E.5 PPI MEDIC Questions - Answers Amendment 0001.pdf

E.5 Questions and Answers (QAs) Template

Questions and Answers – 75FCMC19R0042

*Please use the below required format. Also, make sure to add ‘CMS Answer’ below each question.

REQUEST FOR PROPOSAL QUESTIONS (RFP):

1. Section/ Page Number: B2 / page 2 Schedule of Services

Question: Is the 90 Day transition period included as part of the Base Year CLIN0001?

CMS Answer: Yes, the 90 day transition-in period shall only be included in the Base Year.

2. Section/ Page Number: Section H.1, Page 23 of 80

Question: Could CMS please clarify whether contractors currently working with CMS to audit/review Medicare Part C plans (e.g., risk adjustment data validation audits) would be considered a significant potential conflict of interest?

CMS Answer: Conflicts of interest are very fact specific. As a result, CMS would never be able to provide guidance on mitigation plans on a general level. Please refer to the OCI clause that was included in the Solicitation for a complete list of potential conflicts.

3. Section/ Page Number: c. Significant Potential Conflict of Interest: / Page 23

Question: Is the incumbent NBI Medic contractor allowed to bid under the Conflict of Interest clauses?

CMS Answer: Yes, this is a Full & Open procurement. Please refer to the OCI clause for a list of potential conflicts of interest.

4. Section/ Page Number: Section H/Page 23 of 80

Question: If a contractor or subcontractor performed or will perform a mock compliance program effectiveness audit, including the review of the special investigation unit, for a Medicare Part C or Part D plan sponsor or a first-tier, downstream, and related entity, will CMS view these services as a potential conflict of interest?

CMS Answer: Conflicts of interest are very fact specific. As a result, CMS would never be able to provide guidance on mitigation plans on a general level. Please refer to the OCI clause, which states “It would be a conflict if the contractor that is awarded this contract is also a contractor that may be reviewing/auditing or conducts business with or for entities that operate Medicare Parts C or D Plans.”

5. Section/ Page Number: Section H/Page 23 of 80

Question: If a contractor or subcontractor performed or will perform universe testing services in preparation of a CMS Program Audit for a Medicare Part C or Part D plan sponsor or a first-tier, downstream, and related entity, will CMS view these services as a potential conflict of interest?

CMS Answer: Conflicts of interest are very fact specific. As a result, CMS would never be able to provide guidance on mitigation plans on a general level. Please refer to the OCI clause, which states “It would be a conflict if the contractor that is awarded this contract is also a contractor that may be reviewing/auditing or conducts business with or for entities that operate Medicare Parts C or D Plans.”

6. Section/ Page Number: Section H/Page 23 of 80

Question: If a contractor or subcontractor performed or will perform validation audit(s) of corrective actions associated with CMS Program Audits for a Medicare Part C or Part D plan sponsor or a first-tier, downstream, and related entity, will CMS view these services as a potential conflict of interest?

CMS Answer: Conflicts of interest are very fact specific. As a result, CMS would never be able to provide guidance on mitigation plans on a general level. Please refer to the OCI clause, which states “It would be a conflict if the contractor that is awarded this contract is also a contractor that may be reviewing/auditing or conducts business with or for entities that operate Medicare Parts C or D Plans.”

7. Section/ Page Number: Section H/Page 23 of 80

Question: If a contractor or subcontractor performed or will perform mock risk adjustment data validation audit(s) to test diagnoses and ICD-10 coding for a Medicare Part C or Part D plan sponsor in preparation for a CMS audit, will CMS view these services as a potential conflict of interest?

CMS Answer: Conflicts of interest are very fact specific. As a result, CMS would never be able to provide guidance on mitigation plans on a general level. Please refer to the OCI clause, which states “It would be a conflict if the contractor that is awarded this contract is also a contractor that may be reviewing/auditing or conducts business with or for entities that operate Medicare Parts C or D Plans.”

8. Section/ Page Number: Section H/Page 23 of 80

Question: If a contractor or subcontractor performed or will perform risk adjustment data validation audit(s) under a CMS contract to validate and verify diagnoses and ICD-10 coding for a Medicare Part C or Part D plan sponsor, will CMS view these services as a potential conflict of interest?

CMS Answer: Conflicts of interest are very fact specific. As a result, CMS would never be able to provide guidance on mitigation plans on a general level. Please refer to the OCI clause, which states “It would be a conflict if the contractor that is awarded this contract is also a contractor that may be reviewing/auditing or conducts business with or for entities that operate Medicare Parts C or D Plans.”

9. Section/ Page Number: Section H/Page 23 of 80

Question: If a contractor or subcontractor performed or will perform Medicare Part C or Part D data validation audit(s) on the validity and reliability used to generate CMS-mandated reporting measures for a Medicare Part C or Part D plan sponsor, will CMS view these services as a potential conflict of interest?

CMS Answer: Conflicts of interest are very fact specific. As a result, CMS would never be able to provide guidance on mitigation plans on a general level. Please refer to the OCI clause, which states “It would be a conflict if the contractor that is awarded this contract is also a contractor that may be reviewing/auditing or conducts business with or for entities that operate Medicare Parts C or D Plans.”

10. Section/ Page Number: Section H/Page 23 of 80

Question: If a contractor or subcontractor performed or will perform consulting services, such as formulary administration, bid support, medical and pharmacy claims audits, medical reviews, monitoring and auditing, or data analysis for a Medicare Part C or Part D plan sponsor, will CMS view these services as a potential conflict of interest?

