Consolidated Q and A.xlsx
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- Attached to
- National Provider Directory (NPD) Data Sourcing, Aggregation, and Quality Assurance Services
- Solicitation number
- 75FCMC26R0063
About this file
This is a Consolidated Questions and Answers document providing 76 responses from the Centers for Medicare and Medicaid Services (CMS) to offeror questions regarding the National Provider Directory (NPD) Data Sourcing, Aggregation, and Quality Assurance Services solicitation (75FCMC26R0063). The Q&A addresses critical clarifications on contract structure, pricing, scope, performance standards, and operational dependencies across two primary work areas: WA A (Data Normalization and Delivery) and WA E (Data Aggregation, Quality, and Assurance Services).
Key clarifications include: the contract type conversion for CLIN 0003 (data licensing costs) from Time-and-Materials with a Not-to-Exceed ceiling in the base year to Firm Fixed Price in option years, with CMS confirming it will process ceiling increases via modification if approved source portfolio costs exceed the established ceiling; CLIN 0001 (WA A management services) and CLIN 0002 (WA E quality assurance) are Firm Fixed Price in all years; pricing of each required dataset should be submitted at full anticipated cost with no Government-Furnished Information offset applied pre-award, with offsets resolved post-award through the CLIN 0003 T&M structure; offerors may establish baseline portfolio assumptions in price narratives, with CMS-directed onboarding beyond stated baselines treated as changes entitling contractors to equitable adjustment; the WA E Performance Start Date and 45-day Initial Operating Capability clock begin when CMS confirms WA B write-back is operational, anticipated within the base year with confirmation expected within 30 days of award; WA E correction acceptance rate measurement and downstream validation of WA C FHIR API outputs are contingent on WA B, C, and D operational status, with delays treated as excusable delays; defect density thresholds and baselines will be established collaboratively within 30 days of award rather than prescribed in the solicitation; direct outreach provider verification (phone, in-person) is within WA E downstream validation scope; and multi-year source price schedules are acceptable provided they include termination provisions meeting Data Rights and Portability requirements. CMS also confirmed that data licensing agreements constitute materials or other direct costs, not subcontracts, for pricing purposes; the five-source Initial Operating Capability threshold will be adjusted downward if post-award GFI determinations establish that required datasets are covered by Government-Furnished Information; and WA E upstream quality assessment does not gate WA A data flow into the WA B pipeline but serves as an assessment function with findings routed to CMS government staff.
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Sheet1 Question Number SOO/RFQ Section and/or Page Number Question (for Respondent use) Response (for CMS use)
| 1 | Attachment 6 - Pricing Template | The Attachment 6 - Pricing Template references the contractor's Price List Labor Category and Rates but the RFP does not have any reference to a schedule (i.e.: GSA MAS, etc.) to use for pricing purposes. Can the Government please clarify that pricing should be done under a GSA MAS schedule/SIN? | This solicitation is issued in accordance with FAR Part 12 and FAR Part 15. The Government confirms the information within the RFP pricing Template is provided as an example. | |
| 2 | Attachment 1, Instructions to Offerors, p. 2, and Solicitation, Contract Administration Data (p. 10) | The Contract Specialist's email address is listed as walker.t.hare@cms.hhs.gov in the Instructions to Offerors submission section, and as walker.hare@cms.hhs.gov in the Solicitation's Government Representatives section. Please confirm the correct address for proposal submission. | Email address has been corrected to walker.hare@cms.hhs.gov | |
| 3 | SOO, Constraint 6 (p. 39) and SOO Appendix B, Section 2.D (p. 10) | The SOO states that low severity vulnerabilities shall be remediated within 365 days of identification, while Appendix B states 360 days for the same category. Please confirm the correct remediation timeline. | Revised Appendix B to reflect 365 days. | |
| 4 | SOO Appendix B, Section 2.A.d (p. 2) | The Privacy Compliance subsection marks this solicitation as involving "No PII," yet the SOO and this same appendix describe handling of provider identifying records (state license numbers, board certification data, NPI linked records) and separately require encryption of PII, PII breach reporting, and PII specific incident response procedures throughout Appendix B. Please clarify whether NPD provider data delivered or corrected under WA A and WA E is considered PII for purposes of this contract, and if so, whether the PII determination in Appendix B will be corrected. | Revised Appendix B to reflect PII selection. | |
| 5 | Attachment 1, Instructions to Offerors, Supplemental Dataset table (p. 7–8) and SOO Table 2 (p. 27–29) | There is a mismatch in the Instructions to Offerors' Supplemental Dataset table between the dataset names and the authoritative source descriptions. For example, dataset 9 (Payer/health plan data) is paired with the source description for accreditation bodies (Joint Commission, NCQA), dataset 10 (Board certification, non physician) is paired with the source description for payer/health plan data (NAIC, state Medicaid agencies), and dataset 11 (Additional data sources proposed by offeror) is paired with the source description for non physician board certification bodies. Please clarify. | The Government acknowledges the mismatch in the Supplemental Dataset table in the Instructions to Offerors. An amendment to the Instructions to Offerors will be issued to correct this table. |
| 6 | Attachment 3, QASP Example (all pages) | This attachment appears to be a generic QASP template built for a different type of engagement, referencing website uptime, page load times, server patching, and similar infrastructure metrics that fall outside WA A and WA E scope as defined in the SOO (WA C and WA D infrastructure and front end work are explicitly out of scope). Please confirm that Attachment 3 is provided solely as an illustrative format example and that offerors should build their proposed QASP around the performance objectives in SOO Appendix B rather than the specific measures shown in Attachment 3. | The Government confirms the QASP attachment is provided as an illustrative format example and that offerors should build their proposed QASP around the performance objectives in the SOO. The Government notes required QASP objectives, performance standards, etc. are provided in the SOO. |
