47QFMA19F0016 DHA Tier 2.5 MOD 09 Limited Sources Justification_Redacted.pdf

GSA ASSIST: 47FMA19F0016 10/13/2021

GSA, FAS Mid-Atlantic Region

LIMITED-SOURCES JUSTIFICATION

FOR

Defense Health Agency (DHA) Proactive Data Quality Reconciliation & Tier 2.5 Helpdesk Support

Paper Record Tracking (PRT) & Air Force Data Quality Support

Modification 09

Note: This document is prepared in accordance with the requirements of FAR 8.405-6(c). The acquisition is conducted under the authority of the Multiple-Award Schedule Program.

1. Identification of Requiring Activity and Contracting Activity:

The requiring activity is the Defense Health Agency, 7700 Arlington Blvd Suite 5101 Falls Church VA 22042. The contracting activity is the GSA Federal Acquisition Service (FAS), Mid-Atlantic Region - Philadelphia, PA.

This document is hereby identified as a Limited-Sources Justification.

2. Nature and/or Description of Action Being Approved:

The action being approved is a modification to add within scope work resulting in an increase to the overall value of the DHA Proactive Data Quality Reconciliation & Tier 2.5 Helpdesk Support order number 47FMA19F0016 under the TMCI (The McVey Company) IT Schedule 47QTCA19D0006. This action is crucial in order to facilitate the decommission of the Medical Record Tracking (MRT) System module of the Composite Health Care System (CHCS) and transition into the new paper Record Tracking (PRT) system and perform proactive data analysis in support of Air Force data quality efforts including patient records for the United States Space Force in DHA’s Electronic Health Record (EHR) systems.

Proactive Data Quality Reconciliation & Tier 2.5 Helpdesk Support was competitively awarded in the amount of on 03 July 2019. The period of performance consists of an eleven (11) month base period of 10 July 2019 through 09 June 2020 with four (4) one-year option periods.

3. Description of Supplies/Services Required To Meet the Agency's Needs:

The requirements for this action are necessary to provide the requisite support for DHA in order to deliver clinical IT solutions that enable quality continuity of care and timely administration of benefits. DHA requires proactive data quality support to correct missing and/or invalid Department of Defense Identification Numbers (DODIDs) across the Composite Health Care System (CHCS), legacy electronic health record system, in order to provide timely transition of DHA’s tracking of paper medical records currently performed in the Medical Record Tracking (MRT) module into the new Paper Record Tracking (PRT) system of the replacement electronic health record system MHS GENESIS. This effort includes performing analysis and remediation of patient identity data quality issues found on Government specified systems (e.g., CHCS, CDR, APLIS, HAIMS, PRT, MHS GENESIS, as well as other systems as determined). Additionally, DHA requires analysis and remediation activities for former Air Force now United States Space Force members as well as updates in CHCS to Patient

Category (PATCAT), rank, service, and Unit Identification Code (UIC). This effort involves delivering newly created process assets used to identify, analyze, track, and resolve patient identity, multiple patient records, unmerges, and other data quality issues in advance of CHCS decommission activities.

4. Identification of Statutory Authority and Justification/Rationale for Limiting Sources Demonstrating the Contractor's Unique Qualifications to Provide the Required Supply/Service:

The authority for this action is FAR 8.405-6(a)(1)(i)(A) – An urgent and compelling need exists and following the procedures would result in unacceptable delays.

Brought to the Data Quality & Integration (DQ&I) Program to assist with the transition of the tracking of paper medical records currently performed in the Medical Record Tracking (MRT) module of the Composite Health Care System (CHCS), the PRT support is an urgent and compelling requirement which will allow the Defense Health Agency (DHA) to successfully decommission the CHCS systems across the enterprise. The PRT is a centrally hosted application that supports the global tracking and standardization of physical medical records that are stored in record rooms at Medical Treatment Facilities (MTFs) across the Enterprise.

This current requirement emerged out of a need for contractor support on behalf of the Local Patient Administration Division (PAD) personnel who are currently working on the deployment of MHS Genesis. However, due to staffing issues related to COVID-19, the Local PAD was not able to fully support this effort.

