2018-05-15_BFCC_Pre-Solicit_Conf_FINAL-508_Final.pptx

Welcome!

Beneficiary & Family Centered Care

(BFCC)

Quality Improvement Organization

(QIO)

Pre-Solicitation Conference May 15, 2018 | Baltimore, Maryland 10:00 am – 4:00 pm

Please note that today’s session is being recorded.

Welcome

Steven Rubio, MGA, BSN, RN Director, Division of Beneficiary Health Improvement & Safety Quality Improvement & Innovation Group

Phyllis Lewis Director, Division of Quality Contracts Office of Acquisition & Grants Management

Remarks from Leadership Megan Worstell Acting Deputy Director, Center for Clinical Standards & Quality

Melissa Starinsky Director, Office of Acquisition & Grants Management

Dennis Wagner Director, Quality Improvement & Innovation Group

Important Key Messages & Caveats Current Beneficiary & Family Centered Care (BFCC) Indefinite Delivery / Indefinite Quantity (IDIQ) Request for Proposal (RFP) and Task Orders are Draft, not Final The government has not made any final decisions about the elements of the Draft Task Orders and funding amounts Elements of the Task Orders may change or be eliminated altogether Projected volumes for work may change Any work or contract actions outlined in the Draft IDIQ and Task Orders will be “subject to availability of funds” and in no way represent a government commitment to fund this work

Ground Rules and Housekeeping Agenda Questions Please send questions to BFCC2019@cms.hhs.gov Q&A Team will be monitoring questions as they are received throughout the conference via mailbox submissions Q&A Panel RFP Amendment Session is being recorded and closed captioned Housekeeping for In-Person Participants Security Wi-Fi – access information on back of the agenda Restrooms Breaks & vending machines Lunch

Meet Our Presenters

Confidence Gbarayor, PhD, MPH CMS BFCC Program Coordinator

Cheryl Lehane, RN, CPHQ

BFCC NCC COR

Tiffany Jackson-Dickey, PMP

BFCC-QIO/QMARS SME

Roni Garland, MS, PMP, FAC P/PM III

QIO Program Manager, ISG

Michael Milanese Contracting Officer, OAGM

Greg Gesterling Contractor Compliance Officer Policy, Quality, Data & Systems

OAGM

Bridget Rineker, Director Division of Financial Services Audit & Workforce Group

OAGM

Brandon Williams Senior Financial Management Specialist, BOG

BFCC Program Changes

Steven Rubio, MGA, BSN, RN Director, Division of Beneficiary Health Improvement & Safety Quality Improvement & Innovation Group

Phyllis Lewis

Friendly Reminder: This session is being recorded.

CMS/Stakeholder Listening Sessions 12th SoW Suggested Improvements Enhance the Beneficiary Care Experience Increase the use of Immediate Advocacy Increase the use of Beneficiary Healthcare Navigation for beneficiaries with complex healthcare needs Increase beneficiary knowledge of BFCC-QIOs and their right to high-quality healthcare Improve BFCC-QIO Data and Analytics BFCC-QIO Satisfaction Survey - beneficiary and provider perspective Case Review - publish trends in Complaints and Quality of Care Concerns to identify improvement opportunities Claims Review - to determine cost savings from programs such as Two Midnight (2MN) and Higher Weighted DRG (HWDRG) Reviews

BFCC RFI – What we heard… Key Acquisition Responses Preferred an SOW over performance-based acquisition for case review An IDIQ would make BFCC more attractive National level work is not an incentive to propose All respondents indicated significant interest in the program Preferred the CMS agency 10 region structure

Acquisition Strategy

BFCC Program Changes for the 12th SoW BFCC-QIOs Case Review Services based on the CMS Regional Structure BFCC National Coordinating & Oversight Review Center (NCORC) (Independent) IT Improvements Expanded Focus on Advocacy by “Putting Patients First” Data-Driven Improvements and Outcomes

Framing of the BFCC-QIO Work: Current State & Near Future

Confidence Gbarayor, PhD, MPH CMS BFCC Program Coordinator

“Every system is perfectly designed to achieve the results it gets.”