CMS Answer: Conflicts of interest are very fact specific. As a result, CMS would never be able to provide guidance on mitigation plans on a general level. Please refer to the OCI clause, which states “It would be a conflict if the contractor that is awarded this contract is also a contractor that may be reviewing/auditing or conducts business with or for entities that operate Medicare Parts C or D Plans.”

11. Section/ Page Number: Section H/Page 23 of 80

Question: If a contractor or subcontractor performed or will perform fraud detection and prevention services, such as providing subject matter expertise in conducting training and education, developing methodologies, and designing and implementing data analytics, in support of the CMS Healthcare Fraud Prevention Partnership and work with commercial health plans that are also a Medicare Part C or Part D plan sponsor, will CMS view these services as a potential conflict of interest?

CMS Answer: Conflicts of interest are very fact specific. As a result, CMS would never be able to provide guidance on mitigation plans on a general level. Please refer to the OCI clause, which states “It would be a conflict if the contractor that is awarded this contract is also a contractor that may be reviewing/auditing or conducts business with or for entities that operate Medicare Parts C or D Plans.”

12. Section/ Page Number: Section H/Page 23 of 80

Question: If a contractor or subcontractor sells information technology products (e.g., analytical tools) and data analysis services (e.g., lead development) to a Medicare Part C or Part D plan sponsor, will CMS view these services as a potential conflict of interest?

CMS Answer: Conflicts of interest are very fact specific. As a result, CMS would never be able to provide guidance on mitigation plans on a general level. Please refer to the OCI clause, which states “It would be a conflict if the contractor that is awarded this contract is also a contractor that may be reviewing/auditing or conducts business with or for entities that operate Medicare Parts C or D Plans.”

13. Section/ Page Number: Section H/Page 23 of 80

Question: If a contractor or subcontractor has acquired access to Medicare Part C and Part D claims, encounter data, or prescription drug event records and used these data sources to conduct audits, investigations, and data analysis through contracted or consulting services provided to Medicare Part C or Part D plan sponsor or their first-tier, downstream, and related entities, will CMS view these services as a potential conflict of interest?

CMS Answer: Conflicts of interest are very fact specific. As a result, CMS would never be able to provide guidance on mitigation plans on a general level. Please refer to the OCI Clause, which states “It would be a conflict if the contractor that is awarded this contract is also a contractor that may be reviewing/auditing or conducts business with or for entities that operate Medicare Parts C or D Plans.”

14. Section/ Page Number: Section H/Page 23 of 80

Question: If a contractor or subcontractor served as a Medicare Part D RAC Data Validation Contractor for CMS, will CMS view these services as a potential conflict of interest?

CMS Answer: Conflicts of interest are very fact specific. As a result, CMS would never be able to provide guidance on mitigation plans on a general level. The Offeror should refer to the OCI clause and can submit an OCI mitigation plan if the Offeror believes this not to be a conflict.

15. Section/ Page Number: Section H/Page 23 of 80

Question: If a contractor or subcontractor is contracted with CMS to provide Drug Data Support System services, whereby it designs, captures, validates, stores, and reports prescription drug event records in support of the Medicare Part D program and data analysis, will CMS view these services as a potential conflict of interest?

CMS Answer: Conflicts of interest are very fact specific. As a result, CMS would never be able to provide guidance on mitigation plans on a general level. The Offeror should refer to the OCI clause and can submit an OCI mitigation plan if the Offeror believes this not to be a conflict.

16. Section/ Page Number: Section H/Page 23 of 80

Question: If a contractor or subcontractor is contracted with States’ Medicaid Programs to serve as a fiscal agent and provide claims processing services for providers, such claim payments, voids, refunds, and accounts receivable; processes provider enrollment applications;

and provides training to the provider community, will CMS view these services as a potential conflict of interest?

CMS Answer: Conflicts of interest are very fact specific. As a result, CMS would never be able to provide guidance on mitigation plans on a general level. The Offeror should refer to the OCI clause and can submit an OCI mitigation plan if the Offeror believes this not to be a conflict.

17. Section/ Page Number: Section H/Page 23 of 80

Question: If a contractor or subcontractor sells service and support risk, fraud, and decision management solutions, such as platforms, hardware, and software, to the healthcare industry (e.g., health plans, providers, suppliers, and first-tier, downstream, and related entities), will CMS view these services, support, and solutions as a potential conflict of interest?

CMS Answer: Conflicts of interest are very fact specific. As a result, CMS would never be able to provide guidance on mitigation plans on a general level. The Offeror should refer to the OCI clause and can submit an OCI mitigation plan if the Offeror believes this not to be a conflict.

18. Section/ Page Number: L.8 Proposal Submission, page 62

Question:

Is the offeror required to make an appointment with the Contracting Officer or Contract Specialist to deliver the proposal in person?

CMS Answer: The offeror is not required to make an appointment but it would be in the Offeror’s best interest to set up a time up with OAGM personnel listed in the solicitation to ensure their proposal is received on time.

19. Section/ Page Number: L.10 TECHNICAL PROPOSAL INSTRUCTIONS (VOLUME I)/ Page 63 of

States: The Table of Contents (Unlimited Pages); The Offeror shall include a Table of Contents that identifies and clearly labels the various technical proposal sections.

Question: Can the Government confirm it is acceptable for an Acronym List and/or a Cross Reference matrix to be included within the Table of Contents and excluded from page limitations?

CMS Answer: Yes, it is acceptable to include an acronym list and/or cross reference matrix in the table of contents if necessary. This information will also be excluded from the page limitation.

20. Section/ Page Number: L.9 Proposal Instructions, page 63 and L.11 Business Proposal (Volume II) Instructions, Section F, Subcontracts, page 72

Page 63 states that “Offerors shall ONLY submit electronic copies of their proposal on CD’s”.

