Tab 12 Complete 75H71026Q00276 Amendment 1 Description of Changes Continuation Pages.pdf

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Attached to
Multiple-award Blanket Purchase Agreements (BPAs) for Area-wide Information Health Management (IHS) Medical Coding Services
Solicitation number
75H71026Q00276
Issued by

About this file

This document is Amendment 1 to a Request for Quote for multiple-award Blanket Purchase Agreements (BPAs) for medical coding and data entry services at the Navajo Area Indian Health Service (NAIHS).

The solicitation (75H71026Q00276) is a 100% Indian-owned Small Business Economic Enterprise (ISBEE) set-aside for remote outpatient and inpatient medical coding and data entry services supporting five NAIHS Service Units (Chinle, Crownpoint, Gallup, Kayenta, and Shiprock) across Arizona, New Mexico, and Utah. Services are priced on a firm-fixed per-encounter basis by encounter type, with the inpatient rate applying uniformly regardless of patient length of stay or record size. The contract includes a one-year initial BPA period with up to four optional annual renewal periods, for a potential five-year total. Services are ordered on an as-needed basis through individual call orders with no guaranteed minimum volume. All work must be performed remotely within the United States using secure Government-authorized access to RPMS, IHS EHR, PCC, and SDTS systems. Amendment 1 extended the quote deadline to September 24, 2026 at 2:00 PM MDT, incorporated a revised Performance Work Statement (PWS No. NAIHS-HIM-26-01, Rev. 1), and added CCS as an acceptable inpatient coding credential alongside CIC and CPC-H. Key personnel requirements include current AHIMA or AAPC certifications, minimum two years of relevant coding experience, completed HSPD-12 security clearance, and fluency in English. The Government established a 95% coding accuracy Acceptable Quality Level for both outpatient and inpatient work, with performance measured through random audits. Contractors must maintain a Quality Control Plan, submit weekly deficiency reports and monthly performance reports, and ensure all coding personnel and systems access remain U.S.-based due to Government information system restrictions.

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(x)

75H71026Q00276 x x

1 copies of the amendment; (b) By acknowledging receipt of this amendment on each copy of the offer submitted ; or (c) By separate letter or electronic communication which includes a reference to the solicitation and amendment numbers. FAILURE OF YOUR ACKNOWLEDGEMENT TO BE

RECEIVED AT THE PLACE DESIGNATED FOR THE RECEIPT OF OFFERS PRIOR TO THE HOUR AND DATE SPECIFIED MAY RESULT IN REJECTION OF YOUR

OFFER. If by virtue of this amendment you desire to change an offer already submitted , such change may be made by letter or electronic communication, provided each letter or electronic communication makes reference to the solicitation and this amendment, and is received prior to the opening hour and date specified.

x

Window Rock AZ 86515 PO Box 9020 Navajo Area Office

08/31/20260001

13. THIS ITEM ONLY APPLIES TO MODIFICATION OF CONTRACTS/ORDERS. IT MODIFIES THE CONTRACT/ORDER NO. AS DESCRIBED IN ITEM 14.

12. ACCOUNTING AND APPROPRIATION DATA (If required) is not extended.is extended, Items 8 and 15, and returning

Offers must acknowledge receipt of this amendment prior to the hour and date specified in the solicitation or as amended , by one of the following methods: (a) By completing

The above numbered solicitation is amended as set forth in Item 14. The hour and date specified for receipt of Offers

11. THIS ITEM ONLY APPLIES TO AMENDMENTS OF SOLICITATIONS

FACILITY CODE CODE

10B. DATED (SEE ITEM 13)

10A. MODIFICATION OF CONTRACT/ORDER NO.

9B. DATED (SEE ITEM 11)

9A. AMENDMENT OF SOLICITATION NO.

CODE

8. NAME AND ADDRESS OF CONTRACTOR (No., street, county, State and ZIP Code)

7. ADMINISTERED BY (If other than Item 6)CODE 6. ISSUED BY

PAGE OF PAGES

4. REQUISITION/PURCHASE REQ. NO.3. EFFECTIVE DATE2. AMENDMENT/MODIFICATION NO. 5. PROJECT NO. (If applicable)

1. CONTRACT ID CODE

AMENDMENT OF SOLICITATION/MODIFICATION OF CONTRACT

08/31/2026

CHECK ONE A. THIS CHANGE ORDER IS ISSUED PURSUANT TO: (Specify authority) THE CHANGES SET FORTH IN ITEM 14 ARE MADE IN THE CONTRACT

B. THE ABOVE NUMBERED CONTRACT/ORDER IS MODIFIED TO REFLECT THE ADMINISTRATIVE CHANGES (such as changes in paying office, C. THIS SUPPLEMENTAL AGREEMENT IS ENTERED INTO PURSUANT TO AUTHORITY OF:

D. OTHER (Specify type of modification and authority) appropriation data, etc.) SET FORTH IN ITEM 14, PURSUANT TO THE AUTHORITY OF FAR 43.103(b).

E. IMPORTANT: Contractor is not is required to sign this document and return __________________ copies to the issuing office.

ORDER NO. IN ITEM 10A.

14. DESCRIPTION OF AMENDMENT/MODIFICATION (Organized by UCF section headings, including solicitation/contract subject matter where feasible.)

This is 100% Indian-owned, Small Business, Economic Enterprise (ISBEE) set aside.

The subject solicitation is hereby amended to reflect the following changes:

1. Answer Offeror questions received in response to the solicitation;

2. Incorporate a revised Performance Work Statement (PWS No. NAIHS-HIM-26-01, Rev. 1);

3. Revise Provisions 52.212-1 (Instructions to Offerors) and 52.212-2 (Evaluation) in their entirety to reflect the changes described below;

4. Extend the date and time for receipt of quotes to September 24, 2026 at 2:00 PM MDT.

Extended description of changes are in the continuation page(s).

