Attachment A Innovation Payment Contract SOW 9.9.21.docx

Attachment A: Statement of Work/Schedule of Deliverables

DESCRIPTION/SPECIFICATIONS/WORK STATEMENT

Innovation Payment Contractor (IPC)

I. SCOPE

The Centers for Medicare & Medicaid Services (CMS)/Center for Medicare and Medicaid Innovation (CMMI) require an Innovation Payment Contractor (IPC) to assist CMMI in making payments to eligible participants in multiple Model tests and initiatives (hereinafter referred to as “Models”). The project descriptions, payment requirements, and workload volumes for the Models are incorporated as separate tasks under Section III of this Statement of Work (SOW); all additional Models shall be incorporated through contract modifications to this SOW.

For each Model under this SOW, the IPC shall conduct the following basic financial services activities:

· Disburse Electronic Funds Transfer (EFT) or paper check payments, as required, to eligible Medicare, Non-Medicare, and Medicaid providers and beneficiaries.

· Apply Federal Payment Levy Program (FPLP) withholding for each payee in accordance with U.S. Department of Treasury requirements.

· Issue demand letters, conduct collection activities, and report on receivables.

· Process debt referrals to the U.S. Department of Treasury.

· Manage/monitor Extended Repayment Schedule (ERS) arrangements.

· Make adjustments to payments including accounts payable/receivable netting as required.

· Manage a single bank account for all new and existing Models that make EFT payments, in accordance with the CMS demonstration payment schedule provided by CMMI and OFM.

· Send IRS Forms 1099-MISC annually for payments made to Model participants in accordance with the IRS threshold requirements.

· Provide proper funds control, oversight, and compliance with all applicable laws, regulations, Federal Accounting Standards, Generally Accepted Accounting Principles, CMS Office of Financial Management (OFM) guidelines and reporting requirements and CMS Internet Only Manual (IOM)/Medicare Financial Management Manual, Chapters 3-7.

I.A. Background Section 1115A of the Social Security Act authorizes CMMI to test new health care payment and service delivery Models that have the potential to lower Medicare, Medicaid, and Children’s Health Insurance Program (CHIP) spending while maintaining or improving the quality of beneficiaries’ care (42 U.S.C. 1315a). Through this initiative, CMMI will use its authority to test alternative Models for payment; provide technical support to promote comprehensive primary care; engage and protect beneficiaries; and facilitate learning and diffusing best practices. Section 1115A(b)(2) of the Act requires the Secretary to select Models to be tested where the Secretary determines there is evidence that the Model addresses a defined population for which there are deficits in care leading to poor clinical outcomes or potentially avoidable expenditures. The statute provides a non-exhaustive list of examples of Models the Secretary may select which include the following: 1) a Model under which CMMI contracts directly with groups of providers of services and suppliers to promote innovative care delivery Models through risk-based comprehensive payment or salary-based payment (see section 1115A(b)(2)(B)(ii) of the Act); and 2) a Model under which CMMI promotes care coordination between providers of services and suppliers that transition health providers away from fee-for-service based reimbursement and toward salary-based payment (see section 1115A(b)(2)(B)(iv) of the Act).

CMMI is committed to achieving better care for individuals, better health for populations, and reduced expenditures for Medicare, Medicaid, and CHIP. One mechanism for achieving this goal is for CMMI to partner with groups of health care providers and suppliers who agree to accept joint responsibility for the cost and quality of care outcomes for a specified group of beneficiaries. CMMI is currently pursuing such partnerships through several initiatives, including the Medicare Shared Savings Program (MSSP), Pioneer Accountable Care Organization (ACO) Model, and the Comprehensive ESRD Care (CEC) Initiative.

Several objectives underlie the overall CMMI approach to testing accountable care Models and include the following.

· Promote changes in the delivery of care from fragmented to coordinated care systems as part of broader efforts to improve care integration, such as initiatives on advanced primary care and bundled payments.

· Improve effective beneficiary engagement and protections against harm.

· Protect the Medicare Trust Fund while finding new ways of delivering care that will decrease expenditures over time.

· Learn and share best practices with providers to assist their pursuits of better care for individuals, better health for populations, and lower growth in expenditures for the Medicare fee-for-service population.

· Develop close working partnerships with providers.

Providers enrolled in CMMI Models are typically paid monthly, quarterly, or annually/semi-annually for their participation in the project. Providers participating in shared saving projects may also be entitled to receive shared savings payments if they succeed in meeting/exceeding the goals/objectives of the project. Conversely, if these providers fail to meet the goals/objectives of the project, they may be responsible for re-paying CMMI all or a portion of the Model funds that have been paid to them. Similarly, beneficiaries may be entitled to receive shared savings payments or other incentive payments for their participation in CMMI Model projects.

