Contact Center Engagment JOFOC FINAL Executed.pdf

JUSTIFICATION AND APPROVAL

FOR OTHER THAN

FULL AND OPEN COMPETITION

Acquisition Title: Contact Center Modernization Acquisition Year: FY 2025 Author: Eli Boone

1. Description of Action:

Nature ☒New Requirement ☐Follow-On Order ☐Modification of Existing Purchase Order/Contract Number Contract Type ☒Firm-Fixed Price ☐Time and Materials ☐Cost Plus Fixed Fee (CPFF)

☐Term ☐Completion

☐Cost Plus Award Fee (CPAF) ☐Other: _______________________

Name of Proposed Contractor:

COM-STRAT LLC

1179 Meridith LN Chester Springs, PA 19425

UEI: QEWQNFTJM2D3

2. Description of Supplies or Services:

The purpose of this contract is to provide actionable recommendations to CMS regarding strategies to comprehensively modernize CMS’ contact center operations.

☒Basis for Approval (Far 6.303-1(d) ☒Individual Basis ☐Class Basis

Projected Cost / Price: Base Period FY2025: $70,200

Base Period Option Year 1 Option Year 2 Option Year 3 Option Year 4 $70,200 N/A N/A N/A N/A

Funding Source (s): #001504 Organizational Efficiency Assessment – 0511: Program Operations_Direct:Disc

3. Authority and Rationale:

☐FAR 6.302-1: Only one responsible source and no other supplies or services will satisfy agency requirements, 41 U.S.C. 253(c)(1).

☒FAR 6.302-2: Unusual and compelling urgency, 41 U.S.C.253(c)(2). Rationale:

CMS faces an immediate need to procure advisory services that result in actionable recommendations related to the modernization of its contact center. CMS is operating under a clear and public directive from the White House to rapidly deliver a patient-centered, seamless healthcare ecosystem. Any delay threatens to undermine CMS’ ability to implement promised transformation and deliver meaningful results for the American people by the first quarter of 2026. CMS’ contact center is the public facing “front door” for a wide range of inquiries related to Medicare and Exchange programs, serving more than 87 million beneficiaries and consumers annually and playing a crucial role in providing information, resolving issues, and ensuring access to healthcare services.

However, the contact center’s service delivery model has not kept pace with technological advances that are now widespread throughout industry. Rather, CMS has created a complex web of over a dozen contracts totaling over $900 million per year, which impedes its ability to quickly adopt innovative methods of serving the American people. Continuing this operational status quo directly harms the experience of beneficiaries and consumers by delaying navigation improvements and access to care guidance. Furthermore, CMS’ broader digital modernization initiatives, such as interoperable digital health tools and real-time data exchange, are advancing on tight timelines. A delayed diagnostic and recommendation engagement would decouple call-center improvements from these concurrent deployments, limiting the potential for seamless integration and increasing future complexity and costs.

☐In the interest of economy and efficiency, the new work is a logical follow-on to an original Federal Supply Schedule order provided that the original order was placed in accordance with the applicable Federal Supply Schedule ordering procedures. The original order or BPA must not have been previously issued under sole-source or limited sources procedures (FAR 8.405-6(a)(1)(i)(C)).

☐An item peculiar to one manufacturer can be a particular brand name, product, or a feature of a product, peculiar to one manufacturer). A brand name item, whether available on one or more schedule contracts, is an item peculiar to one manufacturer. (FAR 8.405- 6(b).

4. Bridge Contracts: N/A

5. Actions to Increase Competition: This is anticipated to be a one-time requirement.

6. Market Research: While COM-STRAT is among several vendors that advertise expertise in contact center operations, including McKinsey, MITRE, and Maximus, CMS’ urgent timeline necessitates a sole-source approach with a proven, specialized contractor.

CMS has previously contracted with other organization such as McKinsey, which failed to deliver recommendations CMS could quickly implement. The critical nature and compressed timeline of this engagement demand immediate deployment of a contractor with a proven track record of delivering immediate and actionable results. COM- STRAT’s previous successful work on Social Security Administration call center modernization and standing up the COVID-19 call center during a public health emergency demonstrates that they have the skill set necessary to deliver the actionable recommendations CMS requires. Furthermore, COM-STRAT's team brings an average of over 35 years of specialized experience in this specific sector, providing a combination of institutional knowledge of the federal space with expertise in the capabilities of industry call centers. Their quoted rate of $195/hour, while slightly above the GSA vehicle average of $183.21/hour for senior consultants, is justified by their exceptional experience level and represents fair market value for their specialized capabilities that directly align with CMS's mission-critical requirements.

7. Procurement History: N/A Initial Purchase

Purchase order or contract number:

Was Action Competed? ☐Yes ☐No

Purchase order or contract number:

Was Action Competed? ☐Yes ☐No

If the action was not competed, state the cited authority, summarize rationale, and describe the actions that were supposed to be taken to increase competition and the results thereof:

8. Additional Information to Support the Justification: The complexity and scope of CMS contact center operations necessitate a contractor with exceptional qualifications and proven experience in federal environments. CMS’ contact centers are extraordinarily complex, and standard contact center analysis approaches are insufficient for the operational complexity seen in the CMS contact centers. COM-STRAT LLC has demonstrated experience supporting the Social Security Administration’s contact center modernization efforts, which have similar levels of complexity. This experience also demonstrates COM-STRAT’s ability to work in the federal space, which has unique and different requirements compared to industry contact centers. COM-STRAT LLC also demonstrated their ability to quickly operationalize contact centers through their support standing up the COVID-19 call center; this speed is necessary to inform upcoming decisions for the array of contracts that support contact center operations, including how to best competitively award these valuable contracts. Finally, COM-STRAT has extensive experience modernizing industry contact centers across a wide array of sectors, allowing them to draw on best practices and tailor them to the federal environment. COM-STRAT LLC possesses unparalleled expertise, making them the sole vendor capable of delivering actionable modernization recommendations to CMS within the required timeframe.

APPROVALS:

Program Office Certification: This is to certify that portions of this justification have been developed by the undersigned program office personnel, including supporting information and/or data verifying the Government’s minimum needs, schedule requirements and other rationale, which form the basis for this Limited Source Justification.

Contracting Officer’s Representative (COR)/Date

Program/Project Manager (P/PM)/Date

Best Value Determination: By my signature below, after review of the relevant documents, I have determined that the order subject to this Justification represents the best value for the Government as set forth in FAR 6.303- 2(b)(7) and constitutes a fair and reasonable price.

Contracting Officer Certification: This is to certify that the justification for the proposed acquisition has been reviewed and that to the best of my knowledge and belief, the information and/or data provided to support the rationale and recommendation for approval, is accurate and complete.

Contracting Officer (CO)/Date