| 7 | RFP Section Evaluation Factors for Award - Evaluation Process page 4 | The Instructions state the Phase 1 Corporate Experience narrative is limited to 6 pages, and that "Artifacts are not included in the page count." Focus Area 1 explicitly labels its two required submissions as "Artifact 1" and "Artifact 2." Focus Areas 2 and 3, however, request supporting documentation (e.g., a quality improvement report, correction acceptance rate dashboard, before/after accuracy comparison, QASP performance report, data source change log, sourcing decision memo, or pipeline configuration change record) without using the term "Artifact." Please confirm whether this supporting documentation for Focus Areas 2 and 3 is also considered an "Artifact" excluded from the 6-page limit, or whether it counts toward the page limit for the Corporate Experience narrative. | Supporting documentation submitted in connection with Focus Areas 2 and 3 — including quality improvement reports, correction acceptance rate dashboards, before/after accuracy comparisons, QASP performance reports, data source change logs, sourcing decision memos, and pipeline configuration change records — is considered an artifact for purposes of the page count exclusion and does not count toward the 6-page Corporate Experience narrative limit. Offerors should clearly label all such supporting documentation as artifacts and reference them within the narrative. An amendment to the Instructions to Offerors will be issued to clarify this. |
| 8 | RFP Section Oral Presentation (Interview-Style), "Schedule and Agenda" page 12 | The Schedule and Agenda lists: |
(1) Introductions – approximately 10 minutes;
(2) Contractor Oral Presentation – 1 hour maximum, including a 5-minute break;
(3) Clarifying Q&A Session (if necessary) – 15-minute maximum; and
(4) Total Time – 1 hour maximum.
| Items 1–3 sum to as much as 1 hour 25 minutes, which exceeds the stated 1-hour total. Please clarify if the 1-hour total includes only the Contractor Oral Presentation itself, with Introductions and Clarifying Q&A occurring outside that hour; or Introductions, the Presentation, and any Clarifying Q&A must together fit within a single 1-hour limit. | The Government confirms that the total time will be 1 hour maximum which includes a 10 minute timeframe for introductions and a 15 minute Q&A session (if necessary). The 5 minute break will not be counted in the total time. | |||
| 9 | RFP Section Factor Two (PWS – Key Personnel) page 10 and Oral Presentation (Interview-Style) – Participants page 13 | The Instructions reference "Key Personnel" in two places: (1) the PWS requirement to identify Key Personnel with an explanation of qualifications needed for successful performance of the role, and (2) the Oral Presentation instructions, which state the presentation team "should include the proposed key personnel." However, the SOO does not appear to designate specific Key Personnel roles or positions. Please clarify: (a) whether CMS intends for offerors to self-designate which roles constitute Key Personnel for this effort, or (b) whether a list of required Key Personnel roles will be provided. | Offerors are responsible for identifying key personnel required to perform their approach to this requirement. | |
| 10 | SOO Appendix B (QASP), CLIN 0002 – Data Quality and Assurance Services (WA E), "NPD output quality improvement" metric | The QASP in SOO Appendix B includes a WA E performance metric for "NPD output quality improvement," measured as change in correction acceptance rate, reduction in known error patterns, and increase in high confidence records over successive Program Increments. Output quality of the published NPD is a function of WA A source quality, WA B reconciliation logic, WA C FHIR API implementation, WA D directory implementation, and WA E corrections combined. Please clarify how CMS will attribute output quality outcomes to the WA E contractor given that WA B, WA C, and WA D performance is outside the WA E contractor's control, and whether the "NPD output quality improvement" metric is intended to measure WA E's contribution net of other work area performance or the overall NPD output quality regardless of cause. | The "NPD output quality improvement" metric measures WA E's contribution to NPD output quality — not overall NPD output quality regardless of cause. WA E is accountable for the accuracy of corrections and enrichments it delivers and for the quality of its downstream validation assessments. WA E is not accountable for WA B reconciliation logic, WA C FHIR API implementation, or WA D directory rendering. Where output quality issues are attributable to WA B, WA C, or WA D, those issues will be documented in the WA B pipeline rejection attribution log and will not be counted against WA E performance. | |
| 11 | SOO NPD Program Structure Page 9 | What is the definition of outcome data quality for WA E for CMS? | For purposes of this contract, WA E outcome data quality is the measurable improvement in accuracy, completeness, and currency of NPD provider records attributable to WA E corrections and enrichments, assessed at both ends of the NPD data lifecycle. Input-side quality is measured by correction acceptance rate, coverage of WA A source categories assessed per Program Increment, and quality of feedback loop findings. Output-side quality is measured by reduction in ghost network indicators, stale records, and directory inaccuracies identified through WA E downstream validation. Specific AQLs are established in Appendix B. The baseline will be established collaboratively with the awardee during startup activities in the first Program Increment. | |
| 12 | SOO Table of Contents (p. 4) and attached solicitation documents SOO Appendix A and SOO Appendix B | The SOO Table of Contents lists Appendix A as "Security Requirements" and Appendix B as "Quality Assurance Surveillance Plan (QASP)." The attached PDFs are SOO Appendix A, captioned "Accessibility Requirements Tool ICT Accessibility Requirements Statement per Section 508 of the Rehabilitation Act," and SOO Appendix B, captioned "CMS Cyber Security Requirements." The QASP is provided in the body of the SOO rather than as a separately attached appendix. Please confirm the correct labeling and reconciliation of these appendices, including the intended reference location of the Section 508 solicitation language relative to the SOO. | The SOO has been updated to reflect the correct references to each Appendix. Appendix A is Section 508 requirements, Appendix B is CMS Cyber Security Requirements, and Appendix C is the QASP. | |
| 13 | SOO, Table 1 – Required Datasets (p. 24–26); Table 3 – Government-Furnished Information (p. 30) | Source of Base Data for Ingestion: Does WA A create the base data, or will CMS provide base data (e.g., NPI, name, and active status from GFI sources such as NPPES and PECOS) that WA A must clean and enrich? |
If the former: What is the required ingestion frequency? Can ingestion frequency vary by data source based on when each WA A source is refreshed?
