Questions and Answer - Solicitation 75H71023R00004.pdf

QUESTIONS AND ANSWERS

TELERADIOLOGY READ SERVICE ‐ NAVAJO AREA INDIAN HEALTH SERVICE

SOLICITATION NO.: 75H71023R00004

1) Ques on: Do any of the facili es have Emergent studies? If so, which facili es?

Answer: All facili es have Stat, Urgent and Rou ne exams that they will send for interpreta on.

2) Ques on: Do any of the facili es have Overnight Emergent studies? If so, which facili es?

Answer: Yes, all facili es have overnight Stat exams

3) Ques on: Will the facili es require specific holiday coverage? If so, please list the holidays and the Coverage hours needed during these holidays.

Answer: All federal holiday as well as nights, and weekends for all facili es 2024 Holiday Schedule Monday, January 01 New Year’s Day Monday, January 15 Birthday of Mar n Luther King, Jr.

Monday, February 19 * Washington’s Birthday Monday, May 27 Memorial Day Wednesday, June 19 Juneteenth Na onal Independence Day Thursday, July 04 Independence Day Monday, September 02 Labor Day Monday, October 14 Columbus Day Monday, November 11 Veterans Day Thursday, November 28 Thanksgiving Day Wednesday, December 25 Christmas Day

4) Ques on: How will the NAIHS facili es submit DICOM images to the Teleradiology group? By VPN, by Gateway or Other?

Answer: We use a dedicated VPN to transfer dicom images, as well as HL7 messaging for reports to be transferred back to each facili es HIS/RIS system.

5) Ques on: Cross‐State Licensure clarifica on ques on — Page 12 of the solicita on pdf [Sec on 4.4 B.] says

“Possess an unrestricted license to prac ce medicine in the state where they will be providing professional services (the state where contractors’ radiologist will be located while interpre ng and repor ng exams). The states services to be provided are in the state of New Mexico and Arizona.” However, it's our understanding that in general, to prac ce with telehealth across state lines, physicians must have a valid state license in the state, in every state they have pa ent contact. The origina ng site or the loca on of the pa ent, is also known as the place of service. Thus, the physician must adhere to the rules and regula ons of the pa ent’s loca on. These laws and regula ons around licensing are typically enforced by the state medical board. Addi onally, our Teleradiology partner (located in Texas) stated that "we historically have only read studies that were generated in Texas due to compliance issues. And we do not carry NM or AZ licenses for our physicians". The ACR (American College of Radiology) states on their Teleradiology website that "the current policy of the ACR is to require those physicians interpre ng images in other states be licensed in both the state where the image was generated as well as the state where the interpreta on takes place". We are also aware that there are cross state efforts for teleradiology licensure such as the Interstate Medical Licensure Compact (h ps://www.imlcc.org/) in alignment with the HHS website (h ps://telehealth.hhs.gov/licensure/licensing‐across‐state‐lines), however there are limita ons and they are state‐by‐state dependent. We may be unaware, could the government please elaborate on whether there is an excep on that bypasses the state‐by‐state licensure requirements for the NAIHS facili es? Perhaps because it's a Federal solicita on? Or is there a specific law or website link that we can reference to give offerors addi onal clarity?

Answer: I do not know of a specific site. However, each radiologist must have a license to prac ce in a state.

Federal government facili es require an ac ve and in good standing license. They will also be subject to each facility's creden aling protocols, which are very similar. We follow the ACR and Joint Commission requirements for physicians. You should look at the Joint Commission requirements as well as the ACR requirement for physicians.

6) Ques on: Is there an incumbent? And is there a previous contract award #?

Answer: There have been past awards for teleradiology services made to Inrad LLC, Contract number 75H71020D00001.

7) Ques on: Might the government happen to have/be able to provide a list of imaging CPT’s by Time of Day and by Day of Week? Per month, for the last 24 months? In this format below (see screenshot below). Our radiology group requests: The last 24 months worth of CPTs with volume counts by Month, Day of Week, and Time of Day.

The me of day is essen al for us to consider how we would staff our group to cover this kind of work.

Answer: An es mated volume for each facility is included in the solicita on. We provide services for X‐ray, Mammography, CT, MRI, Ultrasound, Dexa, but these do very from facility to facility. Please review the es mated volumes that have been provided in the solicita on.

