Performance Work Statement

Gallup Indian Medical Center

Office of Information Resource Management Health Information Management

For a

Medical Coding, Auditing, and Data Entry Support Services

Table of Contents

1. General

2. Background

3. Objective

4. Scope of Work

5. Type of Contract Contemplated:

6. Period of Performance:

7. Option to Extend Services / Continuation of Performance………………………………6

8. Place of Performance:

9. Points of Contact:

10. Specific Requirements/Tasks

11. Contractor Quality Assurance

12. Audit Independence Requirements:

13. Security and Safety:

14. Evaluation Factors for Award:

15. Privacy and Indemnification and Governing Law:

Appendix A – Deliverables Schedule

Appendix B – Quality Assurance Surveillance Plan (QASP)

1. General

This Performance Work Statement (PWS) outlines the requirements for providing comprehensive medical coding, auditing, and data entry support services for the Indian Health Service (IHS). The Government anticipates awarding a Firm-Fixed-Price contract based on fixed, fully burdened hourly rates for a specified level of effort. The Government estimates 1,040 labor hours during each six (6)-month performance period.

The Government estimates a workload of up to 36,000 medical records during each six (6)-month performance period. The estimated record volume is provided for workload planning, staffing, and performance purposes and does not constitute the basis for payment. Payment shall be based on actual hours worked and accepted by the Government at the applicable contract hourly rate, not to exceed the funded amount established for the applicable contract period without prior written authorization from the Contracting Officer.

Actual encounter volume may vary. The Contractor shall maintain sufficient qualified personnel to meet the performance, accuracy, timeliness, and workload requirements established in this PWS within the authorized level of effort.

Services will support both inpatient and outpatient encounters across multiple departments, including General, Cardiology, Chest and TB, Diabetic, ENT, Family Planning, Gynecology, Home Care, Immunization, Internal Medicine, Mental Health, Obstetrics, Optometry, Orthopedic, Pediatric, Surgical, and other specialty areas. The contractor shall ensure compliance with HIPAA, the Privacy Act, and IHS IT security policies. The Government will furnish RPMS and VPN access through the GIMC IT Department, and the Health Information Management (HIM) Supervisor will assign coding queues.

2. Background

2.1. The Indian Health Service (IHS) identified a need for external medical coding support to address growing encounter backlogs and to maintain accuracy in clinical documentation and billing data. Internal operations have faced challenges due to high patient volume, limited staffing, and certification requirements that hindered timely coding completion.

These issues have affected reimbursement cycles, compliance tracking, and reporting accuracy. The implementation of this contract will enhance the consistency and timeliness of data entry, improve the quality of coding, and ensure that medical record documentation supports accurate billing and audit readiness. Reliable coding services directly influence the quality of patient care, resource management, and compliance with federal healthcare data standards, making this initiative critical to operational efficiency and service delivery within the Gallup Indian Medical Center and its associated clinics.

3. Objective

3.1. The primary objective of this contract is to obtain professional, certified medical coding and data entry services that ensure the accurate and timely processing of patient encounters within the Resource and Patient Management System (RPMS) and Electronic Health Record (EHR) environment. The contractor shall support IHS goals of improving patient access, enhancing care quality, and strengthening management operations by maintaining a minimum of 98 percent coding accuracy and achieving timeliness standards as defined in this PWS. The objective also includes strengthening internal capacity by reducing backlogs, increasing billing efficiency, and ensuring that all data is fully compliant with applicable regulations and IHS standards. Through consistent coding and auditing practices, this contract will enhance documentation accuracy, streamline third-party billing, and contribute to organizational accountability and transparency in healthcare information management.