If the latter:
1. What are the input data sources for the system?
2. What file format is the system expected to ingest?
3. What is the frequency of updates from these systems?
4. What is the expected data volume (e.g., number of providers, records, etc.)? WA A creates the base data — the contractor establishes direct licensing relationships with authoritative data sources and delivers normalized data files to CMS-designated storage. GFI sources (NPPES, PECOS, data.cms.gov, Lantern, APS) are provided as government-furnished information and are not procured under this contract. The WA B pipeline ingests WA A deliveries and reconciles them with GFI sources and WA E corrections. File formats and delivery specifications will be defined during startup activities in the first Program Increment. Delivery cadence is at minimum weekly for all required datasets, or at the source's natural publication cadence for less frequently updated sources. Offerors should use approximately 2 million active providers as a notional planning assumption for data volume.
| 14 | SOO, Deliverables Summary (p. 54); Category 2 – WA A Data Normalization and Delivery (p. 19) | Is CMS open to different refresh cycles by data element — for example, refreshing name less frequently than address, since name changes less often? | Yes. CMS is open to differentiated refresh cycles by data element where the natural update frequency of the source data supports it. Offerors should propose their recommended refresh cadence by dataset category and data element type in their technical approach, with justification based on the source's update frequency and the NPD's accuracy requirements. CMS will review proposed refresh cadences and will establish final delivery specifications collaboratively with the awardee during startup activities in the first Program Increment. |
| 15 | SOO, Definitions – Minimum Public Field Schema (p. 15, 36) | Does CMS have a list of the data elements it needs for source-of-truth data? | CMS has not finalized a minimum public field schema. It will be developed collaboratively with the awardee during startup activities in the first Program Increment. CMS anticipates that provider identity fields (NPI, name, taxonomy, practice location) will be in the Publish tier for all required datasets. Offerors should propose their approach to field-level publication tier classification in their technical proposal. |
| 16 | SOO, Definitions – WA B Pipeline (p. 16); Constraint 2 – Intake Validation Scope (p. 36); Category 2 – WA A Data Normalization and Delivery (p. 19–20) | Who is responsible for the integration between WA A and WA B, and between WA D and WA E? |
Is there an expected format and structure that would make it easier for CMS to consume WA A output into WA B?
| This could affect how "normalization" is defined for WA A. Is CMS open to a format, structure, or normalization approach proposed by the vendor? | Integration between WA A and WA B is a CMS government responsibility coordinated through CMS government staff and potentially contractor supporting WA B— the WA A contractor delivers normalized files to CMS-designated storage and the WA B contractor ingests them. WA E downstream validation is conducted as an external consumer of NPD data without requiring direct integration with WA D. CMS is open to vendor-proposed normalization approaches, formats, and schema structures provided they are compatible with WA B ingestion requirements. Final delivery specifications will be established collaboratively with the awardee and WA B contractor during startup activities in the first Program Increment. | |||
| 17 | SOO, p. 31 (data sourcing discussion following Table 3, addressing FOIA-covered/public-record data) | For public sources with no license agreements, can we assume CMS does not require proof of redistribution rights? Is it acceptable to mark that field as N/A? | Yes. For data that is covered by Freedom of Information laws, is publicly available, or is made available through a regulatory publication mandate (such as the FHIR-based provider directories required under the CMS Interoperability and Prior Authorization Final Rule), CMS does not require proof of a negotiated redistribution rights agreement. Offerors may indicate "N/A" for the redistribution rights field for such sources, provided they document the legal basis for public availability (e.g., FOIA coverage, regulatory mandate, or public domain status) in their provenance documentation. The provenance and audit requirements in the Work Area A Sourcing Approach section of the SOO apply regardless of whether a formal license agreement exists. | |
| 18 | SOO, Cloud Services (p. 73) | Does CMS have a preferred cloud infrastructure for application/system deployment? | CMS's preferred cloud infrastructure is CMS Cloud (AWS GovCloud). To the extent WA A or WA E contractors develop lightweight tools, scripts, or systems to support their respective functions, contractors should default to CMS-furnished platforms (CMS Cloud) to the maximum extent practicable, as stated in the Cloud Services section of the SOO. Contractors must obtain CMS approval before using any external SaaS tools or contractor-hosted environments for activities that involve CMS data, licensed data received under this contract, or NPD provider data in any form. | |
| 19 | SOO, Definitions – Authoritative Source (p. 12); Category 3 – WA E Objectives, Correction Acceptance Definition (p. 21–22) | What are the acceptance criteria for prioritizing or deprioritizing authoritative sources — including the evidence required, the weighting applied to source-of-truth status, and the quality of data provided by each source? |
| CMS will evaluate and prioritize authoritative sources collaboratively with the awardee based on: coverage (percentage of target provider population), accuracy (consistency with other authoritative sources and real-world data), currency (update frequency and lag), redistribution rights (compatibility with Constraint 1), cost (relative to coverage and quality), and provenance (traceability to primary authoritative sources). These criteria will be formalized during startup activities in the first Program Increment. Offerors should propose their recommended source prioritization methodology in their technical proposal. | |||