Page 72 states “Each Subcontractor Negotiation Memorandum shall be attached and clearly labeled with a TAB.”

Question: Can the Government confirm that TABs are only applicable for physical submissions, and that for electronic submission on the CD, only clear labeling of Subcontractor Negotiation Memorandums is required?

CMS Answer: Correct, as stated on page 63, please only submit electronic copies of your proposal on CD’s. Tab in this situation since proposals are to be submitted electronically is considered a separate file/folder that is clearly labeled to include the subcontractor negotiation memorandum.

21. Section/ Page Number: Section L.9.2, Page 64 of 80

Question: The RFP states that “Each proposal shall be compatible with Microsoft Office 2010”.

However due to the nature of business proposal where multiple supporting documents with signatures will be included, can Offerors submit Business Proposal (Volume II) in PDF format, except for the business proposal spreadsheet (Exhibit E.1)?

CMS Answer: Yes

22. Section/ Page Number: L.9 Proposal Instructions, page 64

Question: Since the proposal submission is electronic, are electronic signatures permissible for the proposal?

CMS Answer: Yes

23. Section/ Page Number: Section L.10, Page 65 of 80

Question: For Scenario 2 in Exhibit E.2, is CMS looking for a separate FWA incidents in Part C and in Part D?

CMS Answer: Yes, both are required.

24. Section/ Page Number: Section L.10, Page 65 of 80

Question: For Scenario 3 in Exhibit E.2, is CMS looking for separate vulnerabilities in Part C and in Part D?

CMS Answer: Yes, both are required.

25. Section/ Page Number: Section L.10, Page 66 of 80

Question: Can a Key Personnel position (e.g., Medical Director) be filled by multiple individuals who each meet the listed requirements and whose proposed hours add up to a minimum of one FTE for each year of the period of performance?

CMS Answer: The SOW states, “The PPI MEDIC shall maintain key personnel positions that are dedicated as Full Time Equivalents (FTEs), with the exception of the Medical Director position.”

One individual should fulfill each key personnel position.

26. Section/ Page Number: 3.2. Staffing Plan / Page 66 of 80

The Staffing Section States: Letters of Commitment: The Offeror shall submit a standard letter of commitment for each key personnel not currently employed by the Offeror. Letters of commitment shall include the date of availability, the salary accepted, how long the individual's commitment is binding, and be signed by the individual and the Offeror’s corporate authorized official. Letters of commitment shall not exceed two (2) pages.

*6 page limit with the exception of the Organizational Charts and Resumes for Key Personnel which will be a maximum of 2 pages each

Question: The page limit for the Staffing Plan is 6 pages; can the Government confirm that the Letters of Commitment can be attached as an appendix in Volume I and that Letters of Commitment are excluded from page limitations?

CMS Answer: Yes, the letters of commitment can be included as an appendix in Volume I and are excluded from the overall page limitations but shall not exceed two pages per letter of commitment.

27. Section/ Page Number: Section L.11, Page 68 of 80

Question: Under RFP Section L.11 - Section B: Contract Forms – RFP Section G, could CMS confirm only subsections G.13.1.ii, G.13.2.a), and G.14 should be filled out by Prime contractors?

CMS Answer: Correct, the subsections and section listed above shall be filled out by the prime contractor for Section G.

28. Section/ Page Number: Section L.11, Page 68 of 80

Question: Under RFP Section L.11 - Section B: Contract Forms – RFP Section K, could CMS confirm that only subsection K.1 needs to be filled out if the Offeror has completed the annual representations and certifications electronically in SAM?

CMS Answer: Yes

29. Section/ Page Number: L.10 Technical Proposal Instructions (Volume I), page 67. Small Business Utilization. Small Business Subcontracting

Question: Will the Government provide the small business subcontracting goals and specify whether they are based on subcontracted dollars?

CMS Answer: The solicitation has been revised to reflect subcontracting goals and the amounts are based on subcontracted dollars.

30. Section/ Page Number: L.10 Technical Proposal Instructions (Volume I), page 67. Small Business Utilization. Small Business Subcontracting

Question: Given that the Small Business Subcontracting Plan will likely include monetary values, can the Government clarify whether the Small Business Subcontracting Plan in the Technical Volume (Volume I) or the Business Volume (Volume II)?

CMS Answer: Volume II Business Volume.

31. Section/ Page Number: L.9 PROPOSAL INSTRUCTIONS; 2. Format; Electronic Proposals / page 63-64

Format #g States: Signed documents such as conflict of interest shall be submitted in Adobe Acrobat or “PDF” format. Organizational charts may be provided in PowerPoint.;Electronic Proposals States: Each proposal shall be submitted on a CD-ROM submitted in Microsoft Office Word, unless otherwise noted.

Question: Can the Government confirm is it acceptable to submit our audited financial statements (and any other forms such as CASB) required for submission with the business volume in PDF as attachments to the business volume since they are generally large files that we receive in a PDF format?

CMS Answer: Yes

32. Section/ Page Number: L.11 Business Proposal (Volume II), Instructions, Section D, Other Administrative Data, Page 70

Question: Will the Government confirm that Labor Hour (LH) type contracts are not considered cost reimbursable since this contract type only includes Fixed Hourly Rates.

CMS Answer: This solicitation is for a CPFF award. Offerors shall have accounting and estimating systems that are in compliance with applicable Contract Cost Principles and Procedures of FAR Part 31.