Due to the fact that CMMI is authorized to test alternative payment and service delivery Models, the unique eligibility, performance, reimbursement, and service rules of these Models often require CMS to make Model payments outside the Medicare claims processing system; as a result, these Model payments are typically not paid using the Medicare Administrative Contractors (MACs) but instead are processed through alternative payment systems within CMS. In order to process these “non-claims based payments” (NCBP) for the multiple Models authorized under the Affordable Care Act, CMMI has determined that an IPC is necessary to manage the anticipated workload. Under this contract the IPC shall process payments using the following funds: ACA 3021, Medicare Parts A and B Trust Fund, Medicaid, and other specialized funding sources. The IPC shall process payments to Medicare providers, Medicare participating entities (such as ACOs), non-Medicare entities (such as community organizations), Medicare beneficiaries, and non-Medicare recipients.

I.A.1. Accounts Payable/Receivable (AP/AR) Financial Transactions CMS manages various payment systems that process EFT payment files through the Healthcare Integrated General Ledger Accounting System (HIGLAS) which is the official general ledger accounting system of record for CMS. Processing CMMI demonstration payment files through HIGLAS ensures that the required accounting and funds control associated with these transactions is properly conducted and maintained within a CMS system of record. However, for some CMMI Models that are not supported by the IPC, such as the Bundled Payments Care Initiative (BPCI) Model, files containing the demonstration Model participant Accounts Payable (AP) payment and Accounts Receivable (AR) overpayment financial transactions are created in a separate source system (e.g., CMS shared system – MCS) that is interfaced to HIGLAS for payment processing during scheduled payment cycles. After the AP payment and AR overpayment files are uploaded to HIGLAS, Model participant AP payments are then netted against AR overpayments and the net EFT payment amounts are disbursed through the CMS Medicare bank accounts, used by the Medicare Administrative Contractors (MACs), for deposit directly into the bank accounts of the respective payees.

In order to disburse payments for high volume Models, CMS often uses a designated CMS payment contractor to process payments to the payees through a CMS approved Medicare bank account. Under this approach, OFM will process CMMI Model payment funding requests submitted by CMS payment contractors and approved by CMMI through HIGLAS. Treasury will process the HIGLAS payment requests and deposit the total amount of the payment contractor’s funding request into a CMS approved Medicare bank account. The CMS payment contractor will then submit EFT payment requests to the CMS approved Medicare bank to disburse the CMMI Model payments to the respective provider/beneficiary payees in accordance with the payment file developed by the contractor. A similar approach is used for CMMI Models where paper checks are issued rather than EFT payments. However, for paper check payments, after the funds are deposited into the bank account by the Treasury, the CMS payment contractor sends a positive pay check issuance file to the bank and then mails the paper checks directly to the payees.

I.A.2. CMS Funding Requests for IPC Model Payments The IPC shall record and process AP payment and AR overpayment financial transactions received from the CMMI Model team in the IPC’s accounting system to determine the total dollar amount of all payments, to be made to the payees in a scheduled payment cycle, and submit a funds request for approval through CMMI. Upon receipt of CMMI approval, the IPC shall submit the CMS funding request to OFM through email for review. After OFM performs funds control to confirm that CMS funds are available for payment, OFM will process EFT payments in HIGLAS that will be sent to Treasury for disbursement of funds to the IPC. Treasury will deposit the funds into the IPC’s Medicare bank account within five business days.

After the funds are deposited in the IPC’s Medicare bank account, the IPC shall record the deposits received for each Model in the IPC’s accounting system. The IPC shall verify the funds availability and remit the EFT detail payee payment files for each Model to the IPC’s bank for processing so that the EFT Model payments are deposited to the bank accounts of the respective provider or beneficiary payees. For paper check payments, the IPC prepares/issues the paper checks and then sends the positive pay check issuance file to the bank that will be used to validate the checks presented for payment. Throughout the payment cycle, the IPC shall maintain complete records for all AP payment and AR overpayment transactions including the recording of receipts for AR collections deposited into the lockbox accounts maintained by the IPC. The IPC shall manage and track the funding, disbursement and receipt of collections recorded in the IPC’s bank account for each Model and submit financial reporting monthly and quarterly to CMS as specified in Section III.A.4. Upon request from CMMI, the IPC shall be required to provide financial reports and access to the detailed payment information for the purpose of CMMI Model program analysis and shared savings calculations.

I.A.3. HIGLAS

CMS will establish a separate Organization Identifier (ORG) in HIGLAS for CMMI that will enable the IPC to submit AP/AR transactions directly into HIGLAS for payment processing. The CMMI ORG in HIGLAS will contain the standard business functionality that is used the by the MACs for the processing of Medicare FFS payments, such as AP/AR netting and interest calculations on receivables. Although the IPC shall use HIGLAS to report the financial transactions for CMMI Model participant payments and overpayments, the IPC shall continue to request Model funds from CMS that will be disbursed by Treasury and deposited to the IPC’s bank account. The IPC shall develop and submit files for all HIGLAS transactions in accordance with the interface formats provided by OFM and shall also manually enter data into HIGLAS as required. It is anticipated that the IPC shall process financial transactions through HIGLAS using standardized file formats provided by the HIGLAS maintainer (GDIT) to convert open transactions for the initial HIGLAS transition and upload CMMI Model payment AP/AR transactions for processing after production cutover to HIGLAS. The HIGLAS payment batch processing will be fully automated to record the accounting for the transactions and generate an EDI X12 820 payment file to send to the IPC’s bank to execute the EFT payments to the Model participants. The IPC shall be responsible for ensuring that the financial transactions submitted to HIGLAS are processed correctly and timely. The IPC shall work with CMS and/or directly with the HIGLAS maintainer (GDIT) to report problems or correct errors. The IPC shall maintain auditable records associated with all financial transactions processed in the HIGLAS Org.

