Coding_Bridge_JA_Final_-_Redacted.pdf

JUSTIFICATION AND APPROVAL FOR USE OF OTHER THAN FULL AND OPEN

COMPETITION

1. Contracting Activity.

Naval Medical Logistics Command (NMLC), Acquisition Management and Analytics Directorate, Code 05, 693 Neiman Street, Fort Detrick, MD 21702.

2. Description of the Action Being Approved.

Approval is requested to award three Indefinite Delivery Indefinite Quantity bridge contracts to Peak Government Sourcing, Inc., Caban Resources, LLC and Diamond Solutions, Inc., on a sole source basis in support of the BUMED’s requirement for coding, auditing and training services at Navy Hospitals and MTFs worldwide.

3. Description of Supplies/Services.

The purpose of the contract is to provide a comprehensive package of coding services that will enhance the overall coding function; assist Navy Military Treatment Facilities (MTFs) in improving the accuracy and completeness of coding; and aid in maximizing workload capture through appropriate medical documentation and coding at MTFs throughout Navy Medicine. The contactor shall provide inpatient and outpatient medical record coding, auditing and training services to Navy MTFs worldwide. Medical coders input appropriate codes for various medical services which will be forwarded to healthcare practitioners and providers for reimbursement. Each type of service has a specific code, and the medical coder is responsible for selecting the appropriate code for the type of service, treatment, test or encounter received. Services are provided on-site or remotely. The objective for this contract is to provide the most accurate and efficient coding, auditing and training services.

Estimated Dollar Value

The estimated dollar value of the contract is $8,288,560.56, inclusive of the option period. The period of performance for this contract is 1 September 2016 through 30 November 2016. A 3-month option period will follow from 1 December 2016 through 28 February 2017. A competitive award is anticipated to be issued with services commencing on 1 December 2016.

4. Statutory Authority Permitting Other Than Full and Open Competition.

10 U.S.C. 2304(c)(1), One source or limited sources.

5. Rationale Justifying Use of Cited Statutory Authority.

When the complete package for this requirement was received on 22 October 2015, the requirement was already two months behind schedule due to constant change requests from the customer. The Solicitation Review Board for the competitive procurement was held on 8 January 2016. Until all questions/concerns were addressed and all changes were incorporated, the solicitation was not released until 1 March 2016.

Less than a week after the solicitation posted on the Federal Business Opportunities website (www.fbo.gov), the customer requested significant changes to the requirement, specifically to remove the Data Quality Audits portion of the requirement and procure these services as a separate requirement.

With these changes, the PWS had to be modified, as well as all of the quantities for most of the CLINs.

http://www.fbo.gov/

Additionally, over one hundred questions were received on the solicitation from interested vendors. Until all the questions were addressed and any necessary changes were made, the solicitation closing date had to be extended several times with the official closing date being 9 May 2016.

The Technical Evaluation Team, Past Performance Evaluation Team and the Pricing/Business Evaluation Team commenced their evaluations on 13 May 2016. The due date for each evaluation was set at 23 June 2016. The Past Performance and Pricing/Business evaluations were completed on or before the due date of 23 June 2016. The Technical Evaluation Report was completed 15 August 2016.

Once legal sufficiency is received on the technical evaluation report, the entire evaluation team (technical, past performance and price/business) will meet to determine rankings of the proposals. The competitive range will be determined at this time and the PCO can prepare to enter into discussions with the offerors.

Due to the reasons cited above, approval to sole source these three contracts to the current contract holders is being requested to avoid a lapse in services. In order to ensure all sites retain these services without a lapse, approval is requested to sole source bridge contracts to the three current contract holders while the documents for the new competitive contract are completed. The new competitive contract is in the technical evaluation phase of the procurement. There is no anticipation of being able to award without discussions. In order to conduct meaningful discussions, allow sufficient time for the offerors to provide revised proposals, allow sufficient time to evaluate the revised proposals, and complete the award process, it is unrealistic to expect this to be completed by the time the current contract ends on 31 August 2016. A lapse in these services is an unacceptable solution because the Navy’s hospitals and clinics worldwide would become noncompliant with federal regulations. Medical coding allows administrations to look at the prevalence and effectiveness of treatment in their facility, which is especially important to hospitals because they can track the efficiency of their treatments. Additionally, Medical coding is essential because it is how claims for payment are reported for appropriate reimbursement of provided medical services. Without medical coding services, there would be an unacceptable delay in payment to the providers which would affect the operations of the MTFs and their ability to meet their mission of patient safety and patient care.