33. Section/ Page Number: I.1 FAR clauses: FAR 52.222-41 Service Contract Labor Standards, page 41; and L.11 Business Proposal (Volume II), Instructions, Section I, Service Contract Labor Standards, Page 76

Question: In accordance with FAR 52.222-41 Service Contract Labor Standards, please provide the applicable Wage Determination(s) to Offerors.

CMS Answer: It is based on where performance is set to occur for the Offeror. Therefore, it is up to the offeror to propose in accordance with the applicable wage determinations and CMS will incorporate them at time of award.

34. Section/ Page Number: L.10 TECHNICAL PROPOSAL INSTRUCTIONS (VOLUME I) / Page 65 of 80; Exhibit E.2 / page 1-2nd bullet

#2 States: Technical Understanding and Approach: Scenario Responses (Page limit: 9 pages); E.2 States: If multiple scenarios are part of the evaluation, the maximum length is 3 pages per scenario response; however, when the Offeror is able to respond to a scenario in less than 3 pages, they may use the remaining space for another scenario (or scenarios).

Question: Can the Government confirm that offerors have latitude to use the 9 pages with any allocation required for each of the scenarios as long as the response is limited to 9 pages?

CMS Answer: Yes, as long as the scenario responses’ total pages do not exceed 9 pages.

35. Section/ Page Number: 3.2. Staffing Plan / Page 66 of 80

The Staffing Section States: Letters of Commitment: The Offeror shall submit a standard letter of commitment for each key personnel not currently employed by the Offeror. Letters of commitment shall include the date of availability, the salary accepted, how long the individual's commitment is binding, and be signed by the individual and the Offeror’s corporate authorized official. Letters of commitment shall not exceed two (2) pages.

Question: Can the Government confirm Salary information does not need to be included in the Letters of Commitment as Letters of Commitment are to be submitted within the Technical volume?

CMS Answer: As stated in the solicitation the letters of commitment shall include the salary accepted.

36. Section/ Page Number: L.9 Proposal Instructions, 2. Format/page 63

The Format, letter g states: Signed documents such as conflict of interest shall be submitted in Adobe Acrobat or “PDF” format. Organizational charts may be provided in PowerPoint.

Question: Can the Government confirm that Organizational charts in PowerPoint are to be submitted separately?

CMS Answer: Yes, organizational charts in power point may be submitted separately.

37. Section/ Page Number: L.10 TECHNICAL PROPOSAL INSTRUCTIONS (VOLUME I) / page 65

Question: Would CMS clarify if a small business is required to submit Section 5: Small Business Utilization?

CMS Answer: Solicitation has been revised for the small business utilization factor.

38. Section/ Page Number: L.10 TECHNICAL PROPOSAL INSTRUCTIONS (VOLUME I) / Page 65 of 80; Technical Understanding and Approach: Scenario Responses

The Offeror’s responses shall include, at a minimum, the following: ii. Relevant data points to support the Offeror’s approach to scenarios;

Question: Can the Government provide clarification on what is meant by “data points” or provide examples?

CMS Answer: The reference to “data point” is standard and shall address/cover information that supports the Offeror’s approach to the scenarios.

39. Section/ Page Number: L.10 TECHNICAL PROPOSAL INSTRUCTIONS (VOLUME I), 3 Key Personnel & Staffing Page 66

Question: Would the Government clarify that the example table shown represents what is described as an “organizational chart” for which the pages are unlimited?

CMS Answer: No, the table shown on p.66 of the solicitation is not an example of an organization chart but a staffing chart.

40. Section/ Page Number: L.10 TECHNICAL PROPOSAL INSTRUCTIONS (VOLUME I), 3 Key Personnel & Staffing Page 66

Question: If the table on page 66 is intended to be an example of an “organizational chart”, can it be used to cover the information required for the “2. Staffing Plan” including Item A which is the total number of FTEs required for all CLINs and contract periods broken out by labor category?

CMS Answer: The table shown on p.66 of the solicitation is not an example of an organization chart but a staffing chart. Therefore, please only use the example on page 66 for when submitting a staffing plan.

41. Section/ Page Number: Section F: Business Proposal Spreadsheet: / Page 73

Question: Would CMS list the ODCs currently used by the incumbent?

CMS Answer: No, this information shall not be provided.

MISCELLANEOUS:

42. Section/ Page Number:

Question: What is the value of the current NBI Medic contract?

CMS Answer: This information shall not be provided.

43. Section/ Page Number: Attachment E.3 PPI Workload Assumptions

Question: Would CMS clarify the number and types of current staff who:

• Are assigned to the IDR User Group?

• Support Analytics: Data and Ad Hoc (New Audit Ideas)?

• Draft responses to Plan Sponsor Alerts?

• Respond to RFIs?

CMS Answer: These numbers shall not be provided.

44. Section/ Page Number: K5 / page 57 I. Disclosure Statement -- Cost Accounting Practices and Certification (b)

Question: We are a small business (NAICS 541990 under the small business size standard) and would like CMS to confirm that we do not have to submit a CAS Disclosure Statement as required by 48 CFR 9903.202.

CMS Answer: Small businesses do not have to submit a CAS disclosure statement.

45. Section/ Page Number: General Question

Question: Is the Investigations MEDIC eligible to bid on the PPI MEDIC RFP?

CMS Answer: This is a Full & Open competition procurement. Please refer to the OCI clause for a list of potential conflicts of interest.

46. Section/ Page Number: Standard From 33, Section 9.

Question: Since the proposal is due the morning of the Monday following the Thanksgiving holiday will CMS extend the due date of the proposal at least one week to Monday, December 9?

CMS Answer: The proposal due date has been extended.