This resulted in a recent discovery of missing/invalid DODIDs across the enterprise. Some of the impacts associated with these missing/invalid DODIDs include but are not limited to:

Inability to uniquely identify patients in any DHA electronic health system, inability to create a longitudinal health record for patients across DHA systems, and duplicative, delayed or unnecessary lab tests, radiology visits, exams and other medical procedures.

Legal and malpractice costs, regulatory compliance fines, and increased Help Desk costs including IT staff and provider input from multiple departments.

Health Data unable to be properly used for viable patient metrics, analytics, and population health analysis, increased risk of fraud and abuse, accidental or improper disclosure as well as operational inefficiencies due to repeat administrative and medical costs, provider time searching and working with multiple records and wasted patient time.

These challenges have led to severely unplanned delays in the deployment of MHS Genesis which has contributed to unplanned costs.

The new PRT system is implemented on an Enterprise Content Management (ETM) and Business Process Management (BPM) platform with a modern, graphical user interface to replace the legacy Medical Record Tracking module in CHCS. Therefore, when fully deployed, the PRT will be used by 500 records room staff members, track 5 million physical medical records across Department of Defense (DoD) and facilitate 3 million transfers between MTF’s each year. The PRT will not only improve the transfer process by automating and tracking requests between MTFs, but it will also automatically track record movement history throughout the record’s lifecycle. These key benefits as a result will lower sustainment costs by leveraging a COTS platform.

Accelerating the deployment of the PRT would not only mitigate patient safety concerns and impacts identified above, but it will generate additional significant cost savings by reducing the decommissioning timeline from 379 days by 259 days to 120 days post deployment. CHCS is currently one of the largest and most expensive legacy health IT systems to maintain. The daily cost of sustaining a single CHCS host is $861.There are currently 101 hosts that are being maintained. As such, the daily cost of sustaining 101 CHCS hosts is approximately $87,000. The total cost of maintaining all hosts at the current decommissioning timeline of 379 days is $32M. Reducing the decommissioning timeline from 379 days by 259 days to 120 days has a potential cost savings of $22.5M. Furthermore, more potential cost savings can be achieved as a result of a separate effort involving the deployment of a script to automate pharmacy refills, a task currently performed within CHCS. If CHCS data becomes static at the decommissioning timeline of 120 days and a total of 259 days of sustainment are saved, potential additional savings may range from $4M-$8M.

Without the PRT support, the Defense Health Agency (DHA) cannot decommission the CHCS systems across the enterprise. There are numerous regulatory requirements for paper medical record tracking that prohibits the DHA from decommissioning CHCS prior to full implementation of PRT at each Military Treatment Facility (MTF) and thousands of clinics across the globe. There are an estimated five (5) Million paper records that must be accurately imported into the PRT system to meet the regulatory requirements and ensure separating Service Member medical records are readily available for VA benefits adjudication.

Regulatory Requirements:

DHA Interim Procedures Memorandum (IPM) 18-018, Physical Custody and Control of the DoD Health Record DHA Administrative Instruction (AI) 047, Transfer and Shipment of Federal Records DoDI 6040.45, DoD Health Record Life Cycle Management DoDI 5015.02, DoD Records Management Program OSD Administrative Instruction (AI) 15, OSD Records and Information Management

Program National Archives and Records Administration (NARA) Disposition Schedule N1-330-

01-002, N1-330-10-003, and General Records Schedule (GRS) 2.7 NARA requirements:

o https://www.archives.gov/records-mgmt/policy o https://www.archives.gov/about/laws/fed-agencies.html

NDAA2014, Public Law 113-66 Sec 525 Statutory Authority:

Title 44, United States Code, 2904, 3101, 3102, and 3105.

OMB Circular A-130, Management of Federal Information Resources, applies to records and information systems containing records Chapter XII, subchapter B of Title 36, Code of Federal Regulations o 36 CFR 1236.20 (4) o 36 CFR 1236.4 o 36 CFR 1222.34 ISO 15489-1:2001, which was replaced by 15489-1:2016, Section 5 (Note: ISOs are

International Standards

The DQ&I Program was notified in April 2021 that the DHA and Air Force Medical Readiness Agency (AFMRA) agreed to transfer roughly three dozen contracts to DQ&I in accordance with Section 702 of National Defense Authorization Act (NDAA) 2017 directing the transfer of certain authorities and control from the Military Departments to the Defense Health Agency.

