIN002 begin for any CPAC rather than conducting a feasibility assessment for a particular CPAC and then performing recovery audit services for that particular CPAC.

Answer: Task 6.3 Feasibility Assessment will be performed on all CPAC current collected/closed claims prior to the issuance of a task order for any Eligible Recovery Audit Services (CLIN0002).

32. The solicitation includes the following statement:

A. This procurement is set-aside based on an order of priority as established in 38 U.S.C. 8127. TIERED EVALUATIONS INCLUDING LARGE BUSINESS CONCERNS: This solicitation is being issued as tiered evaluation with the following tiers: (1) SDVOSB concerns, (2) VOSB concerns, (3) small business concerns with HUBZone small business concerns and 8(a) participants having priority; and (4) large business concerns. If award cannot be made, the solicitation will be cancelled and the requirement resolicited.

Please confirm that small business concerns that are not HUBZone or 8(a) participants will have priority over large business concerns in accordance with PPM 2018-04, VA PROCUREMENT POLICY MEMORANDUM – Procedure for Tiered Evaluations (Cascading).

Answer: Yes, all Small Business concerns will have priority over Large Business concerns.

Does VA have any limitations on the number of accesses that will be granted to each VistA system?

Reference: Page 23; Eligible Task: CPAC Recovery Audit Services NCCPAC “Receive access to the VHA VistA system for the purpose of documenting actions taken to pursue additional collections in VistA (TPJI) following CPAC established standard operating procedures.”

Answer: The general answer is no; however, the Government expects the contractor to only request access for the number of dedicated staff who will perform work, and that the contractor will update their list for removal of access as individuals matriculate. Revenue Operations has a unique VistA access system. The system allows a user to have access to as many VistA systems as necessary utilizing a single request form. In addition, access is maintained at all sites with a single access and verify code.

Will VA provide the contractor with VA email accounts with secure email access?

Reference: Page 26 “he contractor shall provide any newly identified and/or supplementary insurance information identified during the audit/recovery process to VA in a report for each appropriate CPAC, delivered through secure e-mail (Deliverable G).”

Answer: Yes.

Can printing take place outside of the CPAC location?

Reference: Page 32; 9. GFE/GFI “Most work can be done remotely from the Contractor location; however, one work cubicle with GFE will be provided for staff member(s) performing printing functions onsite at the Mid-Atlantic CPAC in Asheville, NC.”

Answer: Yes, with appropriate approvals. Refer to B.2. IT Contract Security.

Are there any exclusions to the 35-page limit, such as financial attachments?

Reference: Page 77; Proposal Submission Requirements; Page limit Answer: Yes, financial attachments are excluded from the 35 page limit, see Amendment 1 for update.

When evaluating financial capability, will VA evaluate all team members individually, or will the team be looked at collectively?

Reference: Page 78; Evaluation Factor -1, sub factor A: Financial Capability Answer: Collectively.

Section B.6 Performance Work Statement, 4. Scope of Work, states “Contingent of the results of the feasibility assessment report, there could be a potential performance of recovery audit services for seven (7) CPACs associated with Veterans Affairs Medical Centers (VAMCs).”

a. Does VA anticipate the possibility of no findings? Answer: The VA does not anticipate one likelihood over the other, it is unknown thus generating the need for the Feasibility Assessment Report and use of IDIQ with minimum and maximum order criteria.

Answer: The VA does not anticipate one likelihood over the other.

Can contractor bill new charges for discovered insurance plans not previously denied or underpaid by a third-party payor? Answer: No, the Contractor should report the findings in the Feasibility Assessment Report if later discovered in monthly reporting. The statue allows pursuance of payment for closed underpaid claims and denied claims. Is this correct? Should we had language into the PWS to clear the gray area Answer: No.

Section B.6 Performance Work Statement, 4. Scope of Work, states “The contractor shall not auto-generate mass mailing or appeal requests.”

a. Can contractor use automated system to generate mailings to third parties?

Answer: No Section B.6 Performance Work Statement, 4. Scope of Work, states “The contractor will receive new claims data each year.”

a. Can the contractor receive incremental updates throughout the year to improve timeliness of follow-up actions?

Answer: Please refer to Task 6.4 regarding frequency of data delivery. This sentence is removed from this section. Reference PWS amendment one (1).

Section B.6 Performance Work Statement, Task 6.2: Project Plan, states “Insurance carrier communication plan – At a minimum the communication plan shall include written and verbal methods the Contractor plans to utilize and sample communications”

a. Does communication plan include templates for correspondence?

Answer: No.

Section B.6 Performance Work Statement, 6.3.1 Initial Assessment, states “Upon acceptance, VA will only send those claims that match the criteria agreed to in the initial assessment report for the Recovery Audit Process.”

Does VA foresee reducing/restricting the types of claims or quantities of claims based on assessment report findings?

