Attachment 2 RFI 2 Questions.pdf

RFI – Information Sought: CCRG Code Sets (RFI 2) The U.S. Department of Veterans Affairs (VA) is conducting market research to obtain meaningful, actionable industry feedback on the draft Performance Work Statement (PWS) for Community Care Referral Guidelines (CCRG) Code Set Development and Maintenance. RFI 2 builds on RFI 1 by seeking evaluation of VA’s proposed approach in the draft PWS and by gathering updated market information on capabilities, quality, governance, update cadence, staffing, and pricing structures. Where possible, please cite or reference the applicable PWS section number/title in your response.

Instructions: Please provide narrative responses that explain the basis for your answer, identify assumptions and risks, and offer recommendations. Avoid simple yes/no answers where possible.

Indicate page and paragraph numbers for any recommended PWS changes or clarifications.

A – GENERAL INFORMATION

A1. Organization Name and the year the company was established/founded (include any previous names used).

A2. Company ownership (public, private, joint venture) and socio-economic designation(s), if applicable.

A3. Identify contract vehicles, SINs/Pools, and NAICS codes your organization believes are most applicable to this requirement.

A4. Describe any compliance certifications or data-handling accreditations relevant to healthcare coding and federal data stewardship (e.g., HIPAA, FedRAMP environments used for file exchange). Reference how these support the PWS §8 Data Handling and Security.

B – CAPABILITY AND EXPERIENCE INFORMATION

B1. Describe past experience (prime/sub; years) and current capability to develop and maintain comprehensive healthcare billing code sets (CPT, HCPCS, ICD‑10‑CM/PCS). Include similar work performed for federal agencies or large healthcare systems.

B2. List the coding tools, databases, and authoritative sources you use to maintain current, accurate code sets. Explain how source monitoring aligns with PWS §4.3.1 (Update Cadence and Release Management).

B3. Provide relevant case studies/work examples demonstrating code-set creation, validation, and maintenance at scale. Summarize quality results, update cadence, and stakeholder validation outcomes.

B4. Based on the anticipated CCRG inventory (~373 active CCRGs; PWS §4.2.3), describe your capacity and ramp plan to support initial production and steady-state maintenance. Include surge options and constraints.

C – CODE SET DEVELOPMENT APPROACH

C1. Evaluate the mapping methodology proposed in PWS §4.2.1. Identify gaps, risks, or process improvements to ensure complete and reproducible mapping from CCRG clinical scope to billable codes and linked rule metadata.

C2. PWS §4.2.1 (Structured Layer Separation) proposes distinct, linked information categories (code-set assignment, authorization conditions, claim-context attributes, payment/edit/grouper metadata, source evidence, etc.). Recommend refinements or additional layers needed to support adjudication accuracy and maintainability.

C3. Assess the minimum record-level metadata fields in PWS §4.2.1. Identify any fields that should be added, clarified, or made optional, and explain how these changes would improve traceability and version control.

C4. Describe your approach to gap/overlap analysis across specialties and code families, and to predecessor/successor tracking. Propose metrics and controls to minimize omissions and inappropriate inclusions (refer to PWS §4.2.1 Review and Reconciliation).

C5. Explain your methodology for incorporating new, revised, or retired codes into routine updates and urgent/off-cycle releases, including evidence tracking and change-log documentation

(PWS §4.3.2).

C6. If using automation/AI/ML/NLP, describe the tool(s), validation methods, human-review checkpoints, limitations, and how generated results are distinguished from human-approved outcomes, consistent with PWS §4.2.1 (Use of Automation).

D – DELIVERABLES, FORMATS, AND UPDATE CADENCE

D1. Evaluate the quarterly baseline release approach and rolling 120-day calendar in PWS §4.3.1.

Recommend the optimal cadence (monthly/quarterly/other), and identify conditions that warrant off-cycle releases.

D2. Comment on the requirement to submit both complete replacement files and delta files (PWS §4.3.1/D3). Propose file formats, schema conventions, and validation checks that would enhance accuracy and ingestion.

D3. Provide recommended advance delivery windows and review periods to meet TPA implementation needs while preserving VA validation, correction, and contingency timelines (see PWS §4.3.1 Backward-Planned Release Schedule).

D4. Describe your standard delivery package (machine-readable files; review workbook;

manifests; traceability; QA/test evidence). Identify opportunities to streamline VA validation

(PWS D2A/D2B/D3).

E – QUALITY ASSURANCE AND VALIDATION

E1. Assess the internal QA scope in PWS §4.4.1 (schema/field validation; source/version validation; code/rule validation; traceability/documentation). Recommend additional checks, automation, or independence requirements.

E2. Propose adjudication-scenario and regression-testing strategies necessary to validate allowed/conditional/excluded services, modifier/place-of-service/provider-type conditions, and date-boundaries (PWS §4.4.1).

E3. Recommend acceptance criteria, defect severity definitions, and release-readiness certifications that best balance speed and quality (PWS §4.4.1).