Continued ...

16A. NAME AND TITLE OF CONTRACTING OFFICER (Type or print)15A. NAME AND TITLE OF SIGNER (Type or print)

15C. DATE SIGNED 16B. UNITED STATES OF AMERICA 15B. CONTRACTOR/OFFEROR 16C. DATE SIGNED

(Signature of person authorized to sign) (Signature of Contracting Officer)

MICHELLE A. JAMES

STANDARD FORM 30 (REV. 11/2016)

Prescribed by GSA FAR (48 CFR) 53.243

Previous edition unusable

Except as provided herein, all terms and conditions of the document referenced in Item 9 A or 10A, as heretofore changed, remains unchanged and in full force and effect .

ITEM NO. SUPPLIES/SERVICES QUANTITY UNIT UNIT PRICE AMOUNT

NAME OF OFFEROR OR CONTRACTOR

2 2

CONTINUATION SHEET

REFERENCE NO. OF DOCUMENT BEING CONTINUED PAGE OF

(A) (B) (C) (D) (E) (F)

75H71026Q00276/0001

All other terms and conditions of the solicitation remain unchanged and in full force and effect.

Period of Performance: 11/01/2026 to 10/31/2031

NSN 7540-01-152-8067 OPTIONAL FORM 336 (4-86)

Sponsored by GSA

FAR (48 CFR) 53.110

AMENDMENT 1, DESCRIPTION OF CHANGES CONTINUATION PAGES

1. Questions and Answers. Attachment E, Questions and Answers, is hereby added to and incorporated into the solicitation.

2. Revised Performance Work Statement. Attachment A, Performance Work Statement, is deleted in its entirety and replaced with PWS No. NAIHS-HIM-26-01, Rev. 1, attached hereto. The revised PWS incorporates the following changes:

a. Section 5.1 (Certification Requirements) is revised to add the Certified Coding Specialist (CCS) credential as an acceptable inpatient coding credential, in addition to CIC and CPC-H.

b. Section 6.4 is revised to add new Section 6.4.1 (Location of Performance), prohibiting off-shore or overseas performance of coding and data entry services under this contract.

c. Section 6.4 is revised to add new Section 6.4.2 (Contractor-Furnished Equipment), confirming the Contractor is solely responsible for all computers, equipment, software, VPN access, internet/connectivity, and other IT resources required for remote performance.

d. Sections 1.6 and 2.2 are revised to clarify that the inpatient per-encounter rate is all-inclusive and applies uniformly regardless of the patient's length of stay or record size.

e. Section 3.2 is revised to confirm the Contractor may establish its own internal audit sample size methodology for quality control purposes, provided the methodology demonstrates sustained achievement of the 95% coding accuracy Acceptable Quality Level (AQL) established in Section 9.0.

f. Section 5.3 is revised to clarify that onboarding timelines will vary based on the Contractor's prior completion of IHS onboarding requirements, and that new vendors without prior completed onboarding should anticipate a process that may exceed one (1) month before reaching full production.

g. Section 8.0 is revised to add a conforming cross-reference to the off-shore performance prohibition at new Section 6.4.1.

3. Provisions 52.212-1 and 52.212-2 Revised in Their Entirety. Provisions 52.212-1 (Instructions to Offerors – Commercial Products and Commercial Services) and 52.212-2 (Evaluation – Commercial Products and Commercial Services) are hereby deleted in their entirety and replaced with the revised provisions attached hereto, which incorporate the following changes:

a. 52.212-1, Volume II, Element 1 is revised to add a requirement that Quoters confirm all coding personnel and systems access will be based within the United States, consistent with the off-shore performance prohibition at PWS Section 6.4.1.

b. 52.212-1, Volume II, Element 3 is revised to add CCS to the list of acceptable inpatient credentials for sample coder resumes, consistent with PWS Section 5.1.

c. 52.212-1, Volume II, Element 4 is revised to confirm that Quoters may propose their own audit sample size methodology, and that the Government does not mandate a specific minimum audit percentage, provided the 95% AQL is sustained.

d. 52.212-1, Volume II, Element 5 is revised to add a requirement that Quoters describe their plan for providing IT equipment, software, VPN, and connectivity for remote performance, consistent with PWS Section 6.4.2.

e. 52.212-1, Volume II, Element 6 is revised to note that onboarding timelines may exceed one month for vendors without prior completed IHS onboarding, and may be expedited for vendors with prior IHS onboarding history.

f. 52.212-1, Volume III is revised to clarify that a Quoter who submits fewer than two Past Performance Questionnaires (PPQs) will be evaluated using whatever references and CPARS information are available to the Government, rather than receiving an automatic Neutral/Unknown confidence rating. Quoters may not proactively elect a Neutral/Unknown rating in lieu of submitting available references.

g. 52.212-1, Volume IV, Pricing Schedule is revised to add a note confirming the Inpatient line item is priced as a single flat rate per encounter, regardless of length of stay or record size.

h. 52.212-1, Volume IV, Section 2 (Total Evaluated Price) is deleted in its entirety, and Section 3 (Price Acknowledgment) is renumbered as Section 2. This BPA's firm-fixed, per-encounter pricing structure does not contemplate a fixed or estimable encounter volume; accordingly, Quoters are not required to calculate or submit a Total Evaluated Price, and no Government encounter volume estimate table will be issued.

i. 52.212-1(e), Debriefings is revised to replace the reference to disclosure of "the overall evaluated price" with disclosure of the Quoters' proposed per-encounter rates, consistent with the deletion of the Total Evaluated Price requirement in Volume IV.

j. 52.212-2, Factor 2 — Past Performance is revised to add the same clarification as 52.212-1, Volume III, above, regarding evaluation of Quoters who submit fewer than two PPQs.

k. 52.212-2, Factor 3 — Price is revised to remove the reference to an hourly rate breakdown. Price reasonableness will instead be assessed by direct comparison of each Quoter's proposed per-encounter rates, by coding category and year, against those of other technically acceptable Quoters.