I.A.4. Alternative CMS Payment and Reporting Systems CMMI may also require the IPC to assist in making certain Model payments using alternative CMS payment systems such as the Automated Plan Payment System (APPS) and the Medicare Advantage and Prescription Drugs System (MARx). CMMI may also require the IPC to interface with other systems such as the Integrated Data Repository (IDR) and Master Data Management (MDM) systems for the purpose of payment reporting and analysis. CMMI shall provide technical assistance and requirements to the IPC for access to these systems.

The IPC shall have the technical capability of making Model payments and conducting all related financial transactions using any of these systems and approaches. Importantly, due to the complexity associated with the system changes required for the IPC to access and use HIGLAS, the integration will be a 14-month project scheduled for production deployment in the following phases: Release 1 in November 2021 and Release 2 in February 2022. Therefore, in order to ensure that the IPC is capable of making payments to the Models identified in SOW Section III.D, the IPC shall plan to make payments in accordance with the requirements outlined below until otherwise directed by CMMI.

I.B. Purpose The purpose of this SOW is to have the IPC process NCBP and provide related financial management services to CMMI for multiple Models. Because of the variation in funding and agency priorities, the actual number of Models requiring financial services during the Option Years may change and in those cases will require a contract modification.

II. TECHNICAL CAPABILITES

The financial services required under this SOW shall be provided by an IPC with demonstrated capabilities in the following areas:

· Managing EFT and paper check payment projects,

· Compiling, managing, and archiving payee banking information, EINs/TINs, legal business names, and addresses,

· Preparing and sending the annual IRS Forms 1099 -MISC to payees,

· Generating and sending National Automated Clearing House Association (NACHA) standard EFT payment files and positive pay check issuance files to a Medicare bank through a CMS approved secure network,

· Disbursing EFTs and issuing paper check payments to Medicare providers and beneficiaries,

· Sending EFT pre-note payments for validation of bank account information in compliance with NACHA rules,

· Maintaining a Medicare bank account and ensuring proper funds control in accordance with all Federal Government and CMS financial management policy,

· Providing collection services and efforts for the recovery of all overpayments including developing/sending demand letters, making telephone contacts, conducting internet searches, referral of delinquent debts to Treasury, offering and managing Extended Repayment Schedule (ERS) plans, and updating recipient payment information, and

· Experience with processing AP/AR transactions through HIGLAS to ensure that FPLP tax and non-tax withholding is conducted on all eligible payments in accordance with Treasury requirements.

III. REQUIREMENTS

The Model Tasks are required for each project unless otherwise directed by CMMI with the following assumptions that the:

· IPC shall process CMMI Model funding requests in accordance with Section I.A.2.

· IPC shall be able to process CMMI Model payments in accordance with the HIGLAS requirements specified in Section I.A.3. and other alternative payment systems specified in Section I.A.4. after the payment system transition schedule has been established.

· IPC shall possess the necessary technical capabilities to complete these Model tasks without additional software, hardware, or other equipment unless otherwise directed and approved by CMMI.

For all Model Tasks specified in Section III.B, the IPC shall:

1) Establish and coordinate routine meetings or conference calls with the Model teams to discuss Model needs and answer questions,

2) Provide a format and schedule to the Model teams for submitting payment requests and transmitting payment files to the IPC,

3) Provide a “welcome packet” with payment related technical/financial services assistance and information to the Model teams,

4) Coordinate with the Model teams to transfer payment files using the CMS Baltimore Data Center, secure email, or other options,

5) Ensure that the CMMI IPC COR and budget staff receive IPC payment requests five business days before the submit date on the OFM calendar for each payment cycle,

6) Coordinate with the CMMI Model team and the budget staff to ensure that sequestration is applied, if necessary, and documented for each payment, and

7) Work with CMMI Model teams to ensure that overpayment collections, recoupments, offsetting and payments are made accurately, timely, and in compliance with CMS financial management policy.

III.A. Operational Tasks (Firm Fixed Price)

III.A.1. Project Management The IPC shall develop and submit the following project management documents to CMMI:

1) Integrated Project Management Plan, which includes Model-specific payments and reconciliation activities, and other tasks that will occur in this Option Year,

2) Payment Methodology,

3) Systems Plan, and

4) Systems Security Plan.

The IPC shall chair weekly conference calls with the CMMI, providing an agenda by 5 pm EST the day prior, and update the agenda with Action Items and any corrections within 24 hours of the meeting. The IPC shall also provide project updates and ad hoc reports as requested. The IPC shall submit monthly progress reports to the CMMI COR and a final report at the conclusion/close-out of each Model; the IPC shall submit a final report at the end of the main contract period of performance that shall include all project accomplishments and recommendations, submit a final payment reconciliation report, return unobligated funds to CMS, and close out the Model bank account. The IPC shall also work with the CMMI COR to develop and implement contractor performance and quality metrics; the CMMI COR shall evaluate the IPC using these metrics on a routine basis.

