Justification Approval - Other Than Full and Open Competition_Redacted.pdf
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- Solicitation number
- 75FCMC25PJ020
About this file
This is a Justification and Approval for Other Than Full and Open Competition (J&A) document dated August 31, 2026, for a contract modification with The Regulatory Group: DocketScope.
The Centers for Medicare & Medicaid Services (CMS) Center for Medicare (CM) is modifying existing contract 75FCMC25PJ020 with The Regulatory Group, a small business consulting firm located at 1901 Fort Myer Drive, Arlington, VA 22209. The modification is a firm-fixed-price contract that extends the base period (09/11/2025–09/10/2026) with one additional option period (09/11/2026–09/10/2027). The services involve DocketScope, an analysis software platform with built-in tools to track, analyze, and report on public comment data in real-time. The software is essential for CMS Medicare Advantage (Part C) and Prescription Drug Benefit (Part D) policy rulemaking, enabling CM-CD staff to assess public comments efficiently and improve comment triage workflows. The justification cites FAR 6.302-1, asserting that only one responsible source exists because DocketScope is the only FedRAMP-certified comment review software available that meets the agency's requirements. Market research determined that other small business applications and data analysis software options do not conform to Medicare rulemaking policy tool needs or provide equivalent functionality. The document notes this is a continuation of prior sole-source acquisitions under contract 75FCMC23P0032. The modification adds an additional performance period to sustain software access and support ongoing policy analysis and improved workflows for healthcare community comment incorporation. Specific pricing and total estimated costs are redacted in the document.
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JUSTIFICATION AND APPROVAL FOR OTHER THAN FULL AND OPEN COMPETITION
UPDATE – 8.31.2026
Acquisition Title: Medicare Advantage (Part C)/Prescription Drug (Part D) Payment Policy Public Comment Support Agency: CMS/CM Acquisition Year: 2026 Author:
1. Description of Action:
Nature New Requirement Follow-On Order Modification of Existing Purchase Order/Contract Number 75FCMC25PJ020
Contract Type Firm-Fixed Price Time and Materials Cost Plus Fixed Fee (CPFF)
Term Completion
Cost Plus Award Fee (CPAF) Other: _______________________
Name of Proposed Contractor:
The Regulatory Group: DocketScope 1901 Fort Myer Dr #1120 Arlington, VA 22209
2. Description of Services or Supplies:
The Regulatory Group (TRG) is a small business consulting firm specializing in the Federal regulatory process. DocketScope is an analysis software incorporated with TRG that has built-in tools to track and analyze public comment data and provide real-time metrics and reporting. This tool is essential for CM-CD staff to quickly assess public comments. In addition, this tool will improve efficiency and workflows to support comment triage on proposed policies for the CMS Medicare Advantage (MA) and Prescription Drug Benefit programs.
Basis for Approval (Far 6.303-1(d) Individual Basis Class Basis
10. A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition for the supplies or services required
N/A
4. Head of Contracting Authority (HCA) Approval
I hereby confirm the circumstances described above apply and approve the justification for other than full and open competition.
HCA Name / Date
5. CMS Competition Advocate (CA) Approval I hereby confirm the circumstances described above apply and approve the justification for other than full and open competition.
Name / Date
6. Senior Procurement Executive (SPE) Approval Based on the foregoing justification, I hereby approve the procurement of (state supplies/services being procured) on another than full and open competition basis pursuant to the authority of (state the full statutory authority and FAR cite and title, consistent with paragraph 4, e.g. 41 U.S.C. 253(c)(1)), as implemented by FAR 6.302-1), subject to the availability of funds, and provided that the services herein described have otherwise been authorized for acquisition.
Name / Date
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