4. Extension of Quote Due Date. The date and time for receipt of quotes specified in this solicitation is changed from September 15, 2026, 2:00 PM MDT, to September 22, 2026, 2:00 PM MDT.

5. Acknowledgment Required. Offerors must acknowledge receipt of this amendment prior to the time and date specified for receipt of quotes, by one of the methods identified in Block 8 of this SF-30, or by acknowledgment on the SF-1449/letterhead quote submitted with the quote itself. Failure to acknowledge this amendment may result in rejection of the quote.

List of Attachments Issued or Revised with This Amendment

Attachment Description Action A Performance Work Statement, PWS No. NAIHS-HIM-26-01 Replaced (Rev. 1)

— Provision 52.212-1, Instructions to Offerors Replaced (in full)

— Provision 52.212-2, Evaluation Replaced (in full)

Attachment Description Action E Questions and Answers Added

Attachments B (DOL Wage Determinations), C (Business Associate Agreement), and D (Past Performance Questionnaire) are unaffected by this amendment and remain as originally issued.

ATTACHMENT A

PERFORMANCE WORK STATEMENT (PWS), Revised per Amendment 1 to RFQ 75H71026Q00276

Navajo Area Indian Health Service (NAIHS) Health Information Management (HIM) Medical Coding and Data Entry Services

1.0 General Information

1.1 Introduction

The Indian Health Service (IHS) is an agency within the United States Department of Health and Human Services responsible for providing federal health services to American Indians and Alaska Natives. The Navajo Area Indian Health Service (NAIHS) administers health centers and hospitals providing health care to approximately 201,583 members of the Navajo Nation across a reservation encompassing more than 25,516 square miles in northern Arizona, western New Mexico, and southern Utah.

NAIHS Health Information Management (HIM) programs support revenue integrity, clinical data accuracy, and regulatory compliance across all NAIHS Service Units. Accurate and timely medical coding is essential to Third Party Revenue collections under the ORAP program, compliance with federal coding standards, and accurate clinical and administrative data reporting.

This Performance Work Statement defines the requirements for remote outpatient and inpatient medical coding and limited data entry services on an as-needed basis in support of NAIHS HIM programs at all NAIHS Service Units.

1.2 Objective

The objective of this contract is to ensure timely, accurate, and compliant medical coding and data entry for ambulatory and inpatient encounters across all NAIHS Service Units. Contractor performance shall be evaluated based on quality, accuracy, timeliness, and regulatory compliance rather than level of effort.

This requirement is limited exclusively to medical coding and associated data entry services. It does not include other revenue cycle management functions such as billing, collections, or accounts receivable.

1.3 Scope of Work

The Contractor shall provide professional medical coding and related data entry services for outpatient and inpatient encounters documented in the IHS Electronic Health Record (EHR) and Resource and Patient Management System (RPMS) across all NAIHS Service Units listed in Section 1.8.

Services include analysis of clinical documentation, assignment of appropriate diagnostic and procedural codes, data entry into RPMS/PCC, and identification and resolution of documentation deficiencies.

Services may be performed by individual certified coders or teams of coders, depending on staffing shortages, workload surges, or coding backlogs at individual Service Units.

All work shall be performed remotely using Government-authorized systems and secure connections established in accordance with Section 8.0.

1.3.1 Call Order Mechanism

Services under this contract are ordered on an as-needed basis through individual call orders issued by the Contracting Officer. The Government does not guarantee any minimum volume of work. Call orders will identify the applicable Service Unit, the encounter type, the applicable coding period, and the number of encounters to be coded. The Contractor shall begin performance within the timeframe specified in each call order, which will not be fewer than five (5) business days from the date of call order issuance unless the Contractor agrees to a shorter commencement period.

The Government may place call orders with any Contractor holding a Blanket Purchase Agreement (BPA) under this requirement. Call order competition procedures are at the discretion of the Contracting Officer consistent with FAR 13.303-5.

1.4 Background

NAIHS HIM programs experience periodic coding backlogs and staffing vacancies driven by the remote and rural nature of NAIHS Service Unit locations and the ongoing national shortage of certified medical coders experienced in IHS and tribal health systems. Contract coding services supplement permanent HIM staff capacity to maintain coding currency, reduce backlog, and protect Third Party Revenue collections.

1.5 Acquisition Approach

This acquisition is organized around measurable outcomes. The Contractor's obligation is to deliver accurate, timely, and compliant coded encounters as defined in this PWS. The Government does not prescribe how the Contractor shall organize its internal coding workforce, assign work, or manage its quality control processes, provided the outcomes defined in this PWS are achieved.

1.6 Type of Contract Contemplated

Services under this contract are priced on a firm-fixed, all-inclusive per-encounter basis by encounter type, as established in the BPA pricing schedule. The per-encounter rate encompasses all costs of performance including coder labor, fringe benefits, overhead, general and administrative expenses, quality control, and profit. The inpatient per-encounter rate applies uniformly regardless of the patient's length of stay or record size; no additional payment will be made based on record complexity, length of stay, or documentation volume. No separate payment will be made for any of these cost components. Pricing terms and payment conditions are addressed in the BPA terms and conditions.

1.7 Period of Performance

Each BPA established under this solicitation shall have a period of one (1) year from the date of establishment, with up to four (4) annual renewal periods at the Government's discretion, for a total potential BPA period of five (5) years. BPA renewals are contingent upon the continuing need for services, the availability of funds, and satisfactory Contractor performance as documented through the Government's quality assurance surveillance activities.

Individual call orders may be placed at any time during the BPA period. The period of performance for each call order shall be specified in the call order.