-Dr. Donald Berwick

Evolution of BFCC to Advancement Under QIO 12th SoW in “Putting Patients First”

BFCC-QIO Program:

11th SoW Core Functions

BFCC-QIO PFE Activities:

Alignment with CMS Strategic Goals “Putting Patients First”

BFCC-QIO Program:

Anticipated 12th SoW Core Functions

BFCC QIO Program:

Anticipated 12th SoW Strategic Goals & AIMs (1 of 2)

BFCC QIO Program:

Anticipated 12th SoW Strategic Goals & AIMs (2 of 2)

BFCC-QIO 12th SoW Case Review Regional Structure

12th SoW BFCC-QIO Collaboration Opportunities In carrying out its responsibilities for all BFCC functions, BFCC-QIOs shall collaborate with CMS contractors and other entities, including but not limited to:

Other Beneficiary & Family Centered Care (BFCC) Program Components NQIIC IDIQ contracts such as: Quality Innovation Networks (QINs) State Survey Agencies (SSAs) Medicare Administrative Contractors (MACs) Recovery Audit Contractors (RACs) Qualified Independent Contractors (QICs) Unified Program Integrity Contractor (UPIC) Zone Program Integrity Contractor (ZPIC) Office of Inspector General (OIG) Office for Civil Rights (OCR) Office of Medicare Hearings & Appeals (OMHA) Departmental Appeals Board Pertinent State-based Organizations Appropriate Federal Partners

Break

Last call for questions to be considered for Q&A panel

Please send questions to:

BFCC2019@cms.hhs.gov

BFCC 12th SoW Services

Cheryl Lehane, RN, CPHQ CMS Contracting Officer’s Representative

“Through Patients Over Paperwork, we’re advancing quality care to establish a system that always puts patients first.”

-Seema Verma, CMS Administrator

BFCC 12th SoW Services (1 of 3)

BFCC 12th SoW Services (2 of 3)

BFCC 12th SoW Services (3 of 3)

Initial Task Orders Beneficiary Protection: Case Review Services

National Coordinating & Oversight Review Center Must be independent Special Innovation Projects

Information Technology & Security QIO 12th SoW Contractors

Tiffany Jackson-Dickey, PMP

BFCC-QIO/QMARS SME

Roni Garland, MS, PMP, FAC, P/PM III QIO Program Manager Information Systems Group

Information Technology & Security QIO 12th SoW Contents IT Improvements Systems/Applications Virtual Access Security Policies Security Responsibilities Security Controls Assessments and Corrective Actions

IT Improvements (1 of 2) Systems/Applications Quality Management & Reporting System (QMARS) National, web-based case management and review system that allows the BFCC-QIOs to track medical records and perform online case reviews BFCC-QIO / CMS System of Record Enhancements to System in 12th SoW include:

Content Manager (Medical Records) Electronic Fax Capability Historical Data Read Access to historical case review data Any transfer of medical records or other sensitive information must be done via a secure and CMS-approved method

QMARS is the system of record, any shadow systems are the QIOs responsibility to maintain

IT Improvements (2 of 2) Virtual Access Virtual Desktop Infrastructure (VDI) Virtual Private Network (VPN)

Users are expected to abide by the HCQIS CFE Policy, which will be published on QIONet.

ISG

During 11th SOW, we made multiple enhancements to our solutions: including VDI Key point: there is no IT GFE, this includes (…), the BFCC will be expected to provide BFCC-QIO contractors are responsible for providing and acquiring all necessary hardware, software and all telecommunication/circuit resources to connect to the HCQIS environment via Cisco ISE virtual private network (VPN) or by virtual desktop infrastructure (VDI).