F – SCALABILITY AND VOLUME MANAGEMENT

F1. Describe your approach to scaling code-set development across numerous specialties and high-volume families while maintaining consistency across CCRGs. Include parallelization, batching, and alignment to VA review capacity.

F2. Explain your ability to deliver accelerated/urgent updates when source effective dates or VA policy decisions require compressed timelines (PWS §4.3.1 Urgent or Off-Cycle Releases).

F3. Identify key risks to scale (licensing/access, source lag, review capacity, staffing continuity) and propose mitigation strategies.

G – TOOLS, TECHNICAL INTEGRATION, AND INTEROPERABILITY

G1. Describe platforms and repositories that support code creation, maintenance, version control, and historical reproducibility (PWS §4.3.2).

G2. Identify delivery mechanisms you support (e.g., API, SFTP, structured files). Provide recommendations for schema and naming/versioning conventions that facilitate VA ingestion and TPA implementation.

G3. Discuss optional HL7 FHIR R4 representations (e.g., ValueSet/ConceptMap) and any constraints or benefits to VA/TPA interoperability (see PWS deliverable format notes).

H – STAFFING AND EXPERTISE

H1. Describe qualifications/certifications of the personnel who will perform clinical validation, coding/classification, reimbursement/payment-policy review, quality assurance, and program management (PWS §6.1).

H2. Propose a staffing model (FTEs and skill mix) for initial development and steady-state maintenance, addressing surge capacity and continuity of operations (PWS §6.1–§6.3).

H3. Explain how you will ensure continuity, backup coverage, and knowledge management to prevent disruption to deliverable schedules (PWS §6.3).

I – CONTRACTOR–VA INTERACTION AND GOVERNANCE

I1. Identify the Government-Furnished Information (GFI) and decisions you need from VA to begin and sustain production; recommend ways to streamline provision and review per PWS §5.

I2. Comment on the governance artifacts (calendars, decision/risk/issue logs, discrepancy log) and meeting cadence in PWS §4.5. Recommend adjustments to strengthen oversight while avoiding undue burden.

I3. What division of responsibilities between VA and the contractor do you recommend for optimal performance? Suggest criteria for escalating conflicting reviewer comments for consolidated VA direction (PWS §4.5).

J – RISKS, CHALLENGES, AND RECOMMENDATIONS

J1. Identify requirements in the draft PWS that may present technical, operational, staffing, schedule, licensing, interoperability, or implementation risks. Explain each risk, its cause, and recommend mitigations or alternative approaches.

J2. Provide recommendations to improve competition, feasibility, performance, and outcomes (e.g., scope clarity, acceptance criteria, release timing, schema simplification).

J3. Describe assumptions and dependencies that VA should address to reduce schedule risk (e.g., source access/licensing, CCRG revision timing, TPA implementation windows).

K – COST AND PRICING STRUCTURE

K1. Describe a recommended pricing structure, including base price and pricing units (e.g., per specialty, per CCRG category of care, per deliverable/release, per record). Explain how pricing scales with deliverables in the PWS and with urgent/off-cycle releases.

K2. Provide estimated costs for developing, validating, and maintaining VA Code Sets mapped to CCRGs. Identify key cost drivers (number of CCRGs/categories, update frequency, complexity, licensing, level of customization).

K3. Identify pricing options for surge/accelerated releases, benchmarking/analytic support when separately ordered (PWS D2C), and for expanded schema or testing requirements if adopted.

L – ADDITIONAL TOPICS FOR FEEDBACK

L1. Code set lifecycle: Provide a high‑level code‑set lifecycle tailored to CCRGs (intake, decomposition, mapping, QA, validation, release, archive, annual review) aligned to PWS §§4.2– 4.4.

L2. Data retention and deletion: Describe your data retention and destruction policies and how they align with federal records management and VA requirements (PWS §8; delivery archives in §4.3.2).

L3. Implementation timelines: From award, estimate business days to be fully operational for pilot development and first production code-set delivery, considering PWS §4.1.1–§4.1.3.

L4. Adjustment timeline: Estimate time to complete the adjustment of industry-standard code sets to VA CCRG categories of care for a typical specialty. Identify complexity drivers and any prerequisites needed from VA.

L5. PWS clarity and revisions: List recommended changes/additions/clarifications to the draft PWS; please cite page and paragraph. Explain the rationale and impacts.

L6. Commercial/industry-leading solutions: Identify commercial or industry-leading tools/practices VA should consider adopting or piloting that are not currently reflected in the draft

PWS.

L7. Scope considerations: Identify any areas where the PWS may be unnecessarily restrictive or where additional detail would clarify scope, acceptance, or downstream use.

Note: Respondents should not include proprietary code descriptions unless permitted by licensing and downstream-use rights. Recommendations are advisory and do not independently establish or modify VA coverage, authorization, utilization limits, or payment policy.