1.8 Place of Performance

All services shall be performed remotely from the Contractor's place of business using secure Government-authorized access to RPMS and IHS EHR systems. Services are provided in support of all NAIHS Service Units, which include:

Service Unit Location Chinle Service Unit Chinle, AZ Crownpoint Service Unit Crownpoint, NM Gallup Service Unit Gallup, NM Kayenta Service Unit Kayenta, AZ Shiprock Service Unit Shiprock, NM

The applicable Service Unit will be identified in each call order.

1.9 Applicable Documents

The Contractor shall perform all work in compliance with the following:

• IHS ORAP Internal Control Policy and Revenue Operations Manual

• ICD-10-CM Official Guidelines for Coding and Reporting (current year)

• ICD-10-PCS Official Guidelines for Coding and Reporting (current year)

• CPT Editorial Panel Guidelines (current year AMA publication)

• HCPCS Level II Guidelines

• CMS Evaluation and Management Documentation Guidelines

• National Correct Coding Initiative (NCCI) Edits

• Local Coverage Determinations (LCDs) applicable to IHS facilities

• Health Insurance Portability and Accountability Act (HIPAA) of 1996

• Privacy Act of 1974

• Computer Security Act of 1987

• IHS General Directives: http://www.ihs.gov

• IHS Computer Security Directives: http://security.ihs.gov

• AHIMA Standards of Ethical Coding

• AAPC Code of Ethics

2.0 Specific Requirements/Tasks

2.1 Task 1 – Outpatient and Ambulatory Medical Coding

The Contractor shall accurately code outpatient and ambulatory encounters documented in the IHS EHR using all applicable coding conventions. The Contractor shall:

• Assign appropriate diagnosis codes using ICD-10-CM, coded to the highest level of specificity supported by clinical documentation;

• Assign appropriate procedure codes using CPT, HCPCS Level II, CDT, or DSM, as applicable to the encounter type;

• Assign Evaluation and Management (E/M) levels in accordance with current CMS E/M documentation guidelines;

• Apply modifiers correctly and in accordance with NCCI edits and applicable LCD requirements;

http://www.ihs.gov/ http://security.ihs.gov/

• Review ancillary services — including pharmacy, radiology, and laboratory — and merge into encounters when appropriate and consistent with IHS coding policy; and

• Enter all coded data into RPMS/PCC in accordance with Section 2.3.

Turnaround Standard: Outpatient and ambulatory encounters shall be coded and entered into RPMS/PCC within five (5) business days of the date the encounter is made available to the Contractor for coding.

2.2 Task 2 – Inpatient Medical Coding

The Contractor shall accurately code inpatient records in accordance with ICD-10-CM and ICD-10-PCS Official Guidelines. The Contractor shall:

• Review inpatient records for documentation completeness and accuracy prior to coding;

• Assign final diagnoses and all procedures performed using ICD-10-CM and ICD-10-PCS, coded to the highest level of specificity supported by documentation;

• Assign the appropriate Diagnosis Related Group (DRG) and apply Major Complication or

Comorbidity (MCC) and Complication or Comorbidity (CC) designations accurately; and

• Enter all coded data into RPMS/PCC in accordance with Section 2.3.

The inpatient per-encounter rate is inclusive of complete ICD-10-CM/PCS coding, DRG assignment, and MCC/CC application regardless of length of stay or record size, consistent with Section 1.6.

Turnaround Standard: Inpatient records shall be coded and entered within thirty (30) calendar days of the date of patient discharge, or within thirty (30) calendar days of the date the record is made available to the Contractor, whichever is later.

2.3 Task 3 – Data Entry Services

The Contractor shall enter all encounter data into the RPMS Patient Care Component (PCC) accurately and completely, including:

• All diagnosis and procedure codes assigned under Tasks 1 and 2;

• Visit-specific data elements required for GPRA reporting and Promoting Interoperability indicators, when not auto-populated by the system; and

• Any additional data elements required by the applicable Service Unit's HIM program as specified in the call order.

All data entry shall be performed concurrently with coding and completed within the turnaround timeframes established in Sections 2.1 and 2.2.

2.4 Task 4 – Documentation Deficiency Management

The Contractor shall identify incomplete or insufficient clinical documentation that prevents accurate code assignment and manage deficiencies as follows:

• Notify the provider of the deficiency through RPMS/EHR or the Secure Data Transfer System (SDTS) within two (2) business days of identifying the deficiency;

• Track all open deficiencies and perform follow-up with the provider at intervals not to exceed five (5) business days per attempt;

• Escalate unresolved deficiencies to the Service Unit HIM Point of Contact after three (3) unsuccessful follow-up attempts; and

• Include deficiency status in the weekly deficiency report required by Section 4.0.

The Contractor shall charge the Government only once per completed encounter, regardless of the number of deficiency follow-up attempts required to obtain sufficient documentation for coding.

2.5 Task 5 – Reporting

The Contractor shall submit the following reports in accordance with Section 4.0:

• Weekly Deficiency Status Report — a summary of all open deficiencies by Service Unit, including the encounter identifier, provider, deficiency type, date of initial notification, number of follow-up attempts, and current status;

• Monthly Performance Report — a summary of completed encounters by Service Unit and encounter type, coding accuracy rate based on the Contractor's internal quality audit, on-time completion rate, backlog status, and any issues or risks identified during the period; and

• Ad Hoc Reports — as requested by the COR or Service Unit HIM Point of Contact with reasonable advance notice.

3.0 Contractor Quality Control

3.1 Quality Control Plan

The Contractor shall develop, implement, and maintain a Quality Control Plan (QCP) to ensure services performed under this contract meet the standards set forth in this PWS. The Contractor shall submit the QCP to the CO within 15 calendar days of BPA establishment. The Contractor shall update the QCP whenever a material change in operations, coding methodology, or quality control processes occurs, and shall submit the updated QCP to the CO within 10 calendar days of the change.