Security Policies All CMS contractors and subcontractors shall comply with Federal, HHS, and CMS security policies:

Federal Information Security Management Act of 2002 (FISMA) National Institute of Standards & Technology (NIST) Standards & Guidelines CMS Information Systems Security and Privacy Policy (IS2P2) CMS Acceptable Risk Safeguards (ARS) CMS Risk Management Handbook (RMH), Security Standards & Procedures Personally-Owned equipment is prohibited from connecting to the HCQIS environment in any manner www.cms.gov/Research-Statistics-Data-and-Systems/CMS-Information-Technology/InformationSecurity/Information-Security-Library.html

Security Responsibilities Security Point of Contact (SPOC) to oversee compliance Security Awareness Training (SAT) required prior to contract performance HHS and CMS Rules of Behavior (RoB) apply Document security compliance includes but not limited to:

System Security Plan (SSP) Risk Assessment Report Comply with security controls and corrective actions Check at least every 30 calendar days for updates CMS security website (http://www.cms.gov/Research-Statistics-Data-and-Systems/CMS-Information-Technology/InformationSecurity/Information-Security-Library.html) QualityNet security website (http://qionet.sdps.org)

QIO Eligibility Requirements

Steven Rubio, MGA, BSN, RN Director, Division of Beneficiary Health Improvement & Safety Quality Improvement & Innovation Group

QIO Eligibility Requirements

42 CFR 475.101

Governing body that includes:

At least one (1) individual who is a representative of health care providers; and At least one (1) individual who is a representative of consumers.

QIO Area Geographic area such as the state(s), region(s) or community(ies) in which the CMS contract directs the QIO to perform.

Must have the ability to perform QIO functions with objectivity and impartiality in a fair and neutral manner.

Not required to be physician-sponsored or physician-access organizations.

All other eligibility requirements should be met through submission of an acceptable proposal.

Requirements for QIOs that Perform Case Review Peer Review – Must have access to multiple levels and disciplines of clinicians and locally licensed physicians who:

Specialize as appropriate for care under review.

Understand the geographic factors that may influence care.

Consider evidence-based national guidelines and standards.

Physicians will still review physician-level care.

Involve beneficiaries and consumers in their work.

Includes the ability to effectively communicate with beneficiaries about the quality of their care and the QIO’s review findings.

Requirements for QIOs that Perform Quality Improvement Set or implement acceptable, quantifiable performance objectives to improve quality efficiently and effectively.

Engage multiple levels and disciplines of clinicians.

Includes physicians, nurses and other healthcare professionals;

Clinicians must have expertise appropriate to the care being improved Employ experts in quality improvement methods, who can:

Support aim achievement and plan quality improvement activities, Implement and/or support interventions to drive change, Use measurement strategies to study improvement, Support and conduct data analysis, and Advise others to make systems-level improvement and efficiencies.

Must have access to qualified IT resources.

Lunch (12:00 pm – 1:15 pm)

BFCC-QIO

Contracting Overview

Michael Milanese Contracting Officer Division of Quality Contracts

BFCC IDIQ Contract Structure Multiple-award IDIQ contracts: Full and Open Competition IDIQ ordering vehicle for Task Orders Maximum Ceiling/Minimum Guarantee Period of Performance Scope of Work Ramp on/Ramp off

BFCC Task Orders FAR 16 for Future Task Orders Fair Opportunity Type of Contracts Types of Projects (Special, National, etc.)

508 Compliance

Section L - Instructions, Conditions, and Notices to Offerors

Michael Milanese Contracting Officer

Instructions, Conditions, and Notices to Offerors (1 of 2) Proposal Submission Volume IA, IDIQ Technical Proposal Volume IB, Business Ethics, Conflict Of Interest and Compliance Proposal Volume IC, IT Connectivity/FISMA/FedRAMP Proposal Volume IIA, Task Order 0001 Technical Response Technical Proposal Volume IIB, Task Order 0001 Business Proposal Volume IIC, Task Order 0001 Business Ethics, Conflict Of Interest and Compliance Proposal

Instructions, Conditions, and Notices to Offerors (2 of 2) Optional Proposal Submission Volume IIIA, Task Order 0002 Technical Proposal Volume IIIB, Task Order 0002 Business Proposal Volume IIIC, Task Order 0002 Business Ethics, Conflict Of Interest and Compliance Proposal

Proposals that merely restate the requirements of the SOW without providing substantive descriptions of the planned work and approach may be considered technically unacceptable.

