ATT110_TPA_QuestionsandAnswers (revised 04.29.25).xlsx

Q&A published 4.29.25 (Amd 7) RFP No. 75D301-25-R-73216 World Trade Center Health Program Third-Party Administrator ATT110, Questions and Answers

Is the TPA responsible for procuring a third party for annual security assessments and penetration testing as part of the program requirements or will this be managed by the government? Note: This was originally question 209, published 3/18/25 with Amendment 2. It was not answered at that time but is being answered now.

The specific auditing pathway will be dependent on the vendor solution; a 3PAO may or may not be required. However, for purposes of the proposal, the offeror should assume that the offeror is responsible for contracting with and paying for a 3PAO assessment on all vendor system(s). If the vendor has an existing FedRAMP auth, 3PAO test results may already be available that may be able to be used.

Program data analysis shows that approximately 45% of all incoming applications are "ever suspended" (suspended at least one time between application receipt through decision). For purposes of this solicitation, Offerors should assume that incoming applications will continue to be suspended at this rate.

273 ATT101 - Summary Volume Data Network Adequacy Tab The NYMA provider tab sums up to a total of 79,451 providers. Section 4.4.1 refers to a volume of 105,500 NYMA providers that need to be adopted into the network. Which value should offerors use as a basis for this function during transition-in? The 105,000 reflects the total number of providers within the EPN, including EPN providers located outside of the NY metropolitan area, while the 80,000 includes only those providers within the EPN that are located within the NY metropolitan area. This discrepancy is due to the current definition of the EPN to include all providers serving CCE members. As the EPN and NPN are consolidated under the TPA, which network a provider is in (EPN vs NPN) will be defined by geographic location. For transition-in, offerors should consider the list of 80,000 as a reasonable approximation of current EPN providers who may qualify to be in the future EPN.

Please also note that requirements have been updated to only require re-affiliation for providers who have had a claim approved within the past 5 years in Amendment 7 to the RFP and the newly provided Attachment ATT118, TPA Network FAQs. The TPA may want to reference the full list to identify potential providers for recruitment to meet network adequacy requirements. The Government is also assessing whether additional data (e.g., rendering provider names and NPIs) can be provided prior to award.

The current environment includes the following, but is subject to change based on the awardee's technical approach and the scope of the TPA contract being wider than the incumbent HPS contract:

The vendor will not be provided WTCHP data (as defined in Attachment ATT017) until an ATO is achieved. The vendor will be provided a de-identified data set for testing. If the vendor has work that needs to be accomplished without the WTCHP-provided data, then that can move forward.

Q&A published 4.8.25 (Amd 4) RFP No. 75D301-25-R-73216 World Trade Center Health Program Third-Party Administrator ATT110, Questions and Answers

Q&A published 4.1.25 (Amd 3) RFP No. 75D301-25-R-73216 World Trade Center Health Program Third-Party Administrator ATT110, Questions and Answers

We opted not to place the Dual Operations phase following the Transition-In Period into its own CLIN because the TPA Contractor will be performing the full scope of services during this Dual Operations phase (unlike the Transition-Out Dual Operations Period, where the TPA Contractor will be performing claims runout activities only). To the extent that offerors’ project a higher level of effort will be required in Option Period 1 owing to the Dual Operations phase following the Transition-In Period, this can be incorporated into offerors’ proposals.

243 6 Section B Can the government provide clarity around the factors driving Time & Materials pricing for CLINx009 Data and Information Exchanges, Integrity, and Governance throughout the life of the contract? This CLIN is priced on a time-and-materials basis for the duration of the Contract for the following reasons:

• During transition-in, the level of effort required to integrate a new TPA contractor into the existing data ecosystem and infrastructure of the Program is not able to be estimated with sufficient accuracy to use a firm-fixed-price contract type because of the highly technical nature of this work, the number of stakeholders, and the sensitive health information being exchanged (and the regulations that must be followed related to it).

• The new TPA contractor will be required to extract, migrate, convert, transform, and load a large amount of data that is not uniformly maintained or structured. The level of effort to perform these complex tasks is similarly not able to be estimated at contract award with sufficient accuracy to use a firm-fixed-price contract type, as the new TPA Contractor would not have clear visibility into all of the Program data and where and how it is stored until after the Transition-In Period begins.

• Even after the Transition-In Period, future changes to the Program (including new or changing other Program contractors) may require additional data exchanges and data integrity and governance work not presently planned.

As with the other time-and-material CLINs in this solicitation, this CLIN may be converted to a firm-fixed-price CLIN through mutual written agreement of the TPA Contractor and the Government after performance begins.

Since pricing for this CLIN may vary based on the number of providers added to the NPN, bidders may propose varying provider volumes, resulting in inconsistent bid pricing. This variation could pose challenges for WTCHP in ensuring a fair price comparison among bidders. Would the government consider either?

• The proposed prime contractor: “[Company name] is submitting a proposal to the Centers for Disease Control and Prevention (CDC) to serve as the prime contractor on the World Trade Center Health Program Third-Party Administrator contract…” (emphasis added)

• and a proposed subcontractor: “or is part of another firm’s proposal to serve as a subcontractor on this contract” (emphasis added).

If the form is being used by a proposed subcontractor to send to its past performance reference(s), the first instance of “company name” will properly identify it as a proposed subcontractor as part of another firm’s proposal.

The unburdened rate provided for proposed subcontractor employees in an offeror’s proposal shall be the employees’ direct, gross wages, and not the rate that the subcontractor charges the prime, to the extent that the subcontractor burdens its unburdened labor rates with fringe, indirect costs, and/or profit in the rate that it charges to the prime.