| 20 | Definitions – Authoritative Source (p. 12) | Can attestation, provider websites, appointment-booking websites, phone outreach, etc., be considered a source of truth for certain elements such as provider location or appointment phone number? | Yes, with qualification. Provider attestation, provider websites, appointment-booking platforms, and phone outreach may be used as WA E enrichment and validation sources for elements such as provider location, appointment phone number, and practice affiliation where authoritative source data is incomplete or stale. For WA A purposes, the primary authoritative sources are those identified in Table 1 of the SOO. WA E corrections derived from provider attestation must include the required metadata and are subject to the correction acceptance process described in the SOO. |
| 21 | SOO, Definitions – Rejected Correction (p. 16); Constraint 3 – Issue Escalation Responsibility (p. 37) | WA E includes data validation at the source. Is the WA E contractor expected to discard inaccurate data and maintain a log of those discards? | WA E contractors do not discard WA A source data — they assess quality and deliver corrections via CMS-designated storage or the NPD API write-back mechanism. The WA B pipeline applies reconciliation logic to determine which data is used in the NPD. WA E contractors are expected to document quality findings — including identification of inaccurate, stale, or inconsistent records — in the Data Quality Dashboard and in feedback loop summaries provided to CMS at each Program Increment. |
| 22 | SOO, Table 3 – Government-Furnished Information, APS row (p. 30); Definitions – Government-Furnished Information (p. 14) | What is the expectation when WA A and WA E rely on the same data source for both ingestion and authoritative source-of-truth purposes (e.g., a state licensing board website)? | This is an anticipated scenario. Where WA A and WA E both reference the same authoritative source: WA A establishes the licensing relationship, normalizes the data, and delivers it to CMS-designated storage; WA E may use the same source as a quality assessment reference without a separate licensing agreement, provided the WA A agreement permits such use. The contractor should confirm this in the field-level publication tier documentation. This scenario is one reason WA A and WA E are combined in a single award. |
| 23 | SOO, Definitions – CMS-Designated Storage (p. 13); Data Storage and Delivery (p. 74) | The SOO's CMS-designated-storage provisions describe WA A and WA E submitting data to CMS-designated storage. Does this imply WA E processing will occur in the contractor's own environment, with data transferred to the CMS environment afterward? | Yes. WA E correction generation and quality assessment activities occur in the contractor's own environment. The contractor delivers corrections to CMS-designated storage or the NPD API write-back mechanism — all corrections then flow through the WA B pipeline. The contractor does not have direct write access to the NPD database. |
Where a contractor proposes to perform processing activities (normalization, quality validation, correction generation) in a contractor-hosted environment, the associated hosting and infrastructure costs must be included in the proposed pricing under the applicable CLIN (CLIN 0001 for WA A management services; CLIN 0002 for WA E quality assurance services).
Offerors are also encouraged to explore hosting processing activities within the CMS Hybrid Cloud environment and should indicate in their proposals whether and how they propose to leverage that environment. Information about the CMS Hybrid Cloud offering is available at https://security.cms.gov/learn/cms-hybrid-cloud. Proposals that leverage CMS Hybrid Cloud infrastructure should reflect any associated cost implications accordingly.
Regardless of hosting approach, any contractor-hosted environment used for activities involving CMS data, licensed data received under this contract, or NPD provider data must receive prior CMS approval consistent with the Cloud Services section of the SOO.
| 24 | SOO, NPD Program Structure (p. 9); Note on Acquisition Scope (p. 5) | Do Work Areas B, C, and D exist today, or will they be built out after WA A and WA E are underway? When does CMS expect WA A and WA E to begin integrating with WA B, C, and D? | WA B is currently operational, supported through a separate CMS contract. WA A data deliveries will be ingested by WA B from the start of performance. WA C is currently operational for FHIR API delivery. WA D is a CMS internal function currently under active development, with the public-facing directory available at directory.cms.gov; additional WA D capabilities will be communicated to the awardee during startup activities. WA E downstream validation of WA C FHIR API outputs can begin once the WA E contractor has access to the FHIR endpoint. |
| 25 | SOO, Note on Acquisition Scope (p. 5), NPD Program Structure (p. 9), and Initial Operating Capability (p. 64 to 66) | The SOO states that WA B, WA C, and WA D are supported through separate government or contractor teams and that follow on or concurrent awards may address WA B and WA C as the NPD program matures. Please clarify the expected timelines for WA B, C and D each to be operational. | See answer 24 above. |
| 26 | Attachment 1 NPD Instructions to Offerors, Phase 2, page 11. | Given this a new system and the extensive scope of the SOO, we request that CMS consider expanding the length of the PWS requirement to 30 pages. | The Government has updated the maximum page count for the PWS submission to be thirty (30) pages. |