BFCC-QIO Proposal Organization

Solicitation Questions Each set of questions shall be submitted in a separate attachment. The file name shall specify whether the questions pertain to the BFCC IDIQ SOW, Task Order 0001, or Task Order 0002. Refer to Attachment J.14, Question Submission Format Sample (in Microsoft Excel format).

Submitted electronically to BFCC2019@cms.hhs.gov Please note that questions submitted by telephone, fax or verbally will not be honored.

Closing Date for Questions: 1 – 2 weeks after RFP is posted

General Proposal Instructions for Multiple Award IDIQ Contract & Task Orders BFCC 12th SoW Initial Awards There are two task orders included with this draft solicitation.

Task Order 0001 (Required) - “BFCC National Coordinating & Oversight Review Center (BFCC NCORC).” Task Order 0001 is mandatory and must be included with proposal submission. Task Order 0001 will be utilized for evaluation of business proposal for the purposes of an IDIQ award and WILL also result in an actual task order award. Refer to Attachments J.2.

Task Order 0002 - “Beneficiary Protection: Case Review Services.” Task Order 0002 is not mandatory. Offerors may choose to propose on Task Order 0002. Refer to Attachments J.3.

BFCC-QIO Case Review Services Award(s) Offerors may bid a minimum of 1 and a maximum of 5 regions.

CMS intends to award no more than 4 regions to any one contractor as to not overburden any one contractor but reserves the right to award more than 4.

If no proposals are received for a particular area or if at any point during the evaluation process, it becomes apparent that there are no viable proposals for a particular area, CMS reserves the right to post an amendment to the solicitation and provide an opportunity for offerors that did not submit the maximum number of proposals, to submit a proposal and compete for that area.

Small Business Subcontracting Plan/Goals Contract Requirement

Sample Provided as Attachment J.11

Plan covers the entire contract Period of Performance

Goals: Total dollars subcontracted 33% - Awarded to Small Businesses Subset: Required goals

5% - SDB & WOSB

3% - Hub Zone & SDVOB

Section M - Evaluation Factors for Award

Michael Milanese Contracting Officer

Evaluation for Award(s)

Evaluation for Award(s) Business Evaluation:

Cost Realism Analysis Cost Analysis

Conflict of Interest, Compliance and Governance:

OCI/PCI Disclosure submission Reasonable opportunity to respond Preclusion from consideration for award(s) Best interest award(s)

BFCC-QIO Award Timeline (1 of 2)

-- Tentative and May Change -- Stage 1: Award in January 2019 BFCC-QIO IDIQ – Beneficiary & Family Centered Care-QIO Full & Open (F&O) Competition Anticipate multiple contract awards Period of Performance

Stage 2: Award in January-February 2019 BFCC NCORC Task Order – BFCC National Coordinating & Oversight Review Center F&O Competition – award concurrent with award of IDIQ contract Single task order award Period of Performance

BFCC-QIO Award Timeline (2 of 2)

-- Tentative and May Change -- Stage 3: Award in January-February 2019 Case Review Services Task Orders F&O Competition – award concurrent with award of IDIQ contract One award per CMS Region; offerors winning more than one region may be combined into one task order award Period of Performance

BFCC-QIO Procurement Timeline

-- Tentative and May Change --

IDIQ Contracts

BFCC NCORC

Case Review Services

System Award Management (SAM) Offerors must be registered, prior to award NAICS Code 541618 Responsible for accuracy and completeness of the data

Failure to register in SAM will prohibit CMS from making an award to your organization.

