E.2 NCCI Questions_CMS Response.docx

E.2. – NCCI Questions Submission Template NCCI - Questions and Responses – 75FCMC22R0035

REQUEST FOR PROPOSAL QUESTIONS (RFP)

1. Question 1:

Section (i.e. RFP, SOW): RFP Title and Number (including subparagraph designations): F.2 Period of Performance (JAN 2014) Page Number: Page 8 Question: “The Period of Performance for the NCCI is estimated to be February 3, 2013 to February 2, 2024.” Please confirm that these dates should read February 3, 2023 to February 2, 2028.

CMS Response: The date should read February 3, 2023, correction has been made to the Solicitation Section F.2, Period of Performance.

2. Question 2 Section (i.e. RFP, SOW): RFP Title and Number (including subparagraph designations): L.6 Technical Proposal Instructions (Volume I), 4. Past Performance, B. Instructions Page Number: Page 53 Question: There is mention of no more than three past performance submission for the Prime, and no more than two for each significant Subcontractor. Later in the section, there is language that reads “…count towards the Offeror’s (Prime’s) maximum of five overall past performance submissions.” Please confirm the total number of past performance submissions for the Prime and Significant Subcontractors.

CMS Response: The referenced paragraph has been updated to include a maximum of three overall past performance submissions for the Prime. In addition the reference to “All” has been removed from L.6 (4)(b)(1 & 2).

3. Question 3 Section (i.e. RFP, SOW): RFP Title and Number (including subparagraph designations): L.6 Technical Proposal Instructions (Volume I), 4. Past Performance, B. Instructions Page Number: Page 54 Question: Can you clarify how many Past Performance Questionnaire’s a Prime, and Significant Subcontractor may have submitted each? The text “Offerors and proposed significant subcontractors without relevant Federal government past performance experience may ask customers to submit no more than three Past Performance Questionnaire (PPQ)” could be interpreted as three in total or three for each.

CMS Response: The number of PPQs should not exceed the maximum allowable past performance submissions for either the Prime or Significant Subcontractor. Specifically, the text has been updated to include the following underlined text: Offerors and proposed significant subcontractors without relevant Federal government past performance experience may ask customers to submit no more than three (Prime)/ two (Significant Subcontractor) Past Performance Questionnaire (PPQ) for the same or similar work directly to the Contracting Officer (See Exhibit E.6).

4. Question 4 Section (i.e. RFP, SOW): RFP Title and Number (including subparagraph designations): L.4 Proposal Submission Page Number: Page 47 Question: This section insinuates that there are separate proposals that the Prime and Significant Subcontractors will submit. Can you clarify what is required to be submitted separately from the Significant Subcontractors?

CMS Response: The phrasing “Prime Contractor AND Subcontractor” is only intended to clarify the intent behind “any portion”. There is nothing explicitly required to be submitted separately by a Subcontractor.

5. Question 5 Section (i.e. RFP, SOW): RFP Title and Number (including subparagraph designations): L.6 Technical Proposal Instructions (Volume I), 2. Technical Understanding & Approach- Scenario Response.

Page Number: Page 52 Question: For the Offeror response to Scenario C, would CMS like us to show the column and date errors on the E.7 Attachment directly within that attachment or a separate Excel Spreadsheet, or tabled out in our Technical Proposal?

CMS Response: Other than as provided in the proposal instructions paragraph 2. Format and the applicable page limits, CMS does not require a specific format for the response to Scenario C.

STATEMENT OF WORK (SOW) QUESTIONS

6. Question 1 Section (i.e. RFP, SOW): SOW Title and Number (including subparagraph designations): D. Assumptions Page Number: 6 Question: It is our understanding that, if staffed properly, at one point there were more than one FTE for all Key Personnel positions except for the Coding Specialist and Medical Director. For an effective NCCI, we feel that additional FTE’s should be considered other than what was mentioned in the Assumptions. Should we price our Business Proposal for the full amount of FTE’s we feel are necessary? If our alternative staffing plan is considered, and then rejected, will we be given an opportunity to revise our Business Proposal pricing?

CMS Response: The assumption states “Assume one FTE for each of the key personnel positions with the exception of Medical Director and Coding Specialist.” The RFP states on page 46 that “Offeror’s are cautioned it is the Government’s intent, if determined to be in the Government’s best interest, to award on initial proposal submissions. Proposals should be submitted initially on the most favorable terms from a price/cost and technical standpoint.” The Offeror should propose their best technical approach, including the staffing to meet that approach. As noted in the assumptions, alternate staffing arrangements will be considered if supported by the contractor’s technical solution.

7. Question 2 Section (i.e. RFP, SOW): SOW Title and Number (including subparagraph designations): Task Group 3: Support Operations. Task 3.0 Correspondence, Inquiries and Communications Page Number: 16 Question: What were the historical volumes (amounts) for incoming correspondence, inquiries, and communications related to Task 3.0?

CMS Response: For the NCCI program including Medicare and Medicaid, the total number of communications (incoming plus responses) is on average 2,350 per contract year. This number was calculated from the most recent three contract years; the range was from approximately 1,600 to 3,300 per contract year.

8. Question 3 Section (i.e. RFP, SOW): SOW Title and Number (including subparagraph designations): I. Scope. B. Purpose Page Number: 6 Question: With mention of the contractor establishing the databases, is this stating that the current databases to store the edit files are owned by the contractor and not CMS? Should there be any expectation of a transitioning of the current databases for edit files?