III.A.2. Accounting System The IPC shall provide an accounting system that can be used to manage all financial transactions for each Model under this contract. The system shall have the necessary accounting, logical partitions, firewalls, and funds control capabilities to ensure that all Treasury deposits and financial transactions associated with each Model can be managed, maintained, and reported separately in a single IPC bank account for Models that make EFT payments in order to prevent co-mingling of Model funds. The system shall be an auditable system of records for all Model financial transactions under the IPC contract. The system shall have quality assurance/payment integrity capabilities to ensure payments are processed accurately and without duplication. The system shall also have separate interfaces for transferring files with CMMI, OFM, the IPC bank, and the Treasury/IRS for purpose of processing AP payments, AR overpayments, FPLP withholding offsets, issuance of IRS Forms 1099-MISC, and remittance advices as required. The system shall have both full and ad hoc reporting capability for all financial transactions and audits, and shall comply with all CMS security requirements.

III.A.3. Establish CMS approved Model bank account The IPC shall be required to maintain a single bank account to include managing, tracking and reporting of available funds for each CMMI Model based upon the processing of the Model’s AP/AR financial transactions including EFT and paper check payments. The IPC accounting system shall be capable of auditable funds control and management of all deposits and transactions. The IPC shall be required to provide the Medicare bank with a monthly banking services Model utilization report that details all Model transactions conducted through the single bank account. The IPC’s bank shall use the monthly utilization report to validate the total monthly utilization for the single account. The bank shall submit a monthly invoice to OFM for the total cost of the single bank account in addition to the costs associated with the separate Model bank accounts. The bank account shall be non-interest bearing and be restricted to receiving Treasury deposits and processing of AP/AR and related Model financial transactions. The IPC shall work with OFM/CMMI as required to add new Models to the single bank account 8 weeks prior to making Model payments. CMS will instruct Treasury to deposit Model funds into the IPC bank account for each payment cycle. Using these funds, the IPC bank shall disburse EFT payments into the payee bank accounts in accordance with the account/routing numbers provided in EFT payment files submitted by the IPC. The IPC shall ensure that the bank account maintains a near zero balance unless otherwise approved by the CMMI COR to manage obligated funds. Surplus funds received from providers due to overpayment collections or voluntary returns and de-obligated funds shall be returned to OFM via a wire transfer on a monthly basis and include the following: Fiscal Year of Model payment cycle with a breakdown of principal and interest amounts, total amount, total count, and allowance.

III.A.4. Financial management and reporting The IPC shall provide CMMI with the following financial reports:

· Monthly TAA reports,

· Monthly CMS 1521/1522 financial reports, and

· Quarterly CMS 751 financial reports.

The IPC shall submit the quarterly 751 financial reports directly to CMS OFM. The IPC shall provide documentation to the CMMI COR demonstrating that adequate internal control policies and procedures have been established by the IPC for all financial transactions conducted under this contract. The IPC’s internal controls shall comply with Federal Government and CMS financial management policy and shall be subjected to the Chief Financial Officer (CFO) Audit and A123 Assessments as required.

III.A.5. Hosting the IPC System Environment The IPC shall host the IPC system environment including the IPC Portal applications, necessary databases (staging, production, etc.), Test and Validation environments, and the Deltek Costpoint system that is used for making non-claims based and other alternative payments for CMMI and CMS-wide Models, demonstrations, and other payments reform vehicles. The IPC will not be responsible for hosting the HIGLAS system environment. Responsibilities for the IPC contractor shall include but are not limited to:

· Secure routine and ad hoc execution of payment files,

· Secure processing and storage of millions of payment records,

· Secure reporting and file transfer capabilities,

· Secure interface with other CMS internal systems and external systems such as US Treasury, and

· Disaster recovery capabilities.

III.A.6. Operation and Maintenance The IPC shall operate and maintain the IPC system environment including the IPC Portal application, necessary databases (staging, production, etc.), Test and Validation environments, and the Deltek Costpoint system. The IPC will not be responsible for hosting the HIGLAS.

Responsibilities for the IPC contractor shall include but are not limited to:

· Secure routine and ad hoc execution of payment files,

· Secure processing and storage of payment records per CMS records retention requirements,

· Secure reporting and file transfer capabilities,

· Secure interface with other CMS internal systems and external systems such as US Treasury, and

· Disaster recovery capabilities.

III.A.7. Software Quality Control and Systems Development Management Plan The Contractor shall establish a culture and infrastructure that supports the practices needed to produce systems and services that meet requirements and satisfy CMS’ needs. The Contractor’s quality improvement program shall include:

· Procedures and standards for creating quality products from the beginning of the lifecycle process, including, but not limited to, elements such as:

· Clear identification of quality roles, responsibilities and authorities within the organization,

· A set of objective (both technical performance and business performance, as well as business impact) criteria to define the overall health of the systems,

· Standard activities to review planning, analysis, and design deliverables that define a system, and

· Practices and tools to verify and validate software release before delivery to CMS.