47. Section/ Page Number: Business Proposal Template, Travel tab

Question: To price the cost of travel, can CMS please provide the historical number of on-site visits for the Program Integrity Audits, the number of PPI MEDIC personnel that participated in each visit, and the locations of the visits? If such data are not available, please provide assumptions for pricing purposes or provide a dollar value all bidders should propose to cover the potential cost of travel (similar to what CMS has done with pass-through costs in other CPFF type solicitations).

CMS Answer: For bidding purposes, offerors shall assume that travel costs are $60,000 per year.

Onsite visits are expected for all Program Integrity Audits. Workload projection numbers are provided for Program Integrity Audits. Please refer to the workload projections provided in the solicitation.

48. Section/ Page Number: Business Proposal Template, Travel tab

Question: To price the cost of travel, please provide the number of times the PPI MEDIC will need to present materials, the number of speakers if a panel of speakers will be required and the locations of the conferences where the presentations will be made.

CMS Answer: The offeror shall develop its travel estimate based on what the SOW requires.

49. Section/ Page Number: Business Proposal Template

Question: The template includes pricing for Task 1: Transition in the Base Year and all Option Years. Please clarify in which years Transition should be priced. If Transition pricing is required in more than the base year of the contract, please explain the government’s intent for the transition pricing in each of the option periods.

CMS Answer: The 90 day transition-in period will occur only in the Base Year. Do not include transition costs in the Option Years.

50. Section/ Page Number: Attachment E.3 PPI Workload Assumptions

Question: How many events are out of the Baltimore area? How many staff are required to attend the out of area events?

CMS Answer: This information shall not be provided. The Offeror shall submit their approach to meeting the requirements in compliance with the SOW.

51. Section/ Page Number: Attachment E.3 Assumptions: Workload Projections, page 1

Question: Are the workload projections in Attachment E.3 Assumptions for pricing purposes only or are they representative of what the actual workloads will be?

CMS Answer: The Workload Assumptions are provided for pricing purposes and represent CMS’ best estimate for future workload levels.

52. Section/ Page Number: Attachment E.3 Assumptions: Workload Projections, page 1

Question: On what percentage of the projected self-audits and national audits in section E.3 will a medical record review, as defined by the PIM 100-08 Sections 7.2.2.12 and 7.2.2.13, need to be performed?

CMS Answer: This information cannot be provided because this will vary based on the audit issue or universes being reviewed.

53. Section/ Page Number: Attachment E.3 Assumptions: Workload Projections, page 1

Question: If medical review is required for the validation of the self-audits and the national audits, how will the offeror receive the medical records? Would it be via an established mechanism such as esMD or would the offeror request records directly from the plans?

CMS Answer: Under the National Audits (Task 6.2) section of the SOW, “The PPI MEDIC shall request the appropriate documents from plans and shall receive and review documentation.”

Under the Self-Audits (Task 6.1) section of the SOW, “The plan shall be required to submit the self-audit results to the PPI MEDIC.” Offerors shall propose a mechanism/method to receive and review records.

54. Section/ Page Number: E.3_PPI_MEDIC_Workload_Assumptions, Page 1 of 1

Question: The attachment E.3_PPI_MEDIC_Workload_Assumptions.docx estimates the PPI MEDIC will develop 5-6 new audit ideas annually. Could CMS confirm whether all proactive data analyses under Task 5 are included in this projection?

CMS Answer: The workload assumptions provided in the solicitation are an estimate of the workload for a 12-month and 9-month period. The referenced requirement is in addition to the workload assumptions provided in the solicitation

55. Section/ Page Number: E.3_PPI_MEDIC_Workload_Assumptions, Page 1 of 1

Question: The attachment E.3_PPI_MEDIC_Workload_Assumptions.docx estimates the PPI MEDIC will address 8-10 RFIs annually. The July 2018 OIG report OEI-03-17-00310, however, reports a substantially higher estimate of RFIs addressed by the MEDIC. For example, Exhibit 12 in Appendix C cites 784 RFIs completed in 2017. Could CMS please explain the difference between these two estimates of RFI workload?

CMS Answer: The workload projection number provided is based on this acquisition, therefore offerors shall base their proposal on the RFI numbers in the workload projections.

56. Section/ Page Number: RFP, B.3 Contract Type, page 2 of 80 and L.4 (page 61)

Question: Please confirm:

a. Must the offeror have an approved accounting system for Cost type contracts prior to bidding?

b. Can the subcontractor(s) enter into a T&M or other type subcontract under the CPFF prime contract, without the requirement for audited indirect cost rates, etc.?

CMS Answer:

a. Please refer to Section L.11, Subsection D.4 for information on the timing of the contractor’s approval for their accounting system.

b. Any flexibly-priced, non-commercial contract type would require an adequate accounting system for the proposed contract type.

57. Section/ Page Number: I.2 HHS Clauses 352.231-70 Salary Rate Limitation /page 42

Current limits (as of Jan 2019): Level Rate Level I $213,600 Level II $192,300 Level III $176,900 Level IV $166,500 Level V $156,000

Question: The salary rate limitation clause HHSAR 331.101.70 (b) significantly reduces the ability of a contractor to attract best talent for Health and Human Services. Many top talents are located in high cost of living areas. Including the salary rate limitation reduces the ability to succeed in HHS programs. Competition ensures that Contractors look for the best talent at the most competitive cost. We recommend the clause to be removed to maximize HHS success in its programs.

CMS Answer: This clause is required for this procurement and will remain.

58. Section/ Page Number: Section L.9, Page 63 of 80

Question: Does CMS have a preferred method for vendors to use to identify proprietary or confidential information contained in proposal Volumes I, II, and III?