8) Ques on: Do all the hospitals have the same PACs system?

Answer: Most use Vista Rad for PACS but I am not sure if they all do or not. We all have the same HL7 messaging with RPMS though.

9) Ques on: Do you have a dicta on so ware in place?

Answer: Yes, some do and some do not, PowerScribe is what most use.

10) Ques on: Sec on B‐2 Fee Schedule (page 4):

Could you clarify how many, if any, of the Ultrasound volumes listed on line 5 of the table would be mammography ultrasounds? What other types of ultrasounds are needed? Please provide a breakdown.

Answer: We have all types of ultrasounds, from Rou ne exams to STAT exams. I know that a couple of facili es do mammography ultrasounds but not sure of the exact amount. These would possibly include, breast biopsy images, or follow‐up exams to a finding on mammography.

11) Ques on: Sec on 4.2.H.b (page 10):

We propose modifying the current thirty‐minute upper limit for STAT/Urgent interpreta ons to a target of thirty minutes with an upwards limit of sixty minutes. This change would be er accommodate high‐volume periods and reflect achievable opera onal capabili es, thus ensuring reliability and fostering transparent expecta ons.

Answer: We will not be modifying the current thirty‐minute me for STAT/Urgent interpreta ons. This is an ongoing requirement for all facili es for teleradiology services.

12) Ques on: Sec on 4.4.C (page 12):

For clarifica on, is formal accredita on by TJC or CMS a mandatory requirement, or is compliance with TJC/CMS standards sufficient?

Answer: Formal accredita on for TJC or CMS allows for our facili es to do creden aling of providers in a simpler way. However, compliance with the standards is a must and you will be held to the standards of the IHS creden aling of providers by each facility.

13) Ques on: If this requirement removal is not feasible, would it be permissible that a subcontractor that is accredited by the Joint Commission creden al the radiologist submi ed for the teleradiology roster?

Answer: Regardless of how you creden al your radiologists, you will s ll be held to the compliance standards of Joint Commission as well as IHS standards for creden aling.

14) Ques on: We provide services at numerous facili es and we have not been required to have Joint Commission accredita on. Our opera ons meet and o en exceed these requirements. We have found that no agencies have relied on the teleradiology provider Joint Commission accredita on. We are able to provide full creden aling packages for each radiologist and have an in‐house creden aling team for this purpose.

Answer: Again, you will s ll be held to the compliance standards of Joint Commission as well as IHS standards for creden aling.

15) Ques on: This would likely also increase the par cipa on of capable small businesses, s mulate compe on, and poten ally lead to more cost‐effec ve offerings for the Government while maintaining high service standards.

Cybersecurity Requirement Recommenda on Ques on: We would like to emphasize the value of more stringent cybersecurity requirements. We recommend specifying the need for cloud service providers to operate in a FedRAMP accredited environment and comply with, at a minimum, NIST 800‐171 and SP 800‐18 to safeguard against poten al cyber threats and align with Government protocols.

Answer: We will have a specific VPN connec on for our facili es, FedRamp compliant cloud services my be considered, however the proper paperwork would need to be included in any proposal, as well as how these services will be safeguarded from cyber‐a acks.

16) Ques on: Page 9 of 46, says the Contractor’s Professional Liability Insurance requirement is $2 million per claim /

$6 million aggregate. Page 27 of 46 says coverage should be $1 million / $3 million aggregate. Please clarify which is correct? The industry standard is $1 million / $3 million. Using the higher requirement of $2 million / $6 million will unnecessarily increase costs to the Government.

Answer: Page 9 is incorrect. Refer to Page 26 of 46, C‐11 52.237‐7 INDEMNIFICATION AND MEDICAL LIABILITY INSURANCE (JAN 1997), which states One Million Dollars ($1,000,000) per claim and Three Million Dollars ($3,000,000) in the annual aggregate, and General Liability Insurance in an amount at least commensurate with industry standards.