3.2 Minimum QCP Requirements

At a minimum, the QCP shall address:

• The Contractor's internal coding audit process, including audit frequency, sample size methodology, and the process for identifying and correcting coding errors. The Contractor may establish its own audit sample size methodology, provided the methodology is sufficient to demonstrate sustained achievement of the 95% coding accuracy AQL established in Section 9.0.

• The Contractor's process for monitoring coder certification currency across all personnel performing services under this contract, including the frequency of checks and the system used to track expiration dates;

• The Contractor's process for identifying and responding to a coder whose certification lapses or is subject to adverse action, including the timeline for notifying the CO and removing the affected coder from performance;

• The Contractor's approach to managing workload surges, backlogs, and multiple concurrent call orders across Service Units;

• The Contractor's internal complaint and corrective action process, including how coding errors, documentation deficiencies, and performance concerns are identified, documented, and resolved;

and

• The name, certification credentials, and contact information of the Contractor's designated quality control manager.

3.3 Government Rights

The Government will conduct its own surveillance of contract performance through the QASP maintained separately by the COR. The existence of the Contractor's QCP does not reduce or replace the Government's independent surveillance activities. The Government reserves the right to conduct coding audits of any encounters coded under this contract at any time during the period of performance.

4.0 Delivery and Deliverables

Item Deliverable Frequency / Deadline Submitted To

1 Quality Control Plan (QCP) Within 15 calendar days of BPA establishment; updated within 10 calendar days of any material change

CO

2 Point of Contact designation in writing, with alternate Prior to BPA establishment date CO

3 Coded encounter data entered into

RPMS/PCC

Within 5 business days of encounter availability (outpatient); within 30 calendar days of discharge or record availability (inpatient)

RPMS/PCC

system; COR notified

4 Weekly Deficiency Status Report Weekly; submitted by close of business each Friday

COR and Service Unit HIM POC

5 Monthly Performance Report Monthly; submitted within 5 business days of month end CO and COR

6 Ad Hoc Reports As requested by COR or Service Unit

HIM POC COR

Invoices (with BPA number, call order number, encounter type, number of encounters coded, and per-encounter rate)

Monthly; submitted electronically IPP, COR

5.0 Contractor Personnel Requirements

5.1 Certification Requirements

All personnel performing coding services under this contract shall maintain current, active certification through the American Health Information Management Association (AHIMA) and/or the American Academy of Professional Coders (AAPC) throughout the period of performance. Acceptable credentials include:

Outpatient and Ambulatory Coding: CCS, CCS-P, CPC, CPC-P, COC

Inpatient Coding: CIC, CPC-H, CCS

The Contractor shall ensure that coders are assigned to encounter types consistent with their certification.

Inpatient coding shall be performed only by personnel holding an inpatient-appropriate certification. The Contractor shall notify the CO within 24 hours of any coder whose certification lapses, is suspended, or is subject to adverse action, and shall immediately remove that coder from performance under this contract.

5.2 Experience Requirements

All personnel performing coding services under this contract shall have:

• A minimum of two (2) years of recent medical coding experience relevant to the encounter types they will code under this contract; and

• Demonstrated experience using RPMS, IHS EHR, PCC, or a comparable federal or tribal healthcare electronic health record system. Coders without prior RPMS experience shall complete Government-provided RPMS orientation before performing independent coding under this contract.

5.3 HSPD-12 Security Clearance and System Access

Each coder performing services under this contract shall complete the Homeland Security Presidential Directive 12 (HSPD-12) security clearance process, including fingerprinting and a background investigation, before being granted access to RPMS, IHS EHR, or any other Government information system. The Contractor shall:

• Initiate the HSPD-12 process for each coder sufficiently in advance of their scheduled start date to allow for clearance completion;

• Account for HSPD-12 processing timelines — which may require 14 to 30 calendar days for a complete and acceptable package — in all call order planning and staffing submissions;

• Notify the CO immediately if a coder receives an unfavorable adjudication or if information arises that may affect the outcome of a pending investigation; and

• Remove from performance any coder who receives an unfavorable adjudication and provide a replacement as needed.

At a minimum, a coder may begin work upon receipt of a favorable FBI National Criminal History Check (fingerprint check) result, provided all other pre-placement requirements of this section have been satisfied and a complete background investigation package has been submitted.

The overall onboarding timeline — including system access, training, and orientation — may vary depending on completion of required onboarding activities. Vendors who have previously completed onboarding requirements with IHS Office of Personnel and IT for another IHS site or contract may experience an expedited timeline to full training and production. New vendors without prior completed onboarding requirements should anticipate an onboarding process that may exceed one (1) month before reaching full production.

5.4 Language and Communication Requirements

All coders performing services under this contract shall read, write, speak, and understand English sufficiently to communicate effectively with providers, HIM staff, and Government personnel, and to accurately interpret clinical documentation written in English.

5.5 Privacy and Security Training

Prior to being granted access to any Government information system, each coder shall complete all IHS-required IT security and privacy training, including HIPAA and Privacy Act training. The Government will provide access to required training through Government-authorized channels. The Contractor bears responsibility for ensuring all its personnel complete required training before system access is granted.

6.0 Special Instructions

6.1 Continuity of Services

The Contractor shall maintain uninterrupted coding services throughout the period of performance for all active call orders. The Contractor's obligation to ensure continuity includes maintaining a sufficient pipeline of pre-credentialed, HSPD-12-cleared coders to absorb unplanned personnel changes without interruption to call order performance.

6.2 Point of Contact

The Contractor shall designate a point of contact with full authority to act on all matters relating to daily BPA and call order operations. This individual shall be available by telephone and email during normal business hours, Monday through Friday, excluding federal holidays. The Contractor shall designate an alternate point of contact and the circumstances under which the alternate serves as primary. Both designations shall be provided to the CO in writing before the BPA establishment date.