4. Scope of Work

4.1. The Government estimates that the Contractor will be assigned up to 36,000 medical records during each six (6)-month performance period. This estimated quantity is provided for workload planning and staffing purposes and does not establish a per-record pricing or payment methodology. The Contractor shall provide medical coding, auditing, and data entry services within the authorized level of effort and shall apply ICD-10, CPT, HCPCS, and E/M codes, including applicable modifiers, in accordance with IHS and Federal requirements. Coding will be performed directly from electronic health records into the RPMS Patient Care Component (PCC), ensuring that each encounter is coded accurately and merged appropriately into the system within four business days of the encounter date. The Contractor shall complete coding within four (4) business days of assignment to the Contractor’s active coding queue for encounters that are complete and available in RPMS/EHR. The four (4) business day period shall begin on the next business day following documented assignment by the HIM Supervisor or the RPMS system timestamp reflecting queue assignment. Encounters delayed due to incomplete documentation, provider queries, Government system outages, credentialing delays, or other Government-controlled impediments shall be excluded from timeliness calculations until resolution and documented re-assignment. Reactivated encounters shall be completed within four (4) business days of documented re-assignment. The contractor will perform bimonthly audits on 10 percent of coded records to verify accuracy and compliance. Staff performing the work must hold current AAPC or AHIMA certifications, and any non-certified personnel must be directly supervised by a certified coder. The contractor must demonstrate prior experience with RPMS and EHR systems. Deliverables will include monthly coding reports submitted by the 10th business day of the following month, every two months will require audit reports submitted within fifteen days after the close of each quarter, and a final certification report thirty days after the end of the period of performance. All work must comply with the Indian Health Manual, HIPAA, and the Privacy Act. The contract requires a minimum of 98 percent coding accuracy, full compliance with security and confidentiality policies, and consistent on-time submission of deliverables.

4.2. Departments will include the following (inpatient/outpatient): General, Cardiology, Chest & TB, Diabetic, ENT, Family Planning, Gynecology, Home Care, Immunization, Internal Medicine, Mental Health, Obstetrics, Optometry, Orthopedic, Pediatric, Surgical, Well Child, Other B/, Family Practice, Emergency Medicine, Physical Therapy, Neurology, Rheumatology, Pharmacy, Alcohol & Substance, Day Surgery, PHN Clinic Visit, Medical Social Services, Nephrology, Telephone Call, Chart Review, Follow-Up Letter, Dental, Radiology, Podiatry, Ultrasound, Dietary, Computed Tomography, Mammography, Speech Pathology, Laboratory, Case Management Service, Labor & Delivery, Teen Clinic, Traditional Medicine, Observation, Telemedicine, Diabetes Education – Group, Diabetes Education – Individual, Diabetic Retinopathy, Colposcopy, Behavioral Health, Home Based Care, Tele-behavioral Health, Anticoagulation Therapy, Homeless, Anesthesiology, Pharmacy Primary Care Clinic, Infusion Clinic, and Palliative Care.

4.3. Only encounters that are documented, coded, and billable within RPMS/EHR and assigned to the Contractor’s coding queue are included in the scope of this contract.

Administrative, non-clinical, test, training, or non-billable encounter types are excluded unless explicitly authorized in writing by the Government.

The Government recognizes that complexity varies by department and service type. The Contractor shall code encounters in accordance with assigned priorities and shall not be penalized for lower throughput in higher-complexity services when overall performance standards are met, provided that the Contractor maintains sufficient staffing and productivity to meet the timeliness, accuracy, and other performance standards established in this PWS within the authorized level of effort.

4.4. Historical workload data for the preceding twelve (12) months, including encounter volumes by department and average monthly distribution, will be provided in the solicitation for pricing and staffing estimation purposes. The Government does not guarantee workload distribution by specialty but represents the data as the best available estimate. The Government may adjust monthly volume expectations proportionally in the event actual encounter volume falls below projected levels.

4.5. Offerors are responsible for proposing adequate staffing levels based on the historical data provided. The Government will not adjust pricing due to fluctuations in departmental complexity unless the total monthly volume materially deviates from projected estimates.

4.6. The historical workload data is provided for planning and pricing purposes only. The Government does not warrant the accuracy of projections beyond the data provided and assumes no liability for variations in departmental distribution or case complexity that do not materially alter the total monthly estimated volume.

5. Type of Contract Contemplated:

5.1. The Government anticipates awarding a Firm-Fixed-Price contract based on fixed, fully burdened hourly rates for a specified level of effort.

5.2. The Government estimates 1,040 labor hours for each six (6)-month performance period.

5.3. Payment shall be based on actual hours worked and accepted by the Government at the applicable contract hourly rate. The Contractor shall not exceed the authorized hours or funded amount without prior written authorization from the Contracting Officer.

5.4. The Contractor's fully burdened hourly rate shall include all labor, supervision, quality control, administrative expenses, overhead, profit, and other costs necessary to perform the requirements of this PWS, except costs expressly identified elsewhere in the contract as separately reimbursable.