| 27 | Attachment 1 NPD Instructions to Offerors, Phase 2, page 14. | For the in-person Oral Presentation, can a virtual white board be used (with participants bringing their laptops for collaboration) or are participants restricted to using the physical white board provided? Will a guest Wi-Fi be available for connectivity? The instructions mix conditions for virtual and in person Orals, so it is not clear. | No, as stated in the solicitation, "The Government will provide a white board or flip-chart and markers for the respondent’s use during in-person oral presentations." No connectivity will be provided during in-person oral presentations. Since this is an interview-style oral presentation, respondents must not bring or present slides, graphs, charts or any other written presentation materials. The Government will not accept or receive contractor handouts. |
| 28 | Attachment 1 NPD Instructions to Offerors, Phase 2, page 14. | For the in-person Oral Presentation, can the white board be used also to develop responses to the questions, in addition to addressing the exercise? | Yes. |
| 29 | General | We would like to know if this is a brand new contract OR if there is (was) an incumbent performing these services. |
| If not brand new, could you please provide the current / previous contract number? | This action is considered a new requirement. | |||
| 30 | General | Is there any incumbent/recompete or this is a brand-new project? If yes, could you please provide us with their award number or even if the customer bought similar services in the past. | See answer 29 above. | |
| 31 | General | Could you please confirm whether there is an incumbent contractor for this requirement? If yes, kindly provide the incumbent contractor's name and contract number. | See answer 29 above. | |
| 32 | General | we would like to know if there can be any extensions, for at least one week. | The Government is unable to extend the solicitation due dates at this time. | |
| 33 | Attachment 1 - NPD Instructions | For bidders providing forecasted indirect cost rates, in lieu of existing Forward Pricing Rate Agreements, can CMS confirm if the forecasted indirect cost rates must also be used in the budget calculations (i.e., pricing) for the business proposal? | The solicitation states, "All indirect costs must be sufficiently explained" and "The BOE should discuss the estimating methodology used to develop the proposed price (e.g., engineering estimates, should-cost analysis, historical benchmarks, subcontractor responses, vendor proposal or awarded purchase orders, catalog pricing, cost drivers and associated estimates of their activity, etc.)." | |
| 34 | Attachment 1 - NPD Instructions | For bidders providing forecasted indirect cost rates, can CMS confirm if bidders should blend, or prorate, indirect cost rates when the proposed budget periods span multiple fiscal years for the bidder? | Offerors should propose prices that align with their technical approach. Offerors should explain proposed indirect costs within their basis of estimate as required by the solicitation. | |
| 35 | Attachment 1 - NPD Instructions | Can CMS confirm if the submission of the forecasted indirect cost rate tables alone is sufficient, or are bidders required to provide their underlying indirect cost rate structure and calculations in support? | See answer 33 and 34 above. | |
| 36 | Attachment 1 - NPD Instructions | Can CMS confirm if proposed subcontractors are required to provide indirect cost rate information and supporting documentation as part of the proposal? | Offerors should provide sufficient detail to support all proposed costs. As stated in the instructions to offerors, if subcontractors are proposed, the offeror shall provide a basis of subcontractor pricing. | |
| 37 | NPD Program Structure; How WA A and WA E Work Together; Pricing and Award Structure - Award Structure | |||
| Instructions Sections: Phase One - Focus Area 4, Objectivity and Independent Verifiability; Business Ethics, Conflicts of Interest (COI) and Compliance | Given that WA E requires independent validation of data quality and root-cause attribution, and WA A is responsible for sourcing/licensing some of the data being validated, how does CMS intend offerors to mitigate potential impaired-objectivity concerns when the same prime contractor performs both WA A and WA E under the required combined award structure? | Refer to the Business Ethics, Conflicts of Interest (COI) and Compliance section in the solicitation as well as the Contractor/Offeror Conflict of interest attachment provided. | ||
| 38 | SOO Sections: NPD Program Structure; How WA A and WA E Work Together; WA E Scope Limitations; Initial Operating Capability; Cloud Services | The SOO states that WA E validates data quality at both the upstream input point and downstream NPD output point, submits corrections through the WA B pipeline, and assesses the accuracy of public-facing NPD outputs served through WA C and WA D. The SOO also states that WA B, WA C, and WA D are outside the scope of this acquisition and are supported through separate government and/or contractor teams. |
For purposes of preparing a compliant PWS, QASP, staffing plan, schedule, and price proposal, please clarify the expected operational status, interface availability, and Government-furnished dependencies for WA B, WA C, and WA D at contract award and during the base period. Specifically:
'Will WA B data ingestion, reconciliation, correction intake/write-back, and issue-routing capabilities be operational before the WA A/E awardee is required to perform WA E correction and enrichment activities?
'Will WA C FHIR/API infrastructure and WA D public/provider-facing outputs be available in time for the WA E contractor to validate downstream NPD output accuracy during the base period?
'If WA B, WA C, or WA D capabilities are delayed or unavailable, how should offerors reflect that dependency in their technical approach, QASP measures, IOC assumptions, and pricing?
'Will CMS adjust WA E performance standards, acceptance criteria, and delivery timelines where performance depends on WA B, WA C, or WA D capabilities outside the WA A/E contractor’s control? See Answer 24 Above. WA E Performance Start Date and 45-day IOC clock will begin when CMS confirms it is operational. WA C is operational for FHIR API delivery. WA D public-facing directory is available at directory.cms.gov with additional functionality rolling out iteratively.