· Quality control to ensure that project teams follow the standards.

· Ongoing work to improve software quality including:

· Evaluate progress against the defined metrics,

· Track and manage the source code quality,

· Track functional defects (e.g., defect density) and execute strategies for efficient defect resolution. Recommend improvements for efficiency and effectiveness of the defect resolution process, and

· Provide oversight and compliance reporting management for CMMI systems under this contract development environment and to manage the process for code promotion.

The Contractor shall develop a System Development Management Plan (SDMP) that describes its approach to software quality control and managing the software development lifecycle. This is a one-time deliverable that describes the Contractor’s approach to software development, including, but not limited to:

· The Contractor’s quality control program (standards, roles, etc.),

· Requirements management process,

· Design and architecture process,

· Source code management (environments, builds, etc.),

· Change and configuration management,

· Verification and validation of sprints and releases before delivery to CMS, and

· Templates for deliverables, including, but not limited to, requirements documents and test plans.

The Contractor shall participate in a Structured Review with the CMS IPT that reviews both the draft SDMP and draft Program Management Plan.

III.B. Model Tasks (T&M) For all Model Tasks the IPC shall:

1) Establish and coordinate routine meetings or conference calls with the Model teams to discuss Model needs and answer questions,

2) Provide a format and schedule to the Model teams for submitting payment requests and transmitting payment files to the IPC,

3) Provide a “welcome packet” with payment related technical/financial services assistance and information to the Model teams, which includes materials for onboarding payments and recoupment,

4) Coordinate with the CMMI Model teams to transfer payment files using the CMS Baltimore Data Center, secure email, or other options,

5) Ensure that the CMMI IPC COR and budget staff receive IPC payment requests five business days before the submit date on the OFM calendar for each payment cycle,

6) Coordinate with the CMMI Model team and the budget staff to ensure that sequestration is applied and documented for each payment

7) Work with CMMI Model teams to ensure that overpayment collections, recoupments, offsetting and payments are made accurately, timely, and in compliance with CMS financial management policy, and to follow-up/resolve issues identified in Model-specific reports.

All work that directly ties to a Model shall be invoiced as Time and Materials (T&M) under the applicable Model SLIN, by task. A supplemental schedule shall be submitted with the invoice that includes the employee name, labor category, hours and rate billed per task.

III.B.1. Develop the payment file format The IPC shall work with CMMI, OFM, and designated project staff to develop a standardized payment file format for each Model. The file format shall include these payee identifiers or those utilized by the Model: legal business name, EIN/TIN, Payee ID, date, and amount, and additional identifiers that may include NPI, CCN, and business address as required by CMMI. The IPC shall develop and update as needed a data dictionary that explains the payment file data elements/format to be included in a “welcome packet” for use by the CMMI Model teams.

III.B.2. Collect Participant Data for Payment Processing (CMS 588 forms and IPC Portal)

The preferred method for collecting and managing banking information is through the IPC Portal which is internet–based. The IPC shall conduct a Next Generation Desktop (NGD) Extract of banking information for Model payees as directed by CMMI. If necessary, a second validation is conducted in HIGLAS. The payee name and banking information is populated into IPC Portal by a Designated Official (DO) who is an authorized user to validate or update the banking information. If there is no banking information available to pre-populate the IPC Portal, the authorized DO user shall add the correct banking information and upload a cancel check/void check or signed letter from the bank. The IPC shall validate the banking information and the authorized DO user will be notified of the status via a system-generated email. Other alternatives for collecting banking information include accessing the CMS shared systems through the NGD system developed by NGS, the PECOS Uniform Global Extract (UGE) file, and HIGLAS.

The CMS OMB approved 588 form is another method used by the CMMI Model teams to collect banking and payment related information from the Model payees. The original hardcopy 588 form shall be signed with ink or digital signatures, as required by the Models governing document, by the payee/company official with authority over the payee bank account and shall be sent by the payee using encrypted email or overnight mail to the CMMI Model team. CMMI shall scan the 588 forms and send them to the IPC. The IPC shall review the 588 form for completeness and verify that the banking information is valid using either a cancelled/void check or signed letter from the bank submitted by the provider. The 588 form contains: payee banking information, EIN/TIN, NPI/Medicare ID number, legal business name, address, contact names, phone, and email address as well as the profit/non-profit indicators and the project ID number which are added separately to the document by the payee. All 588 forms without a canceled check or letter from the bank are considered incomplete and shall not issue payments to these payees.

III.B.3. Develop the control file The IPC shall develop a separate control file for each Model that includes payee identification information from the IPC Portal or CMS 588s for each project. The IPC shall maintain and update this control file as participants enter and exit the project. Changes and updates to the financial information such as legal name, account/routing number, financial institution, and signature authority shall require an update in the IPC Portal or a new original CMS 588 from the payee with ink or digital signatures, as required by the Model’s governing document. If using the CMS 588 form, minor updates can be done to the form with consent from the CMMI Model team and the IPC COR. The IPC shall scrub all payment files against the control file prior to payment to ensure that all payees on the payment file are eligible for payment and that the information on the payment file is correct.