6. Period of Performance:

6.1. The performance period will be six (6) months from the date of award, with an option to extend up to six (6) additional months via contract modification.

6.2. The Government's estimated workload is approximately 6,000 encounters per month.

The Contractor shall maintain sufficient staffing and productivity to process assigned complete encounters in accordance with the timeliness and accuracy standards of this PWS, subject to the authorized level of effort and availability of Government-assigned workload.

6.3. Clinic prioritization shall be based on a Government-provided written priority list updated no more than monthly, unless urgent operational needs require adjustment.

Changes in prioritization shall not alter the overall performance standards or total monthly volume requirement.

7. Option to Extend Services / Continuation of Performance

7.1. The Government may extend the term of this contract in accordance with FAR 52.217-8

(Option to Extend Services) and/or FAR 52.217-9 (Option to Extend the Term of the Contract), as incorporated in the contract.

7.2. The estimated quantity of 36,000 records is provided for workload planning purposes and does not constitute a guaranteed quantity or establish a per-record payment methodology.

7.3. Completion of the estimated workload prior to expiration of the applicable performance period shall not, by itself, authorize additional work or additional compensation.

7.4. The Contractor shall not exceed the authorized level of effort or funded amount without prior written authorization from the Contracting Officer. Any increase in authorized hours, funding, scope, or period of performance shall be accomplished by written contract modification.

8. Place of Performance:

8.1. Services shall be performed in a hybrid work environment. Contractor personnel may perform services onsite at Gallup Indian Medical Center, 516 E. Nizhoni, Gallup, New Mexico, 87301, or remotely from a contractor-managed work location, as authorized by the Government and in accordance with contract requirements.

9. Points of Contact:

9.1. Project Lead: Anne Spencer, anne.spencer@ihs.gov , 505-722-1115

9.2. Lead Coder: Vernon Francisco, Vernon.francisco@ihs.gov, 505-722-1158

9.3. Project Manager: Clarissa John, Clarissa.john@ihs.gov . 505-726-8664

9.4. COR Support and Escalation:

The COR may designate alternate points of contact, subject matter experts, or technical reviewers to assist with audit review, security incidents, and performance monitoring.

9.5. Operational issues unresolved at the COR level may be escalated to the Contracting Officer for resolution.

10. Specific Requirements/Tasks

10.1. Coding and Data Entry – (For purposes of performance measurement, a ‘complete encounter’ is defined as an encounter that contains all required clinical documentation necessary to assign final ICD-10, CPT, and HCPCS codes without the need for additional provider clarification.)

10.1.1. Tasks:

10.1.1.1. The Contractor shall code all inpatient, and outpatient encounters directly from the Electronic Health Record (EHR) into the Resource and Patient Management System (RPMS) – Patient Care Component (PCC) module.

10.1.1.2. The Contractor may submit documentation clarification requests only through a Government-approved query process and shall not directly contact providers unless explicitly authorized in writing by the HIM Supervisor.

10.1.1.3. All approved provider queries shall be documented, tracked, and retained as part of the encounter record in accordance with IHS policy.

10.1.1.4. The Contractor shall ensure that complete encounters are coded within four (4) business days of documented assignment to the Contractor's active coding queue, subject to the performance standards established in this PWS.

10.1.1.4.1. The Contractor shall code all reactivated encounters within four (4) business days of the documented re-assignment date. Delays following re-assignment shall be included in timeliness performance metrics.

10.1.1.5. The Contractor shall ensure proper data entry, merging all relevant “items” into visits as required to produce complete, accurate, and billable records.

10.1.1.6. The Contractor shall adhere to all standards and guidelines outlined in the Indian Health Manual (Part 5, Chapter 1) governing documentation, confidentiality, and coding accuracy.

10.1.1.7. All services must maintain compliance with IHS Information Security, HIPAA, and Privacy Act requirements.

10.1.1.8. Clinic prioritization shall be based on a Government-provided revenue priority list maintained by the HIM Supervisor. The Government reserves the right to adjust prioritization based on operational or billing needs, with changes communicated in writing to the Contractor.

10.1.2. Deliverables:

10.1.2.1. Monthly Coding Report showing total records coded, volumes by department, incomplete encounter counts, and turnaround times.