It is not practicable to obtain competition in this circumstance and the services will only be sole sourced until the competitive contract is in place. The PCO must enter into discussions with the offerors prior to being able to make award(s). Given the time constraints, it is not feasible to obtain an approved technical evaluation report, determine rankings of the proposals/determine competitive range, conduct meaningful discussions and make award by the time the current contract expires on 31 August 2016. With these services expiring in such a short time, it would be unreasonable to think that a contractor would be able to sufficiently recruit workers, familiarize themselves with the local marketplace, military treatment facility (MTF) policies, points of contact and scope of work within the timeframe left to avoid a lapse in services.

Peak Government Services, Inc., Caban Resources, LLC and Diamond Solutions, Inc. are the only sources that currently have the knowledge and resources in place to continue services within the timeframe available in a manner that will prevent disruptions at the hospitals and clinics. Therefore, a determination was made that Peak Government Services, Inc., Caban Resources, LLC and Diamond Solutions, Inc. are the only sources available to meet the Government’s needs.

6. Description of Efforts Made to Solicit Offers from as Many Offerors as Practicable.

This requirement will be synopsized on Federal Business Opportunities (FEDBIZOPPS), pursuant to Part

5.201 of the Federal Acquisition Regulation. FAR Part 5.201 states, “For acquisitions of supplies and services, other than those covered by the exceptions in 5.202, and the special situations in 5.205, the contracting officer must transmit a notice to the GPE, for each proposed -- (i) Contract action meeting the threshold in 5.101(a)(1)…” FAR 5.101(a) states, “as required by the Small Business Act (15 U.S.C.

637(e)) and 41 U.S.C. 1708, contracting officers must disseminate information on proposed contract http://farsite.hill.af.mil/reghtml/regs/far2afmcfars/fardfars/far/05.htm#P66_10346 http://farsite.hill.af.mil/reghtml/regs/far2afmcfars/fardfars/far/05.htm#P101_18941 http://farsite.hill.af.mil/reghtml/regs/far2afmcfars/fardfars/far/05.htm#P15_1294 actions as follows: (1) for proposed contract actions expected to exceed $25,000, by synopsizing in the GPE (see 5.201).”

The proposed bridge contracts will be awarded using simplified acquisition procedures because the services required are commercial services. If there is a gap in services, it will be extremely detrimental to the Government because all Navy hospitals and affiliated clinics would be in violation of the Federal regulations that govern medical services reporting and compliance. A bridge contract approval was obtained from the Naval Supply Systems Command (NAVSUP) on 29 August 2016. A Sources Sought notice was not publicized because as part of the NAVSUP Bridge Contract Approval, the PGI waiver was invoked (see DFARS PGI 206.302-1 (d)). A Sole Source Intent notice was posted on 16 August 2016 with a closing date of 30 August 2016. If another company submits a written interest in this requirement as a result of the announcement, the company’s information will be evaluated before the contract is awarded to Peak Government Solutions, Inc., Caban Resources, LLC and Diamond Solutions, Inc.

7. Determination of Fair and Reasonable Cost. The contracting officer will determine the anticipated cost to the Government of the services covered by this Justification & Approval for Use of Other Than Full and Open Competition will be fair and reasonable by conducting a cost analysis before an award is made.

8. Actions to Remove Barriers to Future Competition.

A competitive, multiple award, Indefinite Delivery Indefinite Quantity Firm-Fixed Price contract will be awarded no later than 1 November 2016.

9. Contracting Point Of Contact.

The point of contact at NMLC is Mr. Erik Przygocki who can be reached at DSN 343-0244, commercial

(301) 619-0244 or by email at erik.j.przygocki.civ@mail.mil.

See Approvals on Next Page http://farsite.hill.af.mil/reghtml/regs/far2afmcfars/fardfars/far/05.htm#P56_9285 mailto:erik.j.przygocki.civ@mail.mil

JUSTIFICATION AND APPROVAL FOR USE OF OTHER THAN FULL AND OPEN COMPETITION