Q&A published 3.18.25 (Amd 2) RFP No. 75D301-25-R-73216 World Trade Center Health Program Third-Party Administrator ATT110, Questions and Answers

1. Does the government intend for the TPA Contractor to hold direct contractual agreements with EPN providers, or will existing agreements between the Program and EPN providers remain in place?

2. If the existing agreements remain between the Program and EPN providers, what contractual provisions require EPN providers to reaffiliate with the TPA Contractor?

3. Providers are required to undergo credentialing through the TPA Contractor. If credentialing is required through the TPA Contractor, does this apply to all EPN providers regardless of prior credentialing status? Further, what contractual provisions require EPN providers to align to TPA contracts, including credentialing requirements?

4. What are the responsibilities of the Third-Party Administrator (TPA) if a provider within the External Provider Network (EPN) decides to withdraw from participation during the re-affiliation period? 1. Yes. TPA Contactor will enter into agreements directly with EPN and NPN providers. The agreements shall include the Program Terms and Conditions (Attachment ATT016).

2. There is no explicit requirement for current EPN providers to reaffiliate with the new TPA Contractor, but the TPA Contractor shall make a good faith effort to re-affiliate with all existing EPN providers. It is expected that some providers may drop off during the transition-in period. This period should be used to refamiliarize continuing providers with the Program and updated Terms & Conditions.

3. The WTCHP mandates that providers must be credentialed upon initial enrollment. Recredentialing is required every three years for providers to remain part of the TPA. For instance, if a provider was credentialed in December 2023, they must be recredentialed by December 2026, regardless of which entity assumes TPA responsibilities. This policy ensures that all providers consistently meet the necessary standards and requirements without imposing more frequent credentialing than the standard timeframe.

4. If a provider within the EPN decides to withdraw during the re-affiliation period, the TPA Contractor's responsibilities include notifying the Program, managing the transition of patients to other providers, and ensuring continuity of care. The TPA Contractor would be expected to fill any gaps in the network over time consistent with the network adequacy standards in the QASP found in Attachment ATT003.

Please see changes to Section 4.4.1 in Amendment 2 to the RFP.

151 103 4.4.2 NPN Contracting: The RFP requires the TPA Contractor to develop and maintain a Nationwide Provider Network (NPN) that ensures adequate and efficient care for members residing outside the NYMA. Section 4.4.2 indicates that “the TPA contractor shall establish provider agreements on behalf of the Program, utilizing the Program’s Terms and Conditions.” It is unclear whether the privity of contract will be between the TPA Contractor and NPN providers.

1. Can the government confirm that the requirement is for the TPA Contractor to hold direct contractual agreements with NPN providers, rather than the government holding agreements between the Program and NPN providers, with the TPA acting as an agent of the Program?

2. If agreements are between the Program and NPN providers, what contractual provisions are in place to ensure NPN providers engage with the TPA Contractor for contract requirements such as credentialing and training?

1. Yes, the TPA Contractor shall hold direct contractual agreements with NPN providers. The TPA Contractor will have privity of contract with NPN providers. The Government will not have privity of contract with NPN providers.

2. This question is inapplicable per the answer to question 1.

152 102 4.4.1 Existing NPN and EPN Provider Information: To facilitate the transition and ensure network adequacy, will the government provide a comprehensive list of current NPN and EPN providers, including:

- Provider name

- Specialty

- Practice location (full address) (ZIP code)

- Practice Phone Number

- Practice Email, if possible

- National Provider Identifier (NPI)

- Provider Tax ID?

If a full provider list cannot be provided due to contractual or confidentiality limitations, can the government provide de-identified aggregated data on provider distribution by specialty and zip code?

1. Can the government provide the actual fee schedule that must be incorporated into provider contracts, including reimbursement rates by CPT code and specialty?

2. If the government cannot provide an exact fee schedule, what methodology should bidders use to set provider reimbursement rates?

3. Will the government provide a hierarchy of reimbursement? Example: If the code is present on FECA, then it will be reimbursed at FECA. If not present on FECA, it falls to CMS, if not present on CMS, does the government have an additional Fee Schedule or would this fall to billed charges?

4. Will the government provide whether or not there are current providers on fee schedule exceptions?

1. The WTC Health Program fee schedule is updated quarterly; incorporating a static fee schedule into provider contracts would not be appropriate. Please find the current WTC Health Program fee schedule in Attachment ATT028, WTCHP Fee Schedule, in Amendment 2 to the RFP. The WTC Health Program fee schedule is updated quarterly.

2. See response to question 1. Furthermore, please note that provider reimbursement rates are exclusively set by the Program.

3. The Program generally uses OWCP (FECA). If the code is not present, CMS and/or other federal payers' fee schedules are referenced as a benchmark. Any unpriced codes would need to be escalated to the Program for the Program to set the appropriate rate(s).

4. There are a very limited number of providers on a fee schedule exception--for the most part, designated cancer hospitals and a couple of other facilities that we have agreed to pay at cost-to-charge ratio instead of DRG pricing. In rare cases (<10 currently), the Program has also authorized temporary exceptions to ensure continuity of care for members in active treatment.

Will the government please clarify specific requirements for:

1. Are there particular types of clinical data that should be excluded to protect Member privacy or comply with regulatory standards?

2. What is the criteria or process for determining information to be relevant in the member profile?

3. Which specific categories or types of clinical information could be considered relevant for providers within the portal? Can the government provide examples or use cases that illustrate the types of clinical information deemed relevant versus those that are not, to help guide our implementation strategy?

This investigation does not result in a national security clearance.