10.1.2.2. Frequency: Monthly

10.1.2.3. Due Date: 10th business day of the following month

10.1.2.4. Ongoing Coding Queue Updates provided through the HIM Supervisor for tracking complete and incomplete records.

10.2. Quality Assurance and Auditing

10.2.1. Tasks:

10.2.1.1. The Contractor shall conduct Bi-Monthly audits of at least ten percent (10%) of all coded records to ensure compliance, accuracy, and consistency.

For the purposes of this contract, “Bi-Monthly” audits are defined as audits conducted once every two (2) months, occurring at the end of Months 2, 4, and 6 of the periods of performance.

10.2.1.2. The Contractor shall submit Bi-Monthly audit reports that include error findings, corrective actions, and improvement recommendations.

10.2.1.3. Any identified deficiencies shall be corrected by the Contractor at no additional cost to the Government.

10.2.2. Deliverables:

10.2.2.1. Bi-monthly Audit Report summarizing sample size, audit results, deficiencies identified, and corrective actions taken.

10.2.2.2. Frequency: Bi-Monthly

10.2.2.3. Audit Correction Log documenting all rework and remediation efforts

10.3. Encounter Tracking and Resolution

10.3.1. Tasks:

10.3.1.1. The Contractor shall monitor and maintain a tracking system for incomplete encounters.

10.3.1.2. The Contractor shall perform necessary follow-up actions with appropriate points of contact until all incomplete encounters are resolved.

10.3.1.3. The Contractor shall not communicate directly with providers or clinical staff regarding documentation clarification, coding questions, or encounter completion.

10.3.1.4. All documentation clarification requests, provider queries, and follow-up actions shall be routed exclusively through the Health Information Management (HIM) Supervisor or designated HIM staff, in accordance with IHS documentation and communication protocols.

10.3.2. Deliverables:

10.3.2.1. Incomplete Encounter Tracking Log maintained on an ongoing basis and included with the Monthly Coding Report.

10.3.2.2. Frequency: Ongoing, reported monthly

10.4. Personnel Qualifications and Experience

10.4.1. Tasks:

10.4.1.1. All coding staff must possess active AAPC (American Academy of

Professional Coders) or AHIMA (American Health Information Management Association) certifications.

10.4.1.2. Any non-certified personnel shall work under the direct supervision of a certified coder.

10.4.1.3. The Contractor shall demonstrate previous experience using RPMS and EHR systems within a healthcare setting.

10.4.1.4. All coding staff will adhere to IHS background policies and have a favorable background clearance in place with the Personnel Security Department.

10.4.1.5. The Contractor shall maintain sufficient certified staffing levels to meet workload and timeliness requirements throughout the period of performance.

10.4.1.6. A ramp-up period of up to thirty (30) calendar days following contract award is authorized for onboarding, access provisioning, and workflow stabilization. Performance metrics shall apply in full following completion of the ramp-up period.

10.4.1.7. The Contractor shall maintain contingency staffing plans to ensure continuity of services in the event of staff turnover or unexpected absences.

10.4.2. Deliverables:

10.4.2.1. Staff Certification Roster listing all coding personnel, certification type, expiration dates, and supervision assignments

10.4.2.2. Frequency: At contract start and upon staff changes

10.4.2.3. Staff complete background checks prior to receiving credentials for system use.

10.5. Government-Furnished Information and Property

10.5.1. Tasks:

10.5.1.1. The Government, through the GIMC IT Department, shall provide the Contractor with RPMS and VPN access credentials necessary to perform assigned tasks. The Contractor shall not be held responsible for performance delays attributable to Government-furnished system access delays, credentialing issues, or system unavailability.

10.5.1.2. The Health Information Management (HIM) Supervisor shall provide coding queue assignments and act as the primary operational point of contact.

10.5.2. Deliverables:

10.5.2.1. Access Acknowledgment Form confirming VPN and RPMS access receipt and user compliance with security protocols.

10.5.2.2. Frequency: Prior to start of performance

10.6. Inspection and Acceptance

10.6.1. Tasks:

10.6.1.1. The Contracting Officer’s Representative (COR) shall review all monthly coding reports and Bi-Monthly audit submissions to verify compliance with contract requirements.