Where WA B, WA C, or WA D capabilities are delayed: WA E performance standards and delivery timelines dependent on WA B write-back will be adjusted consistent with the excusable delay provisions in the SOO; CLIN 0002 FFP payments will be administered based on WA E functions performable without write-back (upstream quality validation and downstream consumer-perspective validation); WA B write-back availability is a Government-controlled dependency excusing associated WA E milestones. Offerors should reflect these dependencies in their technical approach, QASP, IOC assumptions, and pricing.
| 43 | SOO Sections: Note on Acquisition Scope; NPD Program Structure; How WA A and WA E Work Together; WA E Scope Limitations; Initial Operating Capability | The SOO states that WA B, WA C, and WA D are outside the scope of this acquisition, are supported through separate government and/or contractor teams, and that follow-on or concurrent awards may address WA B and WA C as the NPD program matures. Because WA E performance under this procurement depends on WA B correction intake/write-back, WA C FHIR/API infrastructure, and WA D public/provider-facing outputs, please provide the current acquisition or implementation timeline for WA B, WA C, and WA D, including whether each work area will be performed by government staff, existing contractors, POC vendors, or future procurements. If CMS cannot provide the timeline, please identify the assumptions offerors should use for proposal preparation, pricing, QASP measures, IOC planning, and base-period WA E deliverables. | See response to Question 38 for current operational status. CMS cannot provide specific acquisition timelines for future WA B, WA C, or WA D procurements. For proposal preparation, offerors should use the following planning assumptions: WA B data platform and ingestion — operational at contract award; WA B write-back for WA E corrections — available within the base year, specific date anticipated to be confirmed by CMS within 30 days of award; WA C FHIR API — operational at contract award; WA D public-facing directory — available at directory.cms.gov with additional functionality rolling out iteratively. Offerors should describe how they will deliver WA E value during any period when WA B write-back is not yet available. |
| 44 | SOO, Definitions (WA E Performance Start Date); SOO, Initial Operating Capability (WA E IOC); SOO, Note on Acquisition Scope (p. 5) | The WA E Performance Start Date and the 45-day WA E IOC clock are defined by CMS confirmation that the WA B write-back mechanism is operational. Please state (a) whether WA B write-back capability will be provided by a government team or a contractor as of the start of performance, and (b) the anticipated timeframe for write-back availability relative to the 25 SEP 2026 start of performance. If available, please also indicate the anticipated structure and timing of the WA B procurement referenced in the SOO's Note on Acquisition Scope, as this bears on WA E performance planning and pricing. | The WA B write-back mechanism is being developed through the existing separate CMS contract supporting WA B. CMS anticipates it will be available within the base year and anticipates providing written confirmation to the awardee within 30 days of contract award or as soon as it is confirmed operational. Offerors should price CLIN 0002 to reflect the possibility that WA E correction delivery via write-back may not begin on day one of performance, and should describe how they will deliver upstream and downstream quality validation during any period when write-back is not yet available. |
| 45 | SOO Appendix A attachment, CMS Cyber Security Requirements, Section 2.A.d.ii (PII determination); Solicitation, HIPAA Business Associate Clause (OCT 2014); SOO, Table 1 (Required Datasets) | The CMS Security and Privacy attachment indicates this contract involves No PII (Section 2.A.d.ii), while the solicitation incorporates the HIPAA Business Associate Clause and the required datasets include individually identifiable practitioner-level data (licensure status, practice addresses, certification status). Please confirm (a) whether the No PII determination stands for both Work Areas A and E, and (b) whether CMS anticipates the contractor functioning as a Business Associate under the incorporated HIPAA clause, so that offerors can align privacy controls and pricing accordingly. | See above response and updated Appendix B attachment. |
| 46 | Attachment 2, Statement of Objectives (NPD Work Area A and E), 24 July 2026 |
Pricing and Award Structure; Cost Drivers; "Contract Type Conversion - CLIN 0003"
pp. 67-68 The Contract Type Conversion provision for CLIN 0003 concludes with the parenthetical note "(CO to confirm FAR authority and contract clause citation before solicitation release.)" Will the Government identify the FAR authority and the specific contract clause that will govern conversion of CLIN 0003 from T&M ODC in the base year to Firm Fixed Price in Option Years 1 through 4? Offerors need this citation to price option year risk and to evaluate the stated remedy that failure to submit an FFP proposal within thirty calendar days constitutes a material breach.
| Because the Instructions to Offerors provide that the solicitation controls in the event of any conflict with a CMS answer, offerors respectfully request that any affirmative response to this question be effected by amendment to the solicitation rather than by answer alone. | Refer to updated Contract Type Conversion Section in Statement of Objectives for updates regarding this question. | |
| 47 | Attachment 2, Statement of Objectives (NPD Work Area A and E), 24 July 2026 |
Pricing and Award Structure; Cost Drivers, "Contract Type Conversion - CLIN 0003"; Award Structure, CLIN Structure table; read with Approach, Flexibility and Iteration, and Appendix B QASP, CLIN 0001, "New source onboarding timeliness"
pp. 67-68; p. 69; p. 33; p. 81 CLIN 0001 is Firm Fixed Price in all years. It covers data source relationship management, licensing negotiation, quality monitoring, and delivery coordination, so its level of effort is a direct function of the number of active sources in the portfolio. CLIN 0003 converts to Firm Fixed Price based on actual base year licensing costs and the dataset list as modified post-award. The Flexibility and Iteration section separately reserves the Government's right to direct the contractor to onboard new data categories at any time, with a QASP standard of ninety calendar days from CMS direction to first successful delivery. Neither CLIN carries a stated portfolio baseline, so offerors cannot determine what portfolio size their fixed prices are expected to cover. (a) Will the converted Firm Fixed Price for CLIN 0003 be bounded to the CMS-approved source portfolio as it exists on the conversion date, with any CMS-directed source additions during an option year priced and funded by contract modification? (b) Does the Government have an assumed steady-state portfolio size beyond the six required datasets in Table 1 for purposes of pricing CLIN 0001? (c) If not, will the Government confirm that an offeror may state a baseline portfolio assumption in its price narrative, and that CMS-directed onboarding beyond that stated baseline will be treated as a change entitling the contractor to an equitable adjustment?