Answer: Yes, only those claim types identified as having potential collectability will be included in the recurring claims data once audit recovery services are ordered.

Section B.6 Performance Work Statement, 6.4 Eligible Task, states “Receive access to the VHA VistA system for the purpose of documenting actions taken to pursue additional collections…” Will VA permit contractor to use automated system to update VistA accounts?

Answer: No.

Section B.6 Performance Work Statement, 6.4 Eligible Task, states “Prepare and submit documents in support of the claim recovery…Support the claim through the appeal process…”

a. What degree of documentation and what amount of activity is represented in “support the claim…” Answer: The degree of documentation and amount of activity is dependent on the amount of work associated with each claim. The purpose is to ensure the vendor is aware it is responsible for all work associated with the claim. The Government will not provide administrative assistance.

Section B.6 Performance Work Statement, 6.4 Eligible Task, states “…This includes responding to written, telephonic and electronic inquires within the appropriate timeframes…”

b. What are the appropriate timeframes?

Answer: Timelines are associated with each individual carrier’s requirements.

Section B.6 Performance Work Statement, 6.4 Eligible Task, Table 1:

c. Please validate that tables do not include pharmacy claims?

Answer: Yes.

Section B.6 Performance Work Statement, 6.4 Eligible Task, Table 2:

a. Please validate that the table does not include pharmacy claims?

Answer: Same as above.

Section B.6 Performance Work Statement, 6.4 Eligible Task, states “The contractor shall provide VA with a monthly report of the payments (Deliverable B) generated from the accounts.”

a. Please clarify will the VA provide this data to the contractor or is the contractor to execute queries on VA systems to generate reports?

Answer: The Contractor is expected to maintain its own list of claims that the Contractor expects payment to the VA from a third party payer. The VA will compare the actual collections received tot eh Contractor’s list to validate payment of the contingency fee.

Section B.6 Performance Work Statement, 6.4 Eligible Task:

a. Which is the source system from which data are to be derived for Deliverable B?

Answer: The Contractor shall provide a report of anticipated payments from its own tools and resources.

Section B.6 Performance Work Statement, 6.4 Eligible Task:

a. Which is the source system from which data are to be derived for Deliverable C?

Answer: The Contractor shall provide a report of anticipated payments from its own tools and resources.

Section B.6 Performance Work Statement, 8.2 Payment to the Contractor, states “Invoicing by the contractor is not necessary…”

a. What is the mechanism by contractor can establish basis for reimbursement? Submitted Deliverables?

Answer: Please see response to question 51.

Could you share known payer issues for each CPAC?

Answer: Yes

a. If each CPAC is not known, please share the payer issues the VA is aware of for the Florida Caribbean CPAC (FCCPAC) that was reference during the pre-bid conference.

Answer: After award, the Contractor will receive a briefing on the payer landscape for each CPAC upon implementation of the task order for recovery audit services of that CPAC.

Will the contractor have the ability to print from the Ashville location for all 7 CPACs? Can medical records be printed from JLV (Joint Legacy Viewer)?

Answer 1: Yes.

Answer 2: No For a vendor to accurately Will contractors have access to the following government systems:

a. e-denials

b. Payer Compliance Tool (PCT)/Underpayment Identification Tool

c. JLV/CPRS

d. CPAC Workflow Tool Answer to a. : No, this tool is not required for performance of work on collected closed claims.

Answer to b. : Yes.

Answer to c. : Access to CPRS only.

Answer to d. : No, this tool is not required for performance of work on collected closed claims.

Will contractor have access to single sign on CAPRI?

Answer: No, contractors will have access to a single sign on tool that allows for edit capability. CAPRI is a read only system.

Can you tell me where WOSB or small business falls in this tiered evaluation?

Answer: There are four tiers 1.) SDVOSB 2.) VOSB 3.) Small Business Concerns (HUB Zone and 8(a) participants have priority over all other non VOSB small business concerns) and 4.) Large Business Concerns. WOSB or any other SB type fall under tier 3.

Note: This answer rephrases the VA’s tiered evaluation policy for understanding and is not a quotation of the policy verbatim.

Can the Government confirm whether or not this is a new requirement? If not, can the Government provide the incumbent name and contract number?

Answer: This is a new requirement, thus there is not an incumbent name and contract number.

Is the VA allowing companies to subcontract with reputable offshore vendors that have the qualifications and credentials to assist with this project? The company would not "host or store" any of the VA's data offshore, but they will need access to the VA information System to work the denied claims. The company I work with is ISMS certified.

Answer: No, Because of the nature of these requirements, contractors must sign a Business Associate Agreement (BAA). Under a BAA, contractors must agree that any entity performing under the contract are physically located within a jurisdiction subject to the laws of the US and to ensure no data under the contract leaves such jurisdiction without VA permission.

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