CMS Response: It is CMS’ expectation that the contactor will establish and maintain databases directly accessible to CMS to support deliverables related to the requirements of this contract, which is supported by the Offeror’s technical solution. In accordance with the SOW, during the transition-in, the incoming Contractor will receive background information, documentation, records and priority tasks for start-up from CMS and the incumbent Contractor.

9. Question 4 Section (i.e. RFP, SOW): SOW Title and Number (including subparagraph designations): I. Scope. B. Purpose Page Number: 6 Question: There was previously a Microsoft Access database requirement for the NCCI database, is there now no technical requirements for the database and method that the contract chooses to store the edits and associated files?

CMS Response: The SOW states that “The Contractor shall provide CMS with continuous controlled access to the NCCI databases and the instructions for using it. The Contractor shall maintain all documents internally and provide continuous controlled access to CMS.” CMS does not specify how the Contractor will meet this requirement for access to the NCCI databases, but expects that the offeror will provide an effective and efficient solution that may include innovations.

10. Question 5 Section: J.1 – NCCI SOW Title and Number (including subparagraph designations):Task 2.4 NCCI Edits Derived from Publications and Special Initiatives Page Number: 15 Question:

For pricing and staffing purposes, can CMS confirm the following:

1. As a cost saving potential, will CMS provide access to scholarly databases that they maintain subscriptions to that would contain relevant information and allow streamlined research?

1. Will CMS be able to provide any access to internal documents during the clearance process so that changes are ready when the new CMS guidance is published?

1. Will CMS notify contractors of pending internal CMS guidance that they are aware of that cannot be shared pre-publication so the contractor can immediately review and respond?

CMS Response:

1) CMS has a limited number of subscriptions and licenses available for CMS employees only and will not be able to provide contractor access to them.

2) Internal documents undergoing clearance are not final and cannot be shared.

3) CMS cannot share pre-deliberative, proposed, or information that is not final, nor would it be appropriate for the NCCI Contractor to respond on unfinalized or pending internal CMS guidance.

11. Question 6 Section: J.1 – NCCI SOW Title and Number (including subparagraph designations):Task 3.4 NCCI Education to Provider Community Page Number: 18 Question:

For pricing and staffing purposes, can CMS estimate approximate volumes for the following:

1. Number of outside stakeholder meetings to attend per year

0. Additionally – Certain meetings that have been virtual were traditionally in person. Will CMS allow for travel if those meetings return to in-person only?

1. Number of presentations to be prepared per year

1. Number of articles to be written per year

1. Number of articles to be reviewed per year CMS Response:

1) Number of outside stakeholder meetings/calls to attend per year: Based on the past three calendars years, meetings have all been virtual and usually lasted 30 minutes. There was an average of 10 meetings per calendar year, with a mode of 8 meetings per year. Approximately half of the meetings were with State Medicaid Agencies.

a. All meetings will be virtual.

2) Number of presentations to be prepared per year: In the past three calendars years, there were no presentations prepared by the NCCI contractor. For proposal purposes assume one per contract year.

3) Number of articles to be written per year: In the past three calendars years, there were no articles written by the NCCI contractor. For proposal purposes assume one per contract year.

4) Number of articles to be reviewed per year: Based on the past three calendars years, there were an average of two articles reviewed per year. The articles are produced by CMS staff, and examples are the How to Use the NCCI Tools articles, and the Proper Use of Modifiers 59 & –X{EPSU}article.

MISCELLANEOUS QUESTIONS

12. Question 1 Section, if applicable: N/A Document, Section & Page Number as applicable: N/A Question: With no requirement for Microsoft Access database use, is CMS now allowing for files to be sent in SQL Database format?

CMS Response: Yes, CMS will allow any format including SQL.

Question 2 Section, if applicable: N/A Document, Section & Page Number as applicable: N/A Question: Will CMS allow us to export data from the current contractor’s database into the Offeror’s database to fully extract the edit files during the transition period?

CMS Response: Yes.

13. Question 3 Section, if applicable: Not applicable Document, Section & Page Number as applicable: Not applicable Question: Can CMS provide information regarding the number of edits that currently exist that will need to be maintained for each edit type (PTP, MUE, and AOC), and approximately how many new edits are usually added on an annual basis.

CMS Response:

Please refer to the publicly available edit files for exact numbers (See SOW Section I.A, Background). Generally, CMS develops new NCCI edits in response to annual changes in the AMA CPT code set. These changes may result in thousands of NCCI edits based on similar edits with existing codes.

14. Question 4 Section, if applicable: Not applicable Document, Section & Page Number as applicable: Not applicable Question: The recipient of this contract is required to maintain all NCCI PTP, MUE and AOC edits on an ongoing basis, and provide full replacement files for each of the edit types on a quarterly basis. Does CMS have a preference of which tool the contractor uses to maintain the edit data?

CMS Response: The SOW states that the NCCI Contractor shall develop PTP, MUE and AOC edit files in a format jointly agreed to and approved by CMS. CMS does not specify how the Contractor will meet this requirement for edit maintenance, but expects that the offeror will propose/provide an effective and efficient solution that may include innovations.

14. Question 5 Section, if applicable: Not applicable Document, Section & Page Number as applicable: Not applicable Question: Does CMS require the contractor to use a specific system to manage and send edits files to CMS systems?

CMS Response: At this time, the files are sent to CMS via GENTRAN, e-mail or CMS Box, depending on the type of file.