10.6.1.2. Government acceptance shall be based on verified accuracy and timeliness standards.

10.6.1.3. The Contractor shall correct all identified deficiencies at no cost to the Government.

10.6.1.4. Invoice approval shall be based on verification of accepted deliverables and documented performance metrics.

10.6.1.5. In cases of partial performance, the Government may approve pro-rated payment corresponding to accepted work, provided deficiencies are documented and corrective actions are underway.

10.6.2. Deliverables:

10.6.2.1. COR Review Summary and Acceptance Certification, confirming compliance with standards and deliverable acceptance.

10.6.2.2. Frequency: Monthly

11. Contractor Quality Assurance

11.1. Quality Control Plan (QCP): A documented plan outlining how the contractor will monitor daily work, perform internal audits, correct deficiencies, and meet accuracy standards.

11.2. Internal Review Process: Pre-submission checks of coded records, usually a random sample, reviewed by a certified coder or lead auditor before inclusion in the monthly delivery.

11.3. Performance Monitoring: Tracking metrics such as:

11.3.1. Coding accuracy (≥98%) Coding accuracy shall be calculated based on the percentage of encounters reviewed that are free from major coding errors, defined as errors that materially impact reimbursement, compliance, or clinical data integrity.

11.3.1.1. Examples of major coding errors include, but are not limited to: incorrect principal diagnosis, incorrect procedure code affecting reimbursement category, missing required modifier affecting payment, or incorrect E/M level materially affecting reimbursement.

11.3.2. Minor errors that do not affect reimbursement or compliance shall be tracked for quality improvement purposes but shall not independently cause failure of the accuracy standard.

11.3.3. Timeliness (98% within 4 days-new encounters)

11.3.4. Audit completion rates (10% Bi-Monthly)

11.4. Corrective Action Tracking: Repeated or systemic errors shall trigger corrective action planning, including retraining or process modification, at no additional cost to the Government. Reporting: The contractor provides Monthly Coding Reports and Bi- Monthly Audit Reports that include results of internal quality reviews and corrective actions. Repeated or systemic deficiencies may result in escalation through the graduated remedy process outlined in the QASP.

12. Audit Independence Requirements:

12.1. The Contractor’s internal audits shall utilize blind sampling, such that:

12.1.1. Coders are not aware of which encounters will be audited.

12.1.2. Audits shall be performed or reviewed by a certified coder or auditor who did not perform the original coding work.

12.1.3. The Government reserves the right to conduct independent validation audits or re-audits of Contractor-coded encounters at any time during the period of performance.

Performed under its Quality Assurance Plan.

12.1.4. Accuracy shall be calculated as: (Number of encounters reviewed with no major coding errors) divided by (Total encounters reviewed), multiplied by 100. Major coding errors are defined as errors that materially affect reimbursement, compliance, or clinical data integrity. Sampling shall be random and statistically valid using standard industry methodology.

12.1.5. The 10% audit sample shall be randomly selected using industry-standard statistical sampling methodology sufficient to produce a 95% confidence level

13. Security and Safety:

13.1. The Contractor shall ensure full compliance with all applicable federal, departmental, and Indian Health Service (IHS) regulations related to information security, data protection, and workplace safety throughout the duration of the contract.

The Contractor shall safeguard all Government-furnished information, systems, and equipment and maintain a secure environment for personnel and data.

13.2. Information Security

13.2.1. The Contractor shall comply with all HIPAA, Privacy Act, Federal Information

Security Management Act (FISMA), and IHS Information Technology Security Policies.

13.2.2. All coding and data entry work shall be performed within the United States; no data, screenshots, or patient information shall be transferred, stored, or processed outside U.S. jurisdiction.

13.2.3. Contractor personnel shall sign Confidentiality and Non-Disclosure Agreements (NDAs) prior to system access.

13.2.4. The Contractor shall ensure that all staff complete annual HIPAA and IT Security Awareness Training prior to system use and maintain training documentation for audit verification.

13.2.5. Government-furnished access credentials, including VPN and RPMS logins, shall be used only for contract performance and shall not be shared under any circumstances.

13.2.6. Any security incident or breach involving patient or system data must be reported within one (1) hour of discovery to the Contracting Officer’s Representative (COR) and GIMC Information Security Officer (ISSO), in accordance with IHS policy.

13.2.6.1. Incident Response Coordination:

13.2.6.1.1. Upon notification of a security incident, the Contractor shall coordinate response actions with the COR and GIMC Information Systems Security Officer (ISSO).