CMS Answer: There is no preferred method.

STATEMENT OF WORK QUESTIONS (SOW):

59. Section/ Page Number: Section B; Purpose, second paragraph (page 3)

Question: The SOW calls for a full range of statistical, analytical and business functions and also includes addressing program focal areas in management, administration, operation and oversight of the Medicare Part C and D programs. Can audit ideas extend to these focal areas?

What data will be made available to assess the risks in these focal areas?

CMS Answer: Yes, audit ideas can extend to those focal areas, however the Offeror shall ensure their proposal represents their approach to meeting the requirements. Plan sponsor data will be available upon award.

60. Section/ Page Number: B. Purpose, page 4

Question: Will the Government provide the volume and type of workload expected for the Part C and D FWA detection and prevention workload to be transitioned from the previous contractor? Including the current analytics, audits, vulnerabilities, and reporting and alerts.

CMS Answer: The provided workload numbers provided are inclusive of the workload volume and numbers expected to be transitioned from the incumbent contractor. Please refer to the Workload Projections included in the Solicitation.

61. Section/ Page Number: Section B; Purpose, (page 4)

Question: The SOW includes identifying overall program vulnerabilities and ensuring plan sponsors’ adherence to regulatory requirements. Does CMS anticipate that data analysis beyond analysis of claims, encounter or PDE data can/will be used to identify these vulnerabilities? If so, what data does CMS anticipate will be available for analysis to identify noncompliance vulnerabilities and to use in recommending audits?

CMS Answer: The SOW states, “the PPI MEDIC shall follow the CMS Part C and Part D vulnerability protocol that will be provided to the PPI MEDIC by the COR” (p.15). Please adhere to the requirements under Task 8 (Identifying Vulnerabilities) of the SOW.

62. Section/ Page Number: Data Processing Software, page 5

Question: If the offeror is proposing to deploy its own data analytics platform, does this software need to operate within the CMS Data Center or may the contractor use its own systems?

CMS Answer: The contractor shall use its own systems.

63. Section/ Page Number: C. Technical Considerations, Item 2, page 5

Question: What is the expected size of the data to be stored for this project?

CMS Answer: The contractor shall assume the size of data to be stored based on the requirements in the SOW and the workload assumptions provided (i.e. number of audits) and any necessary record retention requirements.

64. Provide Equipment to Store and Analyze Protected Data:

Section/ Page Number: C. Technical Considerations - Data Processing Hardware/Page 5 Question: Under the heading “Data Processing Software”, CMS states that “The PPI MEDIC shall run their data analyses at the CMS Data Center or using the One PI Systems Integrator tool”.

Under section titled “Data Processing Hardware”, CMS directs PPI MEDIC to have “adequate equipment for data analysis…” During the transition period prior to and after Go-Live, what types of data, from whom, and in what volume, will contractors/CMS provide to the incoming PPI MEDIC, to be saved onto PPI-MEDIC supplied equipment?

CMS Answer: Offerors shall have adequate equipment for data analysis to cover what is provided in the workload projections. Please refer to the SOW (Task 1, Transition).

65. Provide an Internal Tracking/Reporting System:

Section/ Page Number: C. Technical Considerations Sub-Section 5/Page 6 Question: Under section “C. Technical Considerations”, CMS directs the PPI MEDIC to include an “internal tracking system that shall be accessible to CMS and have reporting and functional capabilities to include… track workload… compile data… reporting…”No reference is made in the PPI MEDIC SOW to the CMS Unified Case Management System (UCM). Is this PPI MEDIC supplied tracking system to be used in place of UCM or in coordination with it?

CMS Answer: Please refer to the SOW (Section C. Technical Considerations). The Offeror shall base their proposal on the information provided in the SOW.

66. Section/ Page Number: Requirements / Page 6

Question: What is the current size of the Outreach and Education Group?

CMS Answer: This information shall not be provided.

67. Section/ Page Number: C. Technical Requirements 5. / Page 6

Question: What internal tracking system is used by the incumbent? Is the data on the tracking system part of incumbent turnover at transition?

CMS Answer: This information shall not be provided.

68. Section/ Page Number: Coordination, Page 7

Question: What is the frequency for receipt of complaints (inquiries) that should be assumed as a basis of estimates? What is the complexity of handling these complaints in the length of time to resolve?

CMS Answer: Offerors shall use the information provided in the Solicitation. Any additional information shall be based on the Offeror’s assumptions and approach in meeting the requirements.

69. Complaints:

Section/ Page Number: A. General Requirements – Coordination/Page 7

Question: Under the Coordination heading on page 7, CMS states “Collaborate with the Investigations MEDIC on Medicare Parts C and D complaints and investigations; The PPI MEDIC may receive potential Part D and MA fraud complaints from a variety of sources“. Will CMS provide an anticipated workload volume of complaints?

CMS Answer: Offerors shall use the information provided in the Solicitation. Any additional information shall be based on the Offeror’s assumptions and approach in meeting the requirements.

70. Section/ Page Number: Outreach and Conferences, page 7

Question: Can CMS provide a list of outreach and conferences historically attended by the incumbent contractor including locations that were reimbursed with CMS contract funds? If not available, please provide assumptions that can be used by all bidders for pricing purposes.

CMS Answer: For bidding purposes, Offerors shall assume 6 conferences/trainings for each period of performance. Offerors shall propose using the travel dollar amount provided in the answer for question 47.

71. Section/ Page Number: Coordination, page 7

Question: The text refers to an Investigations MEDIC and an Investigative MEDIC. Is this the same entity?