Section 702 of NDAA 2017 includes eliminating duplicative activities carried out by the elements of the DHA and the military departments and maximizing efficiencies in the activities carried out by the DHA. As such, DHA must provide support for the Air Force Data Quality requirements including updating of patient records to United States Space Force members in DHA’s Electronic Health Record (EHR) systems and support other Air Force data quality initiatives. One of the current Air Force data quality contracts is scheduled to expire on 11/3/2021. In order to avoid a lapse in service, DHA requires contractor support to leverage the established DHA enterprise-wide data quality service framework in support of Air Force data quality efforts by providing quality assurance capabilities, metrics, tracking, and ongoing patient identity data quality management support in advance of CHCS decommission activities. Furthermore, this new requirement involves delivering all newly created process assets used to identify, analyze, track, and resolve patient identity, multiple patient records, unmerges, and other data quality issues. Without this support the DHA will falter on its agreement with AFMRA, not be in compliance with section 702 of NDAA 2017 and introduce patient safety issues affecting patient care at Air Force Military Treatment Facilities (MTFs).

Similarly to the patient safety concerns identified above with the decommissioning of the MRT, delays in this effort could result in duplicate record issues, crossed or mixed records, patient demographic issues, billing issues as well as repeat studies and misdiagnoses. This urgent requirement will provide technical and analytical expertise to support data quality, analysis, and remediation for Proactive Data Quality Initiatives in order to mitigate patient safety issues and comply with regulatory requirements as outlined in Section 702 of NDAA 2017.

TMCI has provided acceptable support for DHA Proactive Data Quality Reconciliation since July 2019. In addition, TMCI currently provides support for the deployment of PRT at Madigan Army Medical Center. TMCI possesses the in-depth knowledge and technical expertise to continue supporting the Proactive Data Quality requirements at the level of quality and the timeframe required without interruption. The agency need for these services are extremely urgent, therefore, soliciting competition for these services would result in a substantial duplication of cost to the Government that is not expected to be recovered. Unrecoverable costs include the time of technical and contracting personnel to determine an acquisition strategy, review and evaluate the proposal, and prepare documentation for award.

Additionally, the Government would be impacted by the unnecessary costs associated with credentialing a new contractor to execute the requirements which would result in further delays as a result of the time that would be required for a new contractor to be brought up to speed and execute the requirements.

The information above reinforces the fact that it is imperative that this work continue under the current task order to prevent unacceptable delays. TMCI is fully capable of providing the required services immediately to sufficiently support DHA Proactive Data Quality’s requirements. TMCI has the requisite knowledge and proven experience and expertise in undertaking this initiative to complete it effectively and on schedule.

5. Determination by the Ordering Activity Contracting Officer that the Order Represents the Best Value Consistent with FAR 8.404(d):

The assigned GSA Project Manager will complete a technical evaluation on the contractor’s technical submission to ensure that the quoted labor mix and number of hours are acceptable and commensurate with this requirement and that the contractor has adequately responded to all technical requirements. The assigned GSA Contracting Officer will complete the price evaluation by conducting a price analysis ensuring that there are no math errors or pricing caveats. Quoted labor rates will be checked to ensure that they are reflected in the contractor’s current GSA IT-70 Schedule contract. It is anticipated that the rates proposed for this effort will reflect either a close similarity or the same rates as currently being paid to TMCI under the existing task order which have already been determined to be fair and reasonable. The Contracting Officer has determined that this effort will result in the greatest overall benefit to the Government in response to the requirement, attaining the best value, and fair and reasonable prices.

6. Description of Market Research:

Market Research was conducted in accordance with FAR 10. A review of GSA Advantage and other sources of information for the required services showed that other firms can provide this type of service; however, as stated above, TMCI’s requisite knowledge and proven experience and expertise is the best approach in support of the requirements in order to mitigate patient safety concerns and other impacts identified above and generate significant cost savings without delay.

7. Other Facts Supporting the Justification:

None

8. Actions the Agency May Take to Remove or Overcome Any Barriers that Led to the Restricted Consideration prior to Subsequent Acquisition For the Supplies or Services:

If future expenditures and allowances are granted for continued support during the period of performance of this Task Order, all efforts will be made by the Government to seek alternate sources of service for the support.

However, it is important to note that many variables will play into this alternative source potential, such as regulatory requirements and changes in Government priorities within the current operations and shifting needs.

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