17) Ques on: Page 10 of 46, given pa ent safety, the Na onal shortage of radiologists and high costs for coverage, can turn around mes be more flexible and address pa ent safety? Will IHS consider the following turn around mes or some middle ground: Rou nes = 36 hours; Stats = 60 minutes; Urgents = 4 hours. Essen ally, the current turn around me requirements make every urgent study the same as a stat which is not fair /safe to pa ents with true stat studies. Also, the rou ne turn around by noon the next day may not give sufficient me to be read by a specialist etc depending on when the study is sent to the vendor.

Answer: We will not modify the current thirty‐minute me for STAT interpreta ons. This is an ongoing requirement for all facili es for teleradiology services. Urgent and rou ne exam cases could be looked at to address available coverage op ons.

18) Ques on: Page 14 of 46, will IHS consider adding Op on Years Three and Four? There is a big upfront investment to connect systems and creden al radiologists, and typically, most teleradiology contracts have a base plus four year Op on periods. Having more op on years will mo vate more vendors to compete for this RFP.

Answer: Not at this me.

19) Ques on: Page 32 of 46 says include a minimum of 3 but no more than 5 projects of similar scope… but further down the page, it says offerors shall provide no more than 3 examples of past performance. Can the offeror submit 5 examples?

Answer: Five (5) is acceptable.

20) Ques on: Page 32 of 46, for Volumes 2 and 3, are there any page limits?

Answer: Only the PRICE PROPOSAL has page limit of two (2) pages.

21) Ques on: Page 32 of 46, would electronic submission be acceptable for proposal submission, versus mailing in hard copies?

22) Ques on: Page 32 of 46, the remit address is a PO box. May the proposal be physically handed to someone at

Chinle versus risking it being delayed via the Post office?

Answer: The address includes “Off Highway 191 & Hospital Drive”. Major couriers use this physical address to deliver to this facility.

Chinle Comprehensive Health Care Facility ATTN: Tanya Begay, Supervisory Contract Specialist Solicita on No.: 75H71023R00004 Off Highway 191 & Hospital Drive P.O. Drawer PH Chinle, AZ 86503

23) Ques on: Will the government accept electronic proposal submissions or is the expecta on mailed hard copies?

Answer: No, the Government will not accept electronic proposal submissions.

Reference INSTRUCTIONS FOR PROPOSAL SUBMISSION

a. Sub‐paragraph (b) All offers must include the following informa on and submi ed to the following office at or before the exact me specified in this solicita on. Remit to Address

24) Ques on: Is Subcontrac ng allowed under this solicita on?

25) Ques on: Can the subcontractors past performance be used for proposal?

26) Ques on: Will the government consider allowing specific provider informa on a er the award? We have found

Radiologist to be cau ous of allowing their name, phone, and email addresses to be in a proposal. Would the government accept CV highlights and cer fica on with personal informa on redacted un l post award?

Answer: I do not advise offerors on the how to submit their proposals.

a. Reference Volume 3 – Label “TECHNICAL PROPOSAL.”: Provide evidence that radiologists meet the qualifica ons described in sec on tled Professional Qualifica ons in the Performance Work Statement

(PWS).

27) Ques on: Based on the image es mates listed on the table in the Fee Schedule will the government accept pricing for the reads based on the three urgency levels of Rou ne, Stroke, and Urgent or Stat?

Answer: Offerors shall use the pricing schedule as shown in the solicita on.

a. Reference FEE SCHEDULE: The facili es stated in Sec on B‐1 may submit imaging examina ons of varying numbers, types, severity, urgency, and days and hours of transmission for interpreta on under the terms of the contract.

b. The following are the required melines for the reports sent as “Rou ne”, “Urgent”, “Stroke” and/or “Stat”

Rou ne: Interpreta on should be available at the referring facility by noon the following day.

Stroke: Interpreta ons should be available at the referring facility within twenty (20) minutes.

Urgent or Stat: Interpreta ons should be transmi ed to the referring facility within thirty (30) minutes… Cri cal findings: Should be called within one (1) hour to the referring facility’s NAIHS clinicians.

28) Ques on: Can the government provide an expected percentage of cases based on urgency using the FEE Schedule

Sec on B‐1 as a reference?

Answer: An es mated volume for each facility is included in the solicita on. We provide services for X‐ray, Mammography, CT, MRI, Ultrasound, Dexa, but these do very from facility to facility. Please review the es mated volumes that have been provided in the solicita on.