6.3 Non-Personal Services

This contract is a non-personal services contract. Contractor personnel shall not be subject to the supervision and control of Government personnel in the day-to-day performance of coding work. The Government does not direct how the Contractor assigns encounters to individual coders, manages internal quality reviews, or organizes its workforce. Government technical direction is limited to identifying the encounters to be coded, the applicable coding period, and the performance standards against which output will be measured.

6.4 System Access and Remote Work Requirements

The Contractor shall access Government systems only through Government-authorized secure connections and shall comply with all IHS IT security policies and procedures made available at BPA establishment. The Contractor shall not store, copy, transmit, or retain any Government data — including patient records, encounter data, or coded information — on non-Government systems or personal devices.

All work product produced under this contract is the property of the Government.

6.4.1 Location of Performance. All coding and data entry services performed under this contract shall be performed exclusively within the United States. Off-shore or overseas performance, including the use of off-shore personnel or subcontractors with access to Government systems or data, is not permitted under this contract, due to restrictions on external access to Government information systems.

6.4.2 Contractor-Furnished Equipment. The Contractor is solely responsible for providing all computers, equipment, software, VPN access, internet/connectivity, and any other IT resources required for remote performance of services under this contract. The Government will not furnish computer equipment, software, or connectivity to the Contractor or its personnel, except for authorized remote access credentials to Government systems identified in Section 7.1.

6.5 Ordering Procedures

Call orders may be placed by the Contracting Officer at any time during the BPA period. Each call order will specify the Service Unit, encounter type, coding period, estimated number of encounters, commencement date, and applicable performance period. The Contractor shall acknowledge receipt of each call order in writing within one (1) business day of issuance.

When the Government elects to obtain competition among BPA holders prior to placing a call order, each BPA holder will be provided a brief description of the requirement and an opportunity to submit a quote.

The Contracting Officer will award the call order to the BPA holder offering the best value consistent with the call order requirements.

7.0 Government Furnished Information and Systems

7.1 Systems Access

The Government will provide authorized remote access to the following systems for performance of this contract:

• Resource and Patient Management System (RPMS)

• IHS Electronic Health Record (EHR)

• Patient Care Component (PCC)

• Secure Data Transfer System (SDTS)

• Any additional systems identified in individual call orders

System access is contingent upon completion of HSPD-12 clearance and all required security and privacy training per Section 5.3 and 5.5.

7.2 Orientation and Training

The Government will provide facility-specific and system-specific orientation necessary for the Contractor to perform required services, including RPMS orientation for coders without prior RPMS experience. Training will be provided only when the subject matter is necessary to perform the coding services required under this contract. The Government is not obligated to provide training for continuing education, certification maintenance, or individual professional development.

7.3 Coding Guidelines and Policy Documents

The Government will provide access to applicable IHS HIM coding guidelines, ORAP Internal Control Policy, Revenue Operations Manual, and Service Unit-specific coding policies upon BPA establishment and as updated during the period of performance.

8.0 Security and Confidentiality

The Contractor shall protect all Personally Identifiable Information (PII) and Protected Health Information (PHI) accessed or generated under this contract in accordance with HIPAA, the Privacy Act, the Computer Security Act, and all applicable IHS IT security policies and directives.

The Contractor shall:

• Complete all required IHS IT security and privacy training before accessing any Government system;

• Access Government systems only through authorized secure connections from locations within the United States, consistent with Section 6.4.1;

• Report any actual or suspected data breach, unauthorized access, or privacy incident to the CO and COR immediately upon discovery, and in no case later than one hour after discovery;

• Not retain any Government data on non-Government devices or systems; and

• Upon completion or termination of each call order, ensure that all Government-issued access credentials are deactivated and all Government data is purged from Contractor systems within two (2) business days.

9.0 Performance Requirements Summary

The following Performance Requirements Summary (PRS) identifies each performance requirement, the performance standard, the Acceptable Quality Level (AQL), and the method of surveillance. The Government will use the PRS in conjunction with the Quality Assurance Surveillance Plan (QASP) to assess Contractor performance.

Required Service (PWS Ref.)

Performance Standard

Acceptable Quality Level

(AQL)

Method of Surveillance Remedy

Outpatient/Ambulatory Coding Accuracy (§2.1)

All outpatient and ambulatory encounters shall be coded in accordance with ICD-10-CM, CPT, HCPCS, CDT, DSM, and CMS E/M guidelines, at the highest level of specificity supported by documentation.

95% accuracy rate, measured by random coding audit.

Random audit of completed encounters by COR and/or HIM reviewer;

minimum 10% sample per call order or per month, whichever produces a larger sample.

Accuracy below 95% for two consecutive audit periods: written notice; corrective action plan required. Sustained non-performance subject to reduction in call order volume and escalation to CO for BPA action.

Inpatient Coding Accuracy (§2.2)

All inpatient records shall be coded in accordance with

ICD-10-CM/PCS

Official Guidelines, with correct DRG assignment and appropriate MCC/CC application.

95% accuracy rate, measured by random coding audit.

Random audit of completed inpatient records;

minimum 10% sample per call order or per month.

Same as outpatient coding accuracy.

Outpatient Turnaround Time (§2.1)

Outpatient and ambulatory

95% of encounters

COR review of

RPMS/PCC

On-time rate below 95% for two

Required Service (PWS Ref.)

Performance Standard

Acceptable Quality Level

(AQL)

Method of Surveillance Remedy encounters shall be coded and entered into RPMS/PCC within five (5) business days of encounter availability.

completed on time per call order period.

timestamp data and Contractor monthly performance report.

consecutive periods: written notice; corrective action plan required.

Inpatient Turnaround Time (§2.2)

Inpatient records shall be coded and entered within thirty

(30) calendar days of discharge or record availability, whichever is later.

95% of records completed on time per call order period.

COR review of

RPMS/PCC

timestamp data and Contractor monthly performance report.