Business Proposals

Brandon Williams Senior Financial Management Specialist Business Operations Group

Forms and Instructions Forms Sup Sch YR1 – YR5, Add’l Labor Category, QIOSubconts 2, Travel Detail, QIO ODC

In addition to this, business proposals are required to include the appropriate supporting information. The supporting documentation should be detailed and fully explain calculations and basis for estimates, etc.

Quotes and estimates from vendors Historical data Specific calculations used to estimate proposed costs and an explanation

Accounting Systems

Bridget Rineker Director, Division of Financial Services Audit & Workforce Group

Accounting System Requirements FAR 16.301-3: A cost-reimbursement contract may be used only when the contractor’s accounting system is adequate for determining costs applicable to the contract or order ONLY applies to cost-reimbursement and non-commercial time and material (T&M) type task orders Applies to all business sizes (large and small) Two types:

Pre-award – Acceptable Post-award – Adequate

Pre-Award Accounting System Audit

Post-Award Accounting System Audit

Accounting Systems Useful FAR References & Resources FAR Subpart 9.1, Responsible Prospective Contractors SF 1408: Pre-award Survey of Prospective Contractor Accounting System http://www.dcaa.mil/Content/Documents/sap/17740_ap_na.pdf DCAA Accounting System Audit Program http://www.dcaa.mil/Content/Documents/sap/11070_ap_na.pdf DCAA Information for Contractors Manual http://www.dcaa.mil/Content/Documents/DCAAM_7641.90.pdf

Accounting Systems Key Take Aways Performed by the Government (or its contractor) Two Types: Pre-award (acceptable) and Post-award (adequate) An Offeror’s accounting system must be determined ACCEPTABLE before contract or task order award A contractor must maintain an ADEQUATE accounting system, as determined by a Government CO, while performing cost-reimbursement contracts

Organizational & Personal Conflict of Interest

Greg Gesterling Contractor Compliance Officer

OCI Agenda OCI Introduction

Personal Conflict of Interest

Types of Conflict of Interest

What Is Expected of the Contractor

Compliance Program

Potential Conflicts

What is an Organizational Conflict of Interest (OCI) FAR 2.101 Definition: Organizational conflict of interest means that because of other activities or relationships with other persons, a person is unable or potentially unable to render impartial assistance or advice to the Government, or the person’s objectivity in performing the contract work is or might be otherwise impaired, or a person has an unfair competitive advantage.

The two underlying principals are:

Preventing an unfair competitive advantage pre-award.

Preventing biased and subjective performance not in the government’s best interests post-award.

An OCI can exist with respect to existing procurement, or with respect to a future procurement. But all OCIs, current or future, MUST be resolved for the instant requirement pre-award.

What Is a Personal Conflict of Interest Organizational conflicts of interest at FAR 9.5 has broad application.

FAR 9.5 only mentions “organizations” but the definition at FAR 2.101 talks about “Persons”.

“Persons” is defined broadly to include entities such as corporations and partnerships, as well as natural persons.

Thus, the same terms and principals in FAR 9.5 apply.

As a result, CMS includes personal conflicts as part of the FAR 9.5 conflicts analysis.

This is primarily due to the fact that natural persons run entities and make decisions that could be biased or subjective not in the government’s best interests.

CMS has developed a specific Form for disclosure of personal conflicts. However, this form is NOT filed with the proposal.

Three Forms of OCIs (1 of 2) Unequal Access to Information Think secret information no other offeror has – similar to “insider trading” This is an unfair competitive advantage conflict

Biased Ground Rules Think self interest when a contractor helps CMS develop a new program, SOW, etc.

This is an unfair competitive advantage conflict

Only CMS can resolve unfair competitive advantage conflicts through exclusion or limitation (e.g., can’t develop and test the same system, tool, etc.).

Three Forms of OCIs (2 of 2) Impaired Objectivity Think financial, business or other interests influencing decisions.

Can exist pre-award and/or post-award depending on the facts.

