WC-MCMS BPA LSJ Redacted.pdf

OPOAM 3008.405-6(a)(2) Limited-Sources Justification (LSJ)

For orders or BPAs exceeding the Simplified Acquisition Threshold

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LSJ No.: FY25-016

This acquisition is conducted under the authority of the Multiple-Award Schedule Program, 41 U.S.C. 152(3), Competitive Procedures, and 40 U.S.C. 501, Services for Executive Agencies.

1. Agency and Contracting Activity.

The Department of Homeland Security (DHS), Office of Health Security (OHS), proposes to award a Blanket Purchase Agreement (BPA) pursuant to FAR 8.405-6(a), Limiting Sources. (More specifically, the BPA will be awarded as a logical follow-on pursuant to FAR 8.405-6(a)(1)(i)(C).)

2. Nature and/or description of the action being approved.

DHS/OHS intends to limit the number of sources solicited pursuant to FAR Part 8.405- 6(a) for the procurement of services required to implement an enterprise-wide unified and strategic approach to improving the efficiency and effectiveness of the Department’s Worker’s Compensation Program to Managed Care Advisors (MCA), Inc., 7700 Old Georgetown Rd., Suite 750, Bethesda, MD 20814-6100.

3. Description of Supplies/Services.

The requirement is to provide a full range of Workers’ Compensation – Medical Case Management Services (WC-MCMS) for DHS. WC-MCMS Services are required throughout the United States in all 50 States, the District of Columbia, and U.S.

Territories including Puerto Rico, U.S. Virgin Islands, Guam, Northern Mariana Islands and American Samoa.

The Contractor shall be required to provide support for new or historical WC cases, or the combination of both. This determination will be made at the BPA Call level. The Contractor shall be required to proactively manage cases of all durations, including long-term/periodic roll (PR) claims, from the First Report of Injury (FROI) through a successful Return-to-Work or case resolution.

Under the DHS Enterprise-Wide WC-MCMS activity, DHS requires that the Contractor support all agency personnel with new work-related, pre-existing and PR Payment Schedule injuries and illnesses; provide a toll-free injury reporting hotline, available 24/7;

continually facilitate Medical Case Management interaction with the employees and the medical community; deliver a nationally integrated network of WC-Medical (Doctors and Nurses) Care Management Services; offer an efficient intake process and system of records; deliver an Information Technology (IT) system that encompasses and existing and operational case and reporting Management Information System (MIS) hosted in a Federal Risk and Management Authorization Program (FedRAMP) ready secure cloud

- 3 -significant, as it includes consulting fees, readiness assessment reports, third part assessors, funds to stand up a dedicated FedRAMP environment, a security capability, and multifactor authentication. Since the existing WC-MCMS effort currently operates under DHS OCIO ongoing authorization, the Government would not incur the duplicative costs to bring a new system along to the same point as the current WC-MCMS system. In achieving a FedRAMP-ready system and maintaining an ATO, the estimated breakdown for these costs for a new Contractor are noted below.

• Engineering and Readiness Assessment: average cost - These are costs associated with implementing technical changes to a system to meet the Federal requirements (e.g., FIPS 140-2 encryption, PIV/CAC for authentication, etc.).

• Documentation: average cost - These are costs associated with documenting the system in policies and procedures, the System Security Plan, Incident Response Plan, etc.

• Third Party Assessment Organization (3PAO) Assessment: average cost – These are costs associated with the independent assessment by a FedRAMP Accredited 3PAO including the development of a test plan, onsite assessment, creation of the security assessment report and briefings to authorizing officials.

• FedRAMP Joint Authorization Board (JAB) Review: average cost – These are costs associated with updates required due to meeting the JAB requirements (e.g., areas where a Cloud Service Provider (CSP) didn’t fully meet the FedRAMP requirements prior to entering the assessment process).

A critical requirement of the DHS requirement is the ability to provide a nexus of medical professionals with Federal workers’ compensation experience within medical case management. MCA has the distinction of having proven performance success in the DHS environment in terms of improved medical and vocational outcomes, improved early intervention and return to work metrics, and reduced continuation-of-pay and chargeback expenses. MCA services have also expanded DHS’s ability to develop and enforce policy as well as support procedural and personnel decisions across components based on timely and reliable information. MCA’s policy knowledge creates efficiencies and reduces the lead time for another contractor to provide all MCMS services, while also evolving to adhere to all changes in both DHS component needs and federal regulations. New contractors often experience steep learning curves and, as a result, contract performance can be slow to start until the new Contractor gains sufficient knowledge of the organization and the operating environment.

MCA's cadre of nurse case managers are licensed (RN) certified by MCA and have gone through credentialing in the National Practitioner Data Bank (NPDB) and certified by DHS.

The NPDB is an information clearinghouse containing information on adverse actions related to health care providers and supplier, as established by Congress in 1986. This tool prevents

- 4 -health care providers from moving state to state without disclosure or discovery of previous adverse performance information. MCA is currently leveraging and staffing an average of licensed medical personnel and medical case managers annually. A new contractor would be required to recruit, hire, and credential an equivalent number of licensed medical personnel with intimate working knowledge of federal workers’ compensation. Staffing licensed medical professionals (including physicians) is in the interest of economies and efficiencies since market conditions do not currently show another GSA Schedule contractor with a MCMS system that has this staff feature. The time to attain and onboard a new cadre of or more NPDB-credentialed medical professionals would significantly decrease efficiency and delay performance.