Same as outpatient turnaround.

Data Completeness (§2.3)

All required data elements — including GPRA and Promoting Interoperability indicators — shall be fully and accurately entered into RPMS/PCC for each coded encounter.

95% completeness rate per audit sample.

Random file review by COR and HIM reviewer;

minimum 10% sample per call order or per month.

Completeness below 95%: written notice; corrective action plan required.

Deficiency Management (§2.4)

Provider deficiencies shall be identified and notified within two (2) business days of identification;

follow-up performed at intervals not exceeding five (5) business days;

escalation after three unsuccessful attempts.

95% of deficiencies managed in accordance with PWS timelines.

COR review of weekly deficiency status reports; periodic inspection of deficiency tracking logs.

Non-compliance:

written notice;

corrective action plan required.

Reporting (§2.5, §4.0)

Weekly deficiency status reports and monthly performance reports shall be submitted accurately and on time.

100% on-time submission;

reports address all required elements.

100% inspection of report submissions against submission deadlines and content requirements.

Late or incomplete reports: written notice. Repeated failures subject to escalation to CO for BPA action.

Coder Certification Compliance (§5.1)

100% of encounters coded under this contract shall be

Zero encounters coded by a coder with a lapsed or

100% inspection of coder certification

Any encounter coded by a coder with a lapsed

Required Service (PWS Ref.)

Performance Standard

Acceptable Quality Level

(AQL)

Method of Surveillance Remedy performed by coders holding a current, active, appropriate certification. The Contractor shall notify the CO within 24 hours of any certification lapse or adverse action.

suspended certification.

100% on-time CO notification.

records; periodic audit of active coder roster.

certification constitutes a critical performance failure requiring immediate corrective action, a reduction in the amount paid for affected encounters, and escalation to CO for BPA action.

HSPD-12 Clearance Compliance (§5.3)

100% of coders accessing Government systems shall have completed

HSPD-12

requirements before system access is granted.

Zero coders granted system access without required HSPD- 12 clearance.

100% inspection of clearance records prior to system access authorization.

Any system access granted without required clearance constitutes a critical performance failure requiring immediate access revocation and escalation to CO for BPA action.

Security and Data Protection (§8.0)

All coders shall comply with IHS IT security policies; all incidents shall be reported within one hour of discovery;

Government data shall be purged from Contractor systems within two (2) business days of call order completion.

Zero unauthorized disclosures, data breaches, or security incidents attributable to Contractor action or inaction.

100% timely incident reporting.

COR review of incident reports;

periodic inspection of system access logs; verification of data purge upon call order completion.

Privacy or security violation:

immediate removal of affected coder from system access;

escalation to CO for BPA action.

Quality Control Plan (§3.1)

QCP submitted within 15 calendar days of BPA establishment;

updated within 10 calendar days of any material change.

100% on-time QCP submission and updates.

QCP addresses all minimum requirements of §3.2.

100% inspection of QCP at submission and following each update.

Late or non-compliant QCP:

written notice.

Failure to submit within 30 calendar days of BPA establishment subject to escalation to CO for BPA action.

10.0 Glossary of Abbreviations and Acronyms

Abbreviation/Acronym Meaning AAPC American Academy of Professional Coders AHIMA American Health Information Management Association AQL Acceptable Quality Level BPA Blanket Purchase Agreement CC Complication or Comorbidity CCS Certified Coding Specialist CCS-P Certified Coding Specialist — Physician-based CDT Current Dental Terminology CIC Certified Inpatient Coder CMS Centers for Medicare and Medicaid Services CO Contracting Officer COC Certified Outpatient Coder COR Contracting Officer's Representative CPC Certified Professional Coder CPC-H Certified Professional Coder — Hospital CPC-P Certified Professional Coder — Payer CPT Current Procedural Terminology DRG Diagnosis Related Group DSM Diagnostic and Statistical Manual of Mental Disorders E/M Evaluation and Management EHR Electronic Health Record FAR Federal Acquisition Regulation GPRA Government Performance and Results Act HCPCS Healthcare Common Procedure Coding System HIM Health Information Management HIPAA Health Insurance Portability and Accountability Act HSPD-12 Homeland Security Presidential Directive 12 ICD-10-CM International Classification of Diseases, 10th Revision, Clinical Modification

ICD-10-PCS International Classification of Diseases, 10th Revision, Procedure Coding System

IHS Indian Health Service LCD Local Coverage Determination MCC Major Complication or Comorbidity NAIHS Navajo Area Indian Health Service NCCI National Correct Coding Initiative ORAP Outpatient Revenue and Accounts Policy PCC Patient Care Component PHI Protected Health Information PII Personally Identifiable Information PRS Performance Requirements Summary PWS Performance Work Statement QCP Quality Control Plan QASP Quality Assurance Surveillance Plan

Abbreviation/Acronym Meaning RPMS Resource and Patient Management System SDTS Secure Data Transfer System SU Service Unit

ATTACHMENT E

QUESTIONS AND ANSWERS

Amendment 1 to Solicitation No. 75H71026Q00276 Multiple-Award Blanket Purchase Agreements (BPAs) for Area-Wide Health Information Management (HIM) Medical Coding Services Navajo Area Indian Health Service (NAIHS)

This document is incorporated into and made a part of Solicitation No. 75H71026Q00276 by amendment.

In the event of any conflict between this document and the base solicitation, the terms of the amendment incorporating this document, and the revised Performance Work Statement (PWS) and Combined Synopsis/Solicitation issued concurrently, shall govern.

1. Off-Shore Performance

Question: Are off-shore resources permitted for this project?

Answer: No. All coding and data entry services shall be performed within the United States. Off-shore performance, including the use of off-shore personnel or subcontractors with access to Government systems or data, is not permitted, due to restrictions on external access to Government information systems.