Because the Instructions to Offerors provide that the solicitation controls in the event of any conflict with a CMS answer, offerors respectfully request that any affirmative response to this question be effected by amendment to the solicitation rather than by answer alone. a) The Government confirms that the FFP price for CLIN 0003 at option year conversion will be bounded to the CMS-approved source portfolio as it exists on the conversion date, inclusive of any modifications made during the base year. Any CMS-directed addition of data sources following the option year conversion will be priced and funded via bilateral contract modification. The SOO will be amended to reflect this clarification.
b) The Government's pricing baseline for CLIN 0001 is the six (6) required datasets identified in Table 1. CMS does not prescribe an assumed steady-state portfolio size beyond these six datasets for proposal pricing purposes. See also the response to part (c) below.
c) The Government confirms that offerors may state a baseline portfolio assumption in their price narrative for CLIN 0001. CMS-directed onboarding of data sources beyond an offeror's stated baseline will be treated as a change in terms and conditions of the contract. The contractor will be entitled to seek an equitable adjustment in accordance with the applicable Changes clause. The SOO will be amended to reflect this clarification.
48 Attachment 2, Statement of Objectives (NPD Work Area A and E), 24 July 2026 Pricing and Award Structure; Cost Drivers; "Contract Type Conversion - CLIN 0003"; read with Constraint 1, Field-Level Publication Tiers
pp. 67-68; pp. 34-36 Data source agreements executed in the base year will come up for renewal during the option years, and the contractor does not control renewal pricing or renewal terms. Under a fixed CLIN 0003 price, how does the Government intend to treat the following events occurring after conversion: (a) a source increasing its renewal price above the amount reflected in the converted FFP price; (b) a source declining to renew, requiring replacement sourcing; (c) a source with usage-based or per-query pricing where consumption is driven by WA B and WA E activity rather than by WA A; and (d) a source holding price constant while reducing redistribution rights, for example moving a field from the Publish tier to Use Internally Only at renewal, such that CMS receives materially reduced rights for the same fixed price? Offerors request confirmation that these events are addressed by contract modification or equitable adjustment rather than absorbed within the fixed price.
| Because the Instructions to Offerors provide that the solicitation controls in the event of any conflict with a CMS answer, offerors respectfully request that any affirmative response to this question be effected by amendment to the solicitation rather than by answer alone. | The Government will follow the procedures as stated under the True-Up Clause under the Special Requirements Section of the solicitation. Please refer to that section for the process regarding CLIN 0003. | |
| 49 | Attachment 2, Statement of Objectives (NPD Work Area A and E), 24 July 2026 |
Pricing and Award Structure; Cost Drivers; "Contract Type Conversion - CLIN 0003"; read with Constraint 5, CMS Approval for All Agreements; Constraint 4, Independent Licensing Requirement; Approach, Flexibility and Iteration; and Data Rights and Portability
pp. 67-68; p. 38; pp. 37-38; p. 33; pp. 39-40 The SOO states that the Firm Fixed Price proposal for CLIN 0003 in each option year will be based on actual base year licensing costs, confirmed GFI determinations, and the dataset list as modified post-award. Constraint 5 separately requires CMS written approval before any data access agreement is finalized. Offerors ask how these provisions apply where the contractor negotiates a source agreement containing a defined multi-year price schedule covering the base period and the option periods, and the Contracting Officer approves that agreement before execution. (a) Will the Government establish the CLIN 0003 Firm Fixed Price for each option year by reference to the CMS-approved contractual price schedule for each source, rather than by extrapolation from base-year invoiced amounts? (b) Does the Government prefer multi-year source price schedules, given that they establish option-year pricing in advance and materially reduce the renewal exposure identified in the Cost Drivers section? (c) Will the Government confirm that a multi-year source agreement is consistent with Constraint 4 and with the Flexibility and Iteration provision, provided the agreement includes termination and non-renewal terms meeting the Data Rights and Portability requirements, such that a CMS decision not to exercise an option creates no residual contractor obligation? (d) Where a multi-year agreement has been approved by the Contracting Officer and a subsequent GFI determination establishes that the dataset is covered by Government-Furnished Information, how will the Government treat the contractor's remaining obligation under that agreement?
| Because the Instructions to Offerors provide that the solicitation controls in the event of any conflict with a CMS answer, offerors respectfully request that any affirmative response to this question be effected by amendment to the solicitation rather than by answer alone. | (a) Yes — where a contractor negotiates a CMS-approved multi-year source price schedule, CMS will establish CLIN 0003 FFP for each option year by reference to that approved schedule rather than by extrapolation from base-year invoiced amounts. (b) CMS is open to multi-year source price schedules where they reduce renewal exposure, provided agreements meet Constraints 4 and 5 and the Data Rights and Portability requirements. (c) Multi-year agreements are consistent with Constraint 4 provided they include termination and non-renewal terms meeting the Data Rights and Portability requirements — a CMS decision not to exercise an option creates no residual contractor obligation. (d) Where a multi-year agreement is in place and a subsequent GFI determination covers that dataset, CMS will address the contractor's remaining obligation through contract modification. | |
| 50 | Attachment 2, Statement of Objectives (NPD Work Area A and E), 24 July 2026 |
Pricing and Award Structure; Award Structure; CLIN Structure table, CLIN 0003 ("T&M ODC (NTE ceiling) - base year")
p. 69 CLIN 0003 is identified as T&M ODC with a not-to-exceed ceiling for the base year. Will the Government confirm that the NTE ceiling operates as a limitation of the Government's obligation, such that the contractor is not required to continue acquiring data licenses once the ceiling is reached, and that CMS will raise the ceiling by contract modification if the CMS-approved source portfolio costs more than the ceiling amount? Offerors also request the process and expected timeline for a ceiling increase, given that CMS written approval is required before execution of every source agreement.