But, this is a post-award business performance risk.

Both CMS and the offeror can resolve If pre-award, CMS through exclusion/limitation at pre-solicitation.

If post-award, Offeror through mitigation submitted in proposal.

Type of Information We May Look for You to Disclose IDIQ Level FAR 3.10 Code of Business Ethics and Conduct Requires a formal Compliance Program and Compliance Officer Meet QIO Governance Requirements Disclosure (“J.x”) of all contracts/business lines/affiliations that may result in a conflict. Full explanation is required.

Personal conflicts analysis NOT disclosed to CMS (internal with certification) Task Order Level Board of Directors Same as above (initial or updated as situation dictates) An independent analysis required because of separate TO facts See Section L for full details.

Compliance Program FAR 3.10 Incorporates Seven Elements for Federal Contracts Exceeding $5.5M in value and over 120 Days of Performance.

“Value” is the contract amount as if all options have been exercised Nearly all CMS contracts fall into this category Guidance/Recommendations for Establishing an Effective Compliance Program can be found at:

www.cms.gov/Medicare/Medicare-Contracting/Medicare-Administrative-Contractors/Downloads/compliance.pdf Applies to All Primes and Subcontractors.

All Large Businesses must have a Compliance Program meeting FAR 3.10 with special attention to CMS’ Compliance Program Guidance.

All Small Businesses must have, at the minimum, a Code of Business Ethics and Conduct. For this procurement, CMS highly recommends consideration of the CMS’ Compliance Program Guidance.

Compliance Program Elements Code of Conduct and Written Compliance Policies and Procedures Compliance Officer and Compliance Committee Employee Training and Education Process to Receive Complaints Including the Ability to Report Anonymously Monitoring and Auditing Enforcement and Discipline Investigation and Prevention of Problems and the Development of Policies to Address Sanctioned Persons

BFCC Potential Conflicts (1 of 2) Under the BFCC IDIQ award, there are certain CMS policy exclusions:

BFCC awardees cannot be a NQIIC awardee as a prime or subcontractor

BFCC awardees cannot be affiliated with or contract with a healthcare provider

BFCC awardees cannot be a subcontractor performing work on both NQIIC and BFCC-QIO contracts

BFCC Potential Conflicts (2 of 2) BFCC awardees must consider their financial interests in other entities, including the following:

1) Percentage of ownership in any other entity

2) Income generated from other sources

3) A list of current or known future contracts or arrangements, regardless of size, with any -- Insurance organization or subcontractor of an insurance organization;

Providers or suppliers furnishing healthcare services (which can include universities with health systems) for which payment may be made under the Medicare or Medicaid programs; or Health research entities.

BFCC awardees may not be, become or affiliate with Medicare Administrative Contractors, Recovery Audit Contractors, Program Integrity Contractors, Qualified Independent Contractors and the like.

Contract Award Limitations BFCC-QIO IDIQ contracts and NQIIC IDIQ contracts will likely be awarded within a few months of each other or at the same time Offerors may propose on both the BFCC-QIO and NQIIC but cannot win both If an offeror wins and accepts a BFCC-QIO award and proposed on the NQIIC, the offeror will be removed from the NQIIC competition(s) and vice versa

Break

Q&A Panel

Cadre of CMS Leadership Representatives

To address some questions submitted to the mailbox

Close Out & Adjourn

Phyllis Lewis

Closing: Important Key Messages & Caveats Current Beneficiary & Family Centered Care (BFCC) Indefinite Delivery / Indefinite Quantity (IDIQ) Request for Proposal (RFP) and Task Orders are Draft, not Final The government has not made any final decisions about the elements of the Draft Task Orders and funding amounts Elements of the Task Orders may change or be eliminated altogether Projected volumes for work may change Any work or contract actions outlined in the Draft IDIQ and Task Orders will be “subject to available funds” and in no way represent a government commitment to fund this work

Thank you!

Any new information about this solicitation will be available on FBO.gov.

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