III.B.4. Conduct pre-payment file scrubbing CMMI shall provide the IPC with a Payment Information File (PIF) for each payment cycle that includes the payees, identifiers, and payment amounts at least five business days prior to the payment submit date on the OFM payment calendar. The IPC shall conduct pre-payment file scrubbing on the payment information file to ensure the payee information is correct.

III.B.5. Develop the payment files and conduct pre-note tests The IPC shall prepare an EFT payment file that complies with NACHA standards from the payment information file received from CMMI. The EFT file shall be forwarded to the bank with each payment cycle. The IPC shall also conduct pre-note testing on the EFT file in accordance with NACHA standards for payment purposes and as otherwise requested by the Model teams to validate payee banking information. The IPC shall submit a 3-Day and 6-Day exceptions report to CMMI for all pre-note and EFT failures. The IPC shall work with CMMI to contact the payee to ask them to update the payee’s EFT bank account information in the IPC Portal or request new CMS 588 forms for all payees designated on the exception reports and update the payee’s payment records accordingly within their internal accounting system. The IPC shall scrub payment files against the OIG Exclusion list to ensure Model payments are not deposited into these accounts. The IPC shall notify the CMMI COR and OFM when payees on the OIG Exclusion list are identified on the payment file and these findings shall also be included in the exceptions reports.

After the HIGLAS Transition project has been completed and deployed to production, the HIGLAS system shall be responsible for sending the EFT payment files to the IPC’s Medicare bank for processing.

III.B.6. Prepare a payment request for each payment cycle The IPC shall send a payment request to the IPC team and the CMMI budget staff for approval and funds certification for each Model five business days prior to the submit date during a payment cycle. The payment requests shall provide the total funds requested for each Model separately. The IPC shall coordinate with CMMI to ensure that the approved payment requests and certification documents are sent to OFM a minimum of three business days prior to each submit date. After reviewing and approving the payment request, OFM will process the payment request through HIGLAS and Treasury will deposit the funds into the IPC’s Model bank account five business days later which is the payment date designated on the CMS demonstration payment calendar. The payment request from the IPC shall include the gross payment totals for both EFT and check files for each Model project, the IPC legal business name, and the date of the request. Additional documentation to support the payment may be requested by OFM/CMMI.

The number and frequency of the payment cycles for each Model is specified in Section II.D., and are included as part of the payment requirements for each Model. Due to the potential for unanticipated changes in Model enrollment such as late entry by participants, incomplete banking information, and other circumstances, CMMI shall require the IPC to be capable of completing additional payment cycles as requested by the IPC COR.

III.B.7. Apply FPLP withholding to the payments The IPC shall ensure that all payments are subjected to FPLP tax or non-tax debt withholding in accordance with Treasury policy and procedures. In order to conduct the FPLP withholding, the IPC shall construct an extract file of the payees on the payment information file including legal business name and EIN/TIN. The IPC shall send the extract file to the Treasury to match against the Federal debt database. The IPC shall receive a match file from the Treasury for any payee with outstanding tax or non-tax debt. The IPC shall offset payments to the payee in accordance with the Treasury withholding requirements and send the offset file to Treasury with the debt amounts withheld. The IPC shall receive an acknowledgement file from Treasury and shall forward all FPLP withholdings to Treasury within 10 calendar days. The IPC shall ensure that the payment remittance advice is designated with the appropriate reason code for the FPLP withholding.

After the HIGLAS Transition project has been completed and deployed to production, the HIGLAS system shall be responsible for sending the FPLP files to the Treasury, applying payment reductions, and issuing funds to the Treasury.

III.B.8. Send the EFT and positive pay check files to the IPC’s bank After the Treasury deposit is received in the IPC’s bank account, the IPC shall send the EFT and positive pay check issuance file to the bank. The bank shall execute the EFT payment file received from the IPC and deposit funds into the respective payee bank accounts in accordance with the EFT file payment instructions. For Models with paper check payment requirements, the IPC shall mail the paper checks with the attached remittance advice to the recipient addresses in accordance with the check issuance file. The IPC shall schedule sending the EFT and positive pay check files to the bank to ensure that all payee EFT deposits occur within 24 hours of receipt of the Model funding deposit from Treasury and that paper checks are mailed and can be processed correctly by the bank within 48 hours of receipt of the Treasury deposit.

After the HIGLAS Transition project has been completed and deployed to production, HIGLAS shall be responsible for sending the EFT payment files to the IPC’s Medicare bank account. The schedule for sending the EFT and positive pay check files to the bank mentioned above may need to be adjusted due to the timing of receipt of the funding deposit from Treasury and the HIGLAS payment cycle dates.