13.2.6.1.2. The Contractor shall submit a written incident report within five

(5) business days, including root cause, scope of impact, corrective actions taken, and preventive measures implemented.

13.2.6.1.3. Additional remediation actions may be required at the direction of the Government.

14. Evaluation Factors for Award:

14.1. Factors:

14.1.1. Factor 1 – Technical Approach (40%): Understanding of coding requirements, methodology, and compliance.

14.1.1.1. Technical Approach will be evaluated for understanding of RPMS coding requirements, methodology for meeting timeliness and accuracy standards, internal quality control procedures, and risk mitigation planning

14.1.2. Factor 2 – Staffing & Qualifications (25%): Certifications, experience, and capacity to meet quotas.

14.1.3. Factor 3 – Past Performance (20%): Quality, timeliness, and customer satisfaction on prior contracts.

14.2. Factor 4 – Price (15%): The Government will evaluate price for reasonableness.

The Government may perform a price realism analysis for the limited purpose of assessing performance risk.

14.3. Offerors shall submit technical, past performance, and price volumes.

14.3.1. Technical Volume: Demonstrate coding methodology, staffing plan, quality control plan, and ability to meet timeline.

14.3.2. Past Performance: Provide up to 3 relevant contracts in past 5 years.

14.3.3. Price Volume: The Offeror shall propose a fixed, fully burdened hourly rate for each applicable performance period. The proposed hourly rate shall include all costs necessary to perform the requirements of this PWS. For evaluation purposes, the Government will multiply the proposed hourly rate by the estimated 1,040 hours for each six (6)-month performance period and will evaluate the total price for the base and all option periods.

14.4. Award will be made on a best-value trade-off basis. The Government may award other than the lowest-priced offeror if a higher-rated technical proposal is determined to provide superior value. Technical factors, when combined, are significantly more important than price.

15. Privacy and Indemnification and Governing Law:

15.1. The contractor will comply with the following listed regulations:

15.1.1. - Privacy Act, 5 U.S.C. 552a - Office of Privacy and Civil Liberties | Privacy Act of 1974

15.1.2. Health Insurance Portability and Accountability Act (HIPAA) - eCFR :: 45 CFR Part 164 -- Security and Privacy

15.1.3. CFR 42 Part 2 - eCFR :: 42 CFR Part 2 -- Confidentiality of Substance Use Disorder Patient Records

15.2. Indemnification, Liability, Statute of Limitations: Any provisions in the Terms of Service (TOS) related to indemnification and filing deadlines are hereby waived and shall not apply except to the extent expressly authorized by law. Liability for any breach of the TOS as modified by this amendment, or any claim arising from the TOS as modified by this amendment, shall be determined under the Federal Tort Claims Act, or other governing federal authority. Federal statute of limitations provisions shall apply to any breach or claim.

15.3. Governing law: Any arbitration, mediation or similar dispute resolution provision in the TOS is hereby deleted. The TOS and this amendment shall be governed by and interpreted and enforced in accordance with the laws of the United States of America without reference to conflict of laws. To the extent permitted by federal law, the laws of the State of New Mexico will apply in the absence of applicable federal law.

16. 508 Compliance

16.1. This product must conform to the Revised Section 508 (https://www.access-board.gov/guidelines-and-standards/communications-and-it/about-the-ict-refresh/final-rule/text-of-the-standards-and-guidelines) and WCAG 2.1 Level AA standards as outlined below.

16.2. Solicitations for supplies and services shall require the submission of a Section 508 Product Assessment Template. The template can be found at https://www.itic.org/policy/accessibility/vpat.\

16.3. All Information and Communication Technology (ICT) deliverables under this contract (e.g., websites, applications, electronic documents, and multimedia) must comply with the Revised Section 508 Standards (36 CFR Part 1194) and the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA standards. The Contractor shall ensure accessibility of all ICT deliverables and provide conformance documentation in the form of a Voluntary Product Accessibility Template (VPAT®) / Accessibility Conformance Report (ACR), or by completing the HHS Section 508 Accessibility Checklists. The current VPAT 2.5 template includes fields for reporting conformance to

WCAG 2.1 and shall be used to document accessibility. The Contractor shall remediate any identified accessibility issues at no additional cost. The Contracting Officer will include the applicable Health and Human Services Acquisition Regulation (HHSAR) clauses 352.239-73 and 352.239-74 in the solicitation and resulting contract.