| Because the Instructions to Offerors provide that the solicitation controls in the event of any conflict with a CMS answer, offerors respectfully request that any affirmative response to this question be effected by amendment to the solicitation rather than by answer alone. | In accordance with FAR 16.601(c), the Not-to-Exceed (NTE) ceiling established under a Time-and-Materials contract represents the maximum obligation of the Government, and the contractor is not required to continue performance—including the acquisition of data licenses—once that ceiling is reached; any increase to the ceiling requires a bilateral contract modification. Should approved source portfolio costs exceed the established NTE ceiling, the Government will process a ceiling increase via contract modification in a timely manner, and CMS will communicate the applicable approval process and expected timeline to the contractor consistent with the written approval requirements outlined in the contract. | |
| 51 | Attachment 1, Instructions to Offerors |
Phase Two, 3. Price, "How this factor will be evaluated"; read with Evaluation Factors for Award, General Procedures, paragraph 1.A; and Attachment 2, Statement of Objectives (NPD Work Area A and E), 24 July 2026, Award Structure, CLIN Structure table, and Cost Drivers, "GFI offset" Instructions p. 16; p. 3; SOO p. 69; p. 67 CLIN 0003 is Time-and-Materials ODC with a not-to-exceed ceiling in the base year, and actual data licensing costs will be invoiced against that ceiling. The SOO further contemplates that the ceiling may be raised by contract modification if the CMS-approved source portfolio costs more than the ceiling amount. The Instructions state that prices will be evaluated in accordance with FAR 15.404-1 to ensure they are fair and reasonable, but do not describe a total evaluated price calculation or a method of price comparison among offerors. (a) Will the Government confirm whether and how CLIN 0003 enters into the comparison of prices among offerors, and by what method: at each offeror's proposed not-to-exceed ceiling amount, at a common Government-established plug amount applied uniformly to all offerors, or otherwise? (b) Will the proposed base-year ceiling amount itself be evaluated for price realism? (c) Offerors respectfully request that the Government consider establishing a common plug amount for CLIN 0003 for evaluation purposes. There is at present no established market for provider data licensed on terms permitting free public redistribution as NPD output. The required datasets in Table 1 are held by organizations whose existing commercial models are premised on restricted redistribution, and this Statement of Objectives was issued on 24 July 2026, affording offerors limited opportunity to obtain pricing on redistribution-compatible terms. If price comparison is made at each offeror's proposed ceiling, the offeror that most underestimates this novel and unformed market is advantaged on price, with no evaluated consequence, because the SOO expressly provides for the ceiling to be raised by modification after award. A common plug amount would place all offerors on an identical basis, direct the price competition to the CLIN 0001 and CLIN 0002 services the Government is actually acquiring, and preserve the integrity of the Government's own price evaluation.
| Because the Instructions to Offerors provide that the solicitation controls in the event of any conflict with a CMS answer, offerors respectfully request that any affirmative response to this question be effected by amendment to the solicitation rather than by answer alone. | As stated in the solicitation, Prices will be evaluated in accordance with RFO FAR 15.404-1 to ensure they are fair and reasonable. | |
| 52 | Attachment 2, Statement of Objectives (NPD Work Area A and E), 24 July 2026 |
Anticipated Data Sources and Service Providers, Table 3, Known Government-Furnished Information; read with Pricing and Award Structure, Cost Drivers, "GFI offset," and Award Structure, CLIN Structure table
| p. 30; p. 67; p. 69 | Table 3 states that WA A is procuring redistribution rights for public NPD output rather than duplicating APS data, which distinguishes the Government's existing coverage of a dataset from the redistribution rights required for NPD public output. The Cost Drivers section separately states that CMS will not obligate funding for datasets where GFI coverage is determined to be sufficient for NPD purposes. Offerors request clarification of the test the Government will apply: (a) Will a GFI determination be based on the Government's coverage of the underlying data, on whether the Government's existing rights in that data permit public redistribution as NPD output, or on both? (b) Where a GFI source provides substantial record coverage but the Government's existing rights do not permit public redistribution, will the Government confirm that a WA A license remains necessary and fundable for that dataset? (c) For pricing purposes, is the anticipated GFI offset intended to be shown as a separately identified reduction to the proposed CLIN 0003 amount for each affected source, or netted into the proposed amount? (d) Where a GFI determination removes a required dataset from CLIN 0003, will the Firm Fixed Price for CLIN 0001 be adjusted to reflect the reduced portfolio management scope? | (a) A GFI determination requires both that CMS holds the underlying data and that CMS's existing rights permit public redistribution as NPD output — both conditions must be satisfied. (b) Yes — where a GFI source provides coverage but CMS's existing rights do not permit public redistribution, a WA A license remains necessary and fundable. (c) The anticipated GFI offset should be shown as a separately identified reduction to the proposed CLIN 0003 amount per affected source, not netted. (d) Where a GFI determination removes a required dataset from CLIN 0003, the CLIN 0001 FFP will be adjusted through the annual level-set process. |
| 53 | Attachment 2, Statement of Objectives (NPD Work Area A and E), 24 July 2026 |
Anticipated Data Sources and Service Providers, Table 3, Known Government-Furnished Information; read with Definitions, Government-Furnished Information (GFI), and Pricing and Award Structure, Cost Drivers, "GFI offset"
p. 30; p. 14; p. 67 Table 3 states that the contractor is responsible for identifying additional GFI sources through the pre-award data inventory process, and that the GFI list is not exhaustive.
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