CMS Answer: Yes, this is the same as the Investigations MEDIC.

72. Section/ Page Number: A. General Requirement, Coordination, (page 7-8)

Question: How are the audits, and the coordination efforts, different than the scope of work to be performed by the UPICs? How will it be determined if the UPIC will conduct an audit under their contract or if the PPI MEDIC will conduct an audit?

CMS Answer: The Offeror shall base their proposal on the information provided to them based on the PPI MEDIC Solicitation.

73. Section/ Page Number: A. General Requirement, Constraints/Assumptions, (page 8)

Question: What is meant by “Experience conducting fraud audits of, or for, governmental agencies? Are you referring to actual fraud audits by Certified Fraud Examiners (CFEs) or investigation units of the OIG? Fraud is normally referred to the OIG for investigation. Fraud audits are not normally contracted for by the government.

CMS Answer: The referenced language shall be removed from the SOW.

74. Section/ Page Number: A. General Requirement, Constraints/Assumptions, Item 2 (page 8)

Question: Does CMS expect the MEDIC to strictly adhere to the GAGAS for the conduct of the audits? Please clarify that all bidders must then have staff that meet the GAGAS Continuing Professional Education (CPE) requirements, that GAGAS and AICPA Professional Standards must be followed for documenting workpapers with respect to planning, risk assessment, prior report corrective action reviews, field work, developing findings, and reporting standards including obtaining auditee comments and including obtaining management representation letters, etc.. Performing audits under GAGAS involve all of these efforts to assure compliance with those standards.

CMS Answer: The PPI MEDIC shall perform requirements as defined in this SOW in accordance with

GAGAS.

75. Section/ Page Number: A. General Requirement, Constraints/Assumptions, Item 2 (page 8)

Question: GAGAS requires (See Section 5.79 of GAGAS) that the audit firms have a Peer Review and that the report be provided to entities with their proposal and provide subsequent peer review reports during the period of the contract so that it can be reviewed as current and the agency can determine if there were any deficiencies. Will CMS require the bidder to submit evidence that a GAGAS required peer review has been completed with their proposal and when each subsequent peer review report is received by the offeror/contractor?

CMS Answer: The PPI MEDIC shall perform requirements as defined in this SOW in accordance with

GAGAS.

76. Section/ Page Number: A. General Requirement, Constraints/Assumptions, Item 2 (page 8)

Question: Does CMS expect the audit report to contain the auditor’s opinion? If so, then please confirm that CMS expects the auditor to be a licensed CPA (see GAGAS 6.04) to work for a company authorized by AICPA and GAGAS to issue audit opinions (e.g., have a current Peer Review report), such as a Certified Public Accounting firm.

CMS Answer: The PPI MEDIC shall perform requirements as defined in this SOW in accordance with

GAGAS.

77. Section/ Page Number: A. General Requirement, Constraints/Assumptions, Item 2 (page 8)

Question: What QA or other involvement does CMS anticipate the PPI MEDIC prime contractor, if the prime is not expected to be a CPA firm who is conducting the audits, to have in the GAGAS audit procedures, GAGAS audit reporting, or GAGAS audit delivery to CMS or directly to the MA or PDP Plans? Are the reports also simultaneously provided to CMS (Section I, Scope indicates findings are provided to the Plans)?

CMS Answer: The Offeror shall propose their best approach for meeting the requirements identified in the SOW.

78. Section/ Page Number: Constraints/Assumptions, Item 7, page 9

Question: Is the electronic system referred to in this section the same as the internal tracking system referred to in Section C. Technical Considerations, Item 5, page 6?

CMS Answer: Yes.

79. Provide an Internal Tracking/Reporting System:

Section/ Page Number: B. Specific Requirements – Transition Meetings/Page 10 Question: Will the existing outgoing NBI MEDIC contractor provide the existing set of accumulated workload management data and documents, the data dictionaries and table structure to the incoming PPI MEDIC during the transition/migration? What is the anticipated volume of that data at the time of the transition? What is the anticipated volume of growth in that data annually?

CMS Answer: Please reference SOW (Task 1, Transition). The SOW states, “A list of all deliverables necessary to ensure a smooth transition between the outgoing contractor and incoming PPI MEDIC and the dates on which the deliverables shall be sent to the incoming PPI MEDIC. This will be submitted by the outgoing contractor ten (10) business days after the first transition meeting.” The Offeror shall refer to the workload projections provided for a 9-month period (i.e. Base Year). The workload projections provided cover the volume of work to be transitioned.

80. Transition: Section/ Page Number: Task 1: Transition/Page 10 Question: What is the quantity of cubic feet of paper currently stored at Iron Mountain for the PPI MEDIC? Boxes vary in size, so Iron Mountain charges by the cubic foot. Are all of the current boxes stored in a NARA level facility or a standard commercial Iron Mountain level facility? Will the current MEDIC contractor move them to a NARA level facility before the transition, or is the new contractor to move them, or are they not to move?

CMS Answer: For proposal purposes, Offerors shall assume approximately 3,000 cubic feet of records stored at Iron Mountain.

81. Section/ Page Number: Task 1: Transition, page 10

Question: What is the name of the outgoing contractor?

82. Section/ Page Number: B. Specific Requirements / pages 10 - 18

Question: Would CMS clarify if tasks 1 - 14 in the SOW are performed under the current NBI Medic contract?

CMS Answer: This information shall not be provided.

83. Section/ Page Number: Task 2, page 11

Question: Does the offeror need to obtain its own licenses for data sources listed in this section?