Appendix A – Deliverables Schedule

Deliverable Due Date / Frequency

Quantity / Standard Submission To

Estimated Monthly Workload

End of each month (Months 1– 6)

Approximately 6,000 Government-assigned complete encounters per month, subject to the authorized level of effort and availability of Government-assigned workload.

COR

Coding Timeliness

Ongoing

98% of complete encounters assigned to the Contractor’s active coding queue shall be coded within four (4) business days of documented assignment. The remaining encounters shall be completed as expeditiously as possible and shall not exceed six (6) business days unless delayed by Government-controlled impediments.

COR

Monthly Volume & Status Report

By 10th of each month

Total visits, complete/incomplete counts COR

Bi-Monthly Coding Audit

End of Months 2, 4 and 6

≥10% sample with findings COR

Final Deliverable End of Month 6

Final cumulative coding and performance report reflecting all Government-assigned work completed during the performance period.

COR

Incomplete Documentation Tracking

Ongoing Updated log COR

Compliance Monitoring

Ongoing 100% adherence to HIPAA/Privacy Act/IHS policies

COR

Appendix B – Quality Assurance Surveillance Plan (QASP)

Task / Service Performance Standard Method of Surveillance

Penalty Responsible Party

Medical Coding

≥98% accuracy Bi-Monthly audits (10% sample)

Contractor /

Data Entry 100% accuracy COR review of reports

Timeliness

At least 98% of complete encounters assigned to the Contractor’s active coding queue shall be coded within four (4) business days. Remaining encounters shall not exceed six (6) business days unless delayed by Government-controlled impediments

Spot checks, monthly reports

Workload

Contractor shall maintain sufficient staffing and productivity to process Government-assigned complete encounters consistent with the estimated workload of approximately 6,000 encounters per month and the timeliness standards established in this PWS, subject to the authorized level of effort and availability of Government-assigned workload.

Monthly report review

Task / Service Performance Standard Method of Surveillance

Penalty Responsible Party

Auditing 10% Bi-Monthly Review of audit reports

Govt. Audit Rights

Independent Audits Spot checks Contractor/

COR

Reporting Accurate monthly reports COR review

Invoice rejection until corrected

Contractor /

COR

Confidentiality & Compliance

100% HIPAA/Privacy Act/IHS compliance

COR

oversight

Termination for breach

Graduated Performance Remedies:

1. Performance deficiencies shall be addressed using the following graduated approach, at the discretion of the Government:

a. Written Notice of Deficiency

b. Corrective Action Plan (CAP)

c. Performance Improvement Plan (PIP)

d. Cure Notice

e. Invoice withholding, rejection, or contract termination, as appropriate

2. The Government is not required to progress sequentially through each step and may advance remedies based on severity or recurrence.

Appendix C: Glossary of Abbreviations and Acronyms

Abbreviation Full Term / Definition

AAPC American Academy of Professional Coders

AHIMA American Health Information Management Association

B/ Other/General Clinic Category (used in coding department listings)

CA Corrective Action

CFR Code of Federal Regulations

CO Contracting Officer

COR Contracting Officer’s Representative

CPT Current Procedural Terminology

E/M Evaluation and Management (codes)

EHR Electronic Health Record

ENT Ear, Nose, and Throat

FFP Firm-Fixed Price

FISMA Federal Information Security Management Act

GIMC Gallup Indian Medical Center

HIM Health Information Management

HIPAA Health Insurance Portability and Accountability Act

HS Health Service(s)

IHS Indian Health Service

IPP Invoice Processing Platform

IRB Institutional Review Board (implied in healthcare compliance context)

ISSO Information Systems Security Officer

IT Information Technology

NDAs Non-Disclosure Agreements

ODC Other Direct Costs

PCC Patient Care Component (RPMS module)

PHN Public Health Nursing

PMAP Performance Management Appraisal Program (if referenced in attachments)

PWS Performance Work Statement

QASP Quality Assurance Surveillance Plan

QCP Quality Control Plan

RPMS Resource and Patient Management System

SOW Statement of Work

TB Tuberculosis

U.S.C. United States Code

USO Utilities & Systems Operations (contextually referenced in facility oversight)

VPN Virtual Private Network