III.B.9. Payment cycle reconciliation and reporting

The IPC’s bank shall send a return file with a payment confirmation to the IPC. The IPC shall reconcile the return file with the completed EFT payment file. The reconciliation shall include accounting for both the paid/correct records and the errors from the return file. The IPC shall reconcile paper check payments using the clears file from the bank that contains the list of all checks that have been processed and paid by the bank. The IPC shall notify CMMI that payments have been made and provide information to CMMI regarding any pre-note and EFT failures, and/or undeliverable checks on the exceptions report. The exceptions report shall be sent to CMMI after the 3rd and 6th day of each payment cycle. The IPC shall provide CMMI with a summarized payment history on a monthly basis that contains a detailed listing of all successful EFT payments, cleared checks, pre-note and EFT failures, and all returned checks with undeliverable addresses.

III.B.10. Overpayment/Recoupment collections The IPC shall issue initial overpayment demand letters to all payees with receivables in collection status. The IPC shall issue a second follow-up demand letter, 45 days from the date of the initial demand letter, as a reminder and Intent to Refer (ITR) to Treasury. The IPC shall coordinate all collections activity with CMMI and the Model team to ensure that all demand letters are reviewed and approved by OFM and the Office of General Counsel (OGC) prior to sending to the payee. All communication with OGC will be conducted internally within CMS. The IPC shall have no written or verbal contact with OGC and is prohibited from participating in any meetings when OGC is in attendance. The IPC shall also work with OFM and CMMI to ensure that the proper accounting structure is in place to receive collected funds as necessary. The IPC shall make three (3) telephone calls to contact all providers in collection status on or about the 30th day, 60th day and the 90th day after the initial demand letter. All changes in demand letter contact name and address information obtained from the phone calls shall be incorporated into the follow-up demand letter sent on the 45th day. The IPC shall use the CMS HIGLAS Debt Management Module to refer all uncollected overpayments to Treasury for recoupment 120 days from the date of the initial demand letter, or as required by the Model’s governing document. The IPC shall process Extended Repayment Schedules (ERS) requests on behalf of CMMI for a period not to exceed six months. Repayment schedules requiring more than six months shall be approved by CMMI. The IPC shall work with the CMMI COR, OFM, and OGC to establish the procedures for collections from providers in bankruptcy as well as those whose payment determination is under appeal. The IPC shall monitor the status of Treasury debt collections through HIGLAS Debt Management Module and shall provide CMMI with monthly accounts receivable aging reports that show activity on all debt referred to Treasury. The IPC shall also report AR overpayment collections to CMS (CMMI and OFM) via the quarterly 751 financial reports in addition to the monthly 1521/1522 financial reports. The IPC shall maintain lockbox accounts with the IPC’s Medicare bank in order to process overpayment collections and shall maintain proper funds control, accounting, and reporting for all overpayment collection activity in accordance with CMS financial management policy.

After the HIGLAS Transition project has been completed and deployed to production, all demand and ITR letters will be generated by HIGLAS, the timing of the follow-up ITR letter will be adjusted to 60 days after the initial demand letter, and the referral of delinquent debts to Treasury will follow HIGLAS’ automated process scheduling.

III.B.11. IPC help desk for participant and Model team inquiries

The IPC shall maintain a toll free help desk telephone line for each Model to receive calls from Participants of each Model supported by the IPC, answer payment and debt collection/repayment questions, address problems such as change of address or how to update banking information, lost checks, check reissue and questions about the IRS Forms1099-MISC. The IPC shall provide CMMI with a monthly summary report of customer service contacts, issues, concerns, and solutions.

The IPC shall be responsible for the following:

· Escalate all inquiries from Level- 2 CSR representatives,

· Research and respond to complex inquiries that a Level- 2 representative cannot address related to payment and recoupment,

· Research expedited inquiries related to any and all Payment inquiries from, to include but not limited to; Department of Treasury, Model teams, contractors, beneficiaries, participants or as directed by CMS,

· Monitor the resolution of open issues and ensure that all inquiries are resolved,

· Ensure escalated inquiries are properly documented and resolved timely,

· Provide a weekly report or dashboard that captures all escalated inquiries from CMMI Help Desk,

· Provide ongoing, useful information to CMMI Help Desk that will assist in improving the user experience,

· Develop scripts and materials to address common inquiries relating to payment inquiries, in collaboration with CMS and/or other CMS contractors,

· Use CMS centralized Enterprise IT Service Management (ITSM) tool, where all tickets can be tracked seamlessly through CMS ITSM tool. The use of CMS ITSM tracking tool will allow a seamless transaction between the ticket creator (Tier 1 or 2) and the technical contractor (Tier 3) supporting the Model team,

· Perform trend analysis to identify similar inquiries that could result in the development of new scripts and materials to address common inquiries relating to payment, and

· Use CMS’ enterprise IT Service Management (ITSM) system for submitting trouble tickets. Data stored in the CMS’ enterprise IT Service Management (ITSM) system incident management system in the CMS secure boundary shall be considered secure and shall not require attachments to be encrypted and password-protected. The IPC shall continue to utilize secure methods for storing and transmitting PII data using other methods, such as ensuring individual credentialing, maintain minimum user privileges, and endpoint protection for all systems and encrypting data within email.