Additionally, DHS would lose efficiencies. DHS would be subjected to unacceptable delays in fulfilling an enterprise-wide strategic sourcing solution to enhance mission performance and optimize acquisition excellence across DHS with an uninterrupted, integrated, and consistent process across all of its components for the coordination between injured employee, medical professionals, and DHS WC personnel. To meet DHS system security requirements, the WC-MCMS III IT solution must be FedRAMP ready. From a security authorization standpoint, DHS placed MCA’s IT solution under ongoing authorization in June 2017, and the solution underwent its most recent contingency plan test in September 2024. Understanding the time and cost to achieve FedRAMP ready (average 60 days), FedRAMP Authorized (average 4 months), and a full DHS Authorization to Operate (ATO) (average 12 months) is key to ensuring DHS has continued and uninterrupted services.

Conservative estimates place the time for a contractor to complete the process to achieve the necessary FedRAMP approvals and final DHS ATO decision at 24 months. As noted, the (duplicated) cost for contractors to invest in the FedRAMP process is also significant at an estimated cost of $

It is important to note that DHS does not own the current WC-MCMS IT solution being employed under this ongoing requirement. MCA owns the WC-MCMS IT solution, known as WebOPUS. Under the DHS WC-MCMS requirement, it is the Schedule Contractor’s responsibility to provide an existing IT system/platform that encompasses an existing fully operational FedRAMP ready Case Management and Reporting MIS hosted in a secure environment. From an economy standpoint, not only would DHS assume the financial cost associated with data migration, should MCA not retain this work, but the process of selecting, preparing, extracting, and transforming data and permanently transferring it from one secure system to another would introduce unnecessary risk to both operational timelines and data security.

MCA’s tailored IT capability is fully compliant with DHS IT architecture and security requirements. The WC-MCMS (WebOPUS) system resides in the Infrastructure as a Service. MCA has dedicated considerable resources tailoring their WebOPUS IT solution to DHS’ exact specifications to serve as a secure web-based case management database and document storage system to store, document, and report all case management activities, and to monitor program and employee performance. Recent case

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5. Determination by the ordering activity contracting officer that the anticipated order represents the best value consistent with FAR 8.404(d).

The Contracting Officer has determined that the proposed logical follow-on BPA to Managed Care Advisors, for Workers' Compensation Medical Case Management Services represents the best value and will result in the lowest overall cost, considering price and administrative costs, to meet the Government's needs. For the current effort, costs have been incurred for the development of the WebOPUS tool that has already received DHS ongoing authorization. Cumulative costs associated with getting the FedRAMP-ready WebOPUS IT solution to the ongoing authorization phase have been incurred over multiple contracts, starting with the original WC-MCMS BPA requirement in 2013. Because these successive contracted costs were sustained under multiple previous awards utilizing the same IT solution, it is in the interest of economy and efficiency to conduct a logical follow-on with MCA, as MCA owns the meticulously tailored IT solution.

In addition, this BPA will be placed in accordance with FAR 8.404, “Use of Federal Supply Schedules.” The GSA has already negotiated fair and reasonable pricing rates.

Discounts to these GSA schedule rates will be requested. Additionally, prior to issuance of the BPA, the ordering activity will consider the level of effort and the mix of labor proposed to perform the specific task being ordered to determine that the total price is reasonable. The Contractor’s labor mix and level of effort will also be compared to the Independent Government Cost Estimate (IGCE).

6. A description of the market research conducted among schedule holders and the results, or a statement of the reason market research was not conducted.

A Request for Information (RFI) was published on August 9, 2024, in GSA eBuy under Request for Quote (RFQ) ID RFQ1717315, closing August 23, 2024, using GSA’s Market Research as a Service (MRAS) offering. The RFI sought to better understand the current capabilities of GSA Schedule contractors to provide a full range of workers’ compensation medical case management services for DHS to assure timely and successful return of DHS employees to the workforce, and to deliver an integrated MCMS solution encompassing injury care support services, medical case management services, and a FedRAMP-Ready information technology solution that incorporates an existing case and reporting management information system.

GSA’s MRAS RFI resulted in six sources responding, with responses overwhelmingly indicating that no small businesses were capable of meeting the WC-MCMS requirement.

With the exception of MCA, the RFI revealed that respondents to the RFI only possessed the capability to build a case and management information system as part of a “sole-source pilot” – which runs counter to the stated requirement that the contractor must have an existing FedRAMP-Ready solution, to include services and capabilities – and failed to

- 8 -the FECA. Additionally, DHS’s Workers’ Compensation Program Manager conducts regular trainings at this event. This and similar educational and network events provide opportunities to stay abreast of updates on federal workers’ compensation practices and emerging trends in private companies offering medical case management services.

9. Within 14 days after establishing the BPA, DHS will post the notification and this

LSJ on System for Award Management (SAM.gov) pursuant to FAR 8.405- 6(a)(2)(i).

10. Technical/Requirements Personnel Certification.

Pursuant to FAR 8.405-6(c)(2)(x), I certify that this requirement meets the Government’s minimum need and that the supporting data, which form a basis for the Limited-Sources Justification, are accurate and complete.

Technical Representative/COR Date

11. Contracting Officer Certification and/or Approval *

Pursuant to FAR 8.405-6(c)(2)(ix), I certify that the Limited-Sources Justification is accurate and complete to the best of my knowledge and belief:

Contracting Officer

12. Approval.

Date

Head of Contracting Activity Date