CMS Answer: Licenses will not be required for all of the data sources listed under Task 2 of the SOW. The Offeror may be required to purchase licenses for relevant prescription drug data sets (for example, First Databank, Medispan, NCPDP, Redbook).

84. Section/ Page Number: Task 2, page 11

Question: Does CMS anticipate that the offeror should obtain licenses for ALL of the data systems listed in this section?

CMS Answer: Licenses will not be required for all of the data sources listed under Task 2 of the SOW. The Offeror may be required to purchase licenses for relevant prescription drug data sets (for example, First Databank, Medispan, NCPDP, Redbook).

85. SAS and BO Licenses: Section/ Page Number: Task 2: Systems Access/Maintenance/Page 11

Question: Task 2 in the SOW identify several data sources outside of the CMS OnePI which cannot be analyzed through SAS, Business Objects, and other CMS-supplied software licenses made accessible only in the OnePI environment. Will PPI MEDIC contractors be provided access to CMS-procured licenses?

CMS Answer: No, the Offeror shall not be provided with access to CMS-procured licenses, however the contractor will be provided with access to CMS systems. The Offeror may be required to purchase licenses for relevant prescription drug data sets (for example, First Databank, Medispan, NCPDP, Redbook).

86. Section/ Page Number: Task 3 PIDUG / Page 11

Question: Would CMS clarify the number of staff supporting PIDUG activities in 2018 and to date in 2019?

87. Section/ Page Number: Task 3 PIDUG / Page 11

Question: In addition to licenses for relevant prescription drug data sets (for example, First Databank, Medispan, NCPDP, Redbook) would CMS provide a list of all licenses currently held by the incumbent?

CMS Answer: This information shall not be provided.

88. Section/ Page Number: Task 5: Analytics: Data and Ad Hoc Analysis / Pages 12 and 13

Question: Would CMS clarify the number received in 2018 and to date in 2019:

• Executive Branch inquires,

• Legislative Branch inquiries and requests, and

• Directives by the COR in support of CMS’ participation in Office of Inspector General

(OIG) and Government Accountability Office (GAO) entrance and exit conferences?

CMS Answer: For proposal purposes the offeror shall base their proposal on the workload assumption numbers provided for Analytics.

89. Section/ Page Number: Task 5: Analytics: Data and Ad Hoc Analysis, Page 13

Question: Is there a basis of estimates the Government would like us to use for the frequency of ad hoc report requests and the size of the request (e.g., length of time typically required to complete)?

CMS Answer: For proposal purposes the offeror shall base their proposal on the workload assumption numbers provided for Analytics.

90. Section/ Page Number: Task 5: Analytics: Data and Ad Hoc Analysis, Page 13

Question: The Government specifies that the Drug Trend Analysis Report and the Outlier Prescriber reports are produced quarterly. How frequent is production of the other two types of reports listed – the Pharmacy Risk Report and the Pharmacy and Prescriber Spike Reports?

CMS Answer: Quarterly. Please refer to the deliverables schedule (p. 24).

91. Section/ Page Number: Task 5: Analytics: Data and Ad Hoc Analysis / Pages 13

Question: Is a DUA required for third party sources for example, Part D drug information from Wolters Kluwers (First Databank Part D Module) and Drug Enforcement Administration Registration information available from the National Technical Information Service? Would CMS clarify how this data is obtained by the incumbent and at what frequency?

CMS Answer: Please refer to the System Security section under General Requirements of the SOW. The Offeror shall enter into a DUA with CMS for CMS provided systems and data.

92. Section/ Page Number: Task 5: Analytics: Data and Ad Hoc Analysis / Page 13

Question: How is the incumbent contractor securely storing medical information, such as procedure codes, diagnosis codes, drug compendia, and medical records? Are medical records stored in ES-MD? Will this data be available at transition?

CMS Answer: This information shall not be provided.

93. Section/ Page Number: Task 5: Analytics: Data and Ad Hoc Analysis, page 13

Question:

Is the analysis effort needed to prepare the four reports separate and distinct from the effort to perform the projected analytics in E.3 Assumptions: Workload Projections?

CMS Answer: Data analysis is required to prepare the requested reports and is assumed in the workload projections.

94. Section/ Page Number: Task 6 Audits, page 13

Question: Will the Government confirm that all sub-tasks under Task 6 require GAGAS. If not, please clarify which sub-tasks require GAGAS.

CMS Answer: The PPI MEDIC shall perform requirements as defined in this SOW in accordance with

GAGAS..

95. Section/ Page Number: Task 6, page 13

Question: For the audits, does the offeror have to follow the Medicare Program Integrity Manual Chapter 008 for audits in anticipation of potential ALJ referrals or to support potential higher Return on Investment.

CMS Answer: The Offeror shall comply with the information provided in the solicitation.

96. Medical Review:

Section/ Page Number: Task 5: Analytics: Data and Ad Hoc Analysis/Page 13 Question: In paragraph 8 under Task 5, CMS states the PPI MEDIC shall support reviews of medical information. Will CMS provide metrics to represent the annual workload volume for medical reviews?

CMS Answer: Workload assumptions were provided in the solicitation. No additional information will be provided. The Offeror shall propose their best approach and assumptions for meeting the requirements identified in the SOW.

97. Section/ Page Number: Task 6: Audits (page 13 – 14)

Question: As described, these procedures (self audits, national audits, program integrity audits) do not sound like GAGAS audits unless they are intended to fall under the Performance Audit Standards. Please confirm that CMS’ expectation is an GAGAS audit.

a. What does CMS mean by the audit topic shall contain the “data methodology”?

b. Is the scope of the audit to conduct validation samples by reviewing the audit results submitted by the…