III.B.12. Send IRS Forms 1099-MISC annually to payees The IPC shall prepare and send IRS Forms 1099-MISC no later than January 31, to all payees (excluding non-profit organizations) that received payments during the prior calendar year. The IPC shall also send the electronic 1099-MISC file with this information to the IRS in accordance with the IRS reporting deadline.

After the HIGLAS Transition project has been completed and deployed to production, HIGLAS will generate the necessary data for the IPC to produce the IRS 1099-MISC forms, reports and electronic files.

III.B.13. Apply IRS Backup Withholding The IPC shall apply backup withholding to affected payments in compliance with IRS/Treasury laws and regulations.

III.B.14. Model Onboarding The IPC shall work with the CMMI Model teams on all onboarding activities related to new Models, the IPC Portal, and recoupment of overpayments.

III.C. CMMI Support Tasks (T&M)

III.C.1. Innovation payment enhancements and process improvements The IPC was tasked with developing and implementing payment process improvements to include:

1) A solution for gathering banking and payment related information from applicable CMS data systems, which may include the shared system maintainers (FISS/MCS), PECOS, HIGLAS, NGD, or other CMS systems, and

2) Developing the IPC Portal, an internet-based method for gathering and validating payee EFT bank account and correspondence address information that will allow Model Participants to view and confirm information that the IPC has on record.

The IPC shall assist CMMI in identifying the business needs and potential efficiencies, developing business requirements, and implementing IPC Portal enhancements to better serve internal and external stakeholders.

Release 3 concepts include expanding the IPC Portal Application to provide Model teams the ability to:

· Download reports and file templates;

· Submit files to the IPC;

· Send emails to the participant DOs;

· Specify their cycle schedules;

· Receive email notifications when new reports/files are posted; and

· Access charts and data showing payment, demand, DO information.

III.C.2. IPC Application Authority To Operate (ATO) and annual Adaptive Capabilities Testing (ACT)

The IPC shall obtain/maintain Authorization to Operate (ATO) for the IPC environment including the Deltek Costpoint accounting system and all IPC related payment and data management systems and portal applications. CMMI shall work with the IPC and the CMS Chief Information Security Officer (CISO) to establish a schedule for this ATO that meets the program needs. The IPC shall be required to participate in all facets of security testing, prepare security documents, answer questions, and implement recommendations as required by the CISO to obtain ATO for the payment system application. The IPC shall maintain an ATO by successfully completing all annual CMS security testing requirements needed to process Model payments. This may be done in a 3-year cycle, with one-third of the system reviewed annually. The IPC is not responsible for obtaining an ATO specifically for HIGLAS. The IPC ATO shall be inclusive of the overall IPC environment.

III.C.3. HIGLAS Transition CMMI is working with OFM to establish a CMMI IPC ORG in HIGLAS that will enable the IPC to submit and record all Model AP/AR transactions in HIGLAS for payment processing. The conversion from the IPC’s current Deltek Costpoint accounting system to HIGLAS will be completed in the following phases: Release 1 go-live date is targeted for November 8, 2021 and the Release 2 go-live date is targeted for February 7, 2022; after which the IPC will process all Model transactions exclusively in HIGLAS, unless otherwise directed by CMMI. The HIGLAS Transition initiative will provide automated tracking and reporting of cash balances by CMMI Model by Fiscal Year (FY) by fund. An initial set of high-level business requirements for this capability in HIGLAS were developed by OFM and CMMI in July 2017 and shall be updated with the assistance of the IPC. As directed by the IPC COR, the IPC shall develop a transition plan that details the IPC system changes and migration of IPC data to HIGLAS. The IPC shall participate in all related HIGLAS meetings and work groups to determine the business requirements and functional and technical design specifications for the conversion programs and participate in Integration and User Acceptance Testing (UAT). The IPC shall begin processing CMMI Model financial transactions through HIGLAS, which includes reconciliation and offsetting of payments to recoup Model overpayments, as directed by the IPC COR. For purposes of CMMI Model reconciliation and payment offsetting, the IPC shall:

· Evaluate the HIGLAS functionality required to support CMMI Model requirements for reconciliation and offsetting of payments,

· Develop a plan and supporting business processes for meeting CMMI Model needs and Model-specific reporting that cannot be supported by HIGLAS, and

· Support the CMMI reconciliation and offsetting requirements until the HIGLAS Transition is completed and operational.

· Participate in meetings with OFM and the CMMI Model teams until business processes and necessary systems are established.

The HIGLAS Transition initiative shall provide enhanced functionality to process FPLP offsets to collect delinquent tax debts. The IPC shall meet with the CMMI Model teams and other internal and external stakeholders to gather information, improve problem understanding, and develop a technical solution approach. The IPC shall submit a methodology that includes the technical approach and implementation schedule for addressing CMMI needs in this support task throughout the program contract year. The IPC shall implement the technical approach for this support task after the IPC COR has reviewed and approved the proposed methodology.

III.D. Model Projects and Workload Assumptions The IPC shall have the necessary equipment, facilities, and capabilities to conduct the following activities under this contract.