2. Inpatient Coding Credential — CCS

Question: PWS Section 5.1 lists acceptable inpatient coding credentials as CIC and CPC-H only. The AHIMA Certified Coding Specialist (CCS) is the standard AHIMA inpatient credential and includes ICD- 10-PCS competency. Will CCS be accepted as a qualifying credential for inpatient coding under this

BPA?

Answer: Yes. CCS is an acceptable inpatient coding credential in addition to CIC and CPC-H. The PWS has been revised accordingly.

3. Past Performance Questionnaires — Fewer Than Two Submitted

Question: If a Quoter submits fewer than two Past Performance Questionnaires (PPQs), will the Government rate the Quoter on available references or default to Neutral/Unknown? May a Quoter elect Neutral/Unknown proactively?

Answer: A minimum of two PPQs is required to determine whether a Quoter can meet the scope of work requirements. A Quoter who submits fewer than two PPQs will be evaluated using whatever references and CPARS information are available to the Government, rather than receiving an automatic Neutral/Unknown rating. Quoters may not proactively elect a Neutral/Unknown rating in lieu of submitting available references, as doing so may raise questions regarding the Quoter's ability to meet the scope of work requirements.

4. Hourly Rate Breakdown

Question: The Instructions to Offerors at 52.212-1 reference an "hourly rate breakdown" in Volume IV, but the pricing schedule requests only firm-fixed per-encounter rates. Is an hourly rate breakdown required, and if so, what format is expected?

Answer: No hourly rate breakdown is required. The pricing structure for this BPA is per-encounter, not hourly. The reference to an hourly rate breakdown in the Instructions to Offerors and in the price evaluation factor has been removed by amendment; price reasonableness will be assessed by direct comparison of Quoters' proposed per-encounter rates.

5. Encounter Volume Estimate Table / Total Evaluated Price

Question: The Government's encounter volume estimate table referenced in the Volume IV pricing instructions does not appear to be included in the solicitation documents. Please provide the volume estimate table needed to calculate the Total Evaluated Price.

Answer: No encounter volume estimate table will be issued. Because this is a BPA under which call orders are placed on an as-needed basis with no guaranteed or set encounter volume, indexing proposed per-encounter rates against an estimated volume to produce a Total Evaluated Price is not a meaningful basis for evaluation. The Total Evaluated Price requirement at Volume IV, Section 2, has been removed by amendment. Price will instead be evaluated by direct comparison of each Quoter's proposed per-encounter rates, by coding category and year, against those of other technically acceptable Quoters.

6. Limitations on Subcontracting — Native American Sole Proprietors

Question: For purposes of the limitations on subcontracting clause at FAR 52.219-14, will Native American independent contractors operating as sole proprietors — with signed Indian Economic Enterprise representations and tribal enrollment documentation on file — be treated as similarly situated entities?

Answer: The "similarly situated entity" concept under 52.219-14 governs only work that the prime Contractor subcontracts to another entity — it has no bearing on work the prime Contractor performs itself. Under this ISBEE (Indian Small Business Economic Enterprise) set-aside, if the prime Contractor subcontracts any portion of the work to another ISBEE, including a Native American independent contractor operating as a sole proprietor with a signed Indian Economic Enterprise representation and tribal enrollment documentation on file, that subcontracted work is performed by a similarly situated entity and does not count against the 50% subcontracting limitation in 52.219-14(e)(1). If, however, the prime Contractor subcontracts work to an entity that is not itself an ISBEE, that subcontracted work counts against the 50% limitation, regardless of the individual subcontractor's tribal enrollment or Indian Economic Enterprise status.

7. Historical Encounter Volume Data

Question: Please provide historical encounter volumes by Service Unit and coding category, if available.

Answer: Historical volume varies by facility size and by year. Ambulatory visit categories include Outpatient, Emergency (Trauma), Day Surgery, Specialty Services (e.g., Rheumatology, Podiatry, Cardiology, Neurology), Home Care, Nursing Home, School-Based, and Community Health visits, as well as ancillary services (Pharmacy, Radiology, and Laboratory). Inpatient categories include Observation, General and Family Medicine, Pediatrics, OB/GYN, and Surgery.

Historical outpatient and inpatient visit counts by Service Unit for FY 2024–FY 2026 are provided below.

These figures reflect historical actuals and are provided for informational purposes only; they do not constitute a guarantee of future volume or an encounter estimate for price evaluation purposes.

Outpatient Visits

Service Unit FY 2024 FY 2025 FY 2026 Crownpoint 121,146 131,471 109,003 Kayenta 80,265 110,038 106,647 Chinle 349,945 330,124 291,846 Gallup (GIMC) 395,440 403,356 351,112 Shiprock (NNMC) 388,000 396,715 376,689 Total 1,334,796 1,371,704 1,235,297

Inpatient Visits

Service Unit FY 2024 FY 2025 FY 2026 Crownpoint 244 308 259 Kayenta 196 228 225 Chinle 1,815 1,424 1,168 Gallup (GIMC) 2,662 2,418 1,973 Shiprock (NNMC) 1,664 1,667 1,609 Total 6,581 6,045 5,234

8. Current Coding Backlog

Question: Please provide the current coding backlog by Service Unit and coding category, including the approximate age of the backlog.

Answer: Backlog data below is as of August 27, 2026, and may vary depending on when the data is run.

Figures do not include clinic-specific data, and are not broken out by category or age.

Service Unit Backlog (as of 8/27/2026) Crownpoint 5,064 Kayenta 975 Chinle 1,509 Gallup (GIMC) 44,832 Shiprock (NNMC) 2,370 Total 54,750

9. IT Equipment and Remote Access Responsibility

Question: Will the Government provide computers, equipment, software, VPN, internet/connectivity, or other IT resources required for remote performance? If not, please confirm these are the Contractor's responsibility.

Answer: The Contractor is responsible for all IT equipment, software, VPN, and…

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