DEL_JA Limited Source Justification Redacted.pdf

FEDERAL SUPPLY SCHEDULE LIMITED-SOURCES JUSTIFICATION

Acquisition Title: Maintenance and Oversight of the Support of the CMS Data Element Library (DEL) Agency: Centers for Medicare and Medicaid Services Acquisition Year: 2020 Author:

2. Description of Action:

Nature

• __X__ New Requirement

• ____ Follow-On Order

• ____ Modification of Existing Purchase Order / Contract Number

Contract Type

• __X__ Firm-Fixed Price

• ____ Time and Materials

• ____ Cost Plus Fixed Fee (CPFF)

• ____ Term

• ____ Completion

• ____ Cost Plus Award Fee (CPAF)

• ____ Other: ___________

Projected Cost / Price: __ ______ Funding Source (s):__5309_______

Name of Proposed Contractor(s): Nguyen Information Consulting (NIC)

Street Address: 1776 West Lakes Parkway, Suite 1229

City, State, Zip: West Des Moines, IA 50266

3. Description of Supplies or Services:

This procurement is for the sustainment of the DEL application to continue direct support of data standardization efforts, including the CMS Assessment Library Data Council (CALDC) change control process and Government Support Team (GST) analyses; and ensure provision of up-to-date HIT standards and other data element attributes.

The Period of Performance is estimated to be September 15, 2020 – September 14, 2021.The estimated value of the proposed action is which will utilize 5309 QIO funds. The applicable North American Industry Classification code is 541512, with a size standard of $27.5M.

The CMS Data Element Library (DEL) serves as the centralized and authoritative resource for CMS’s required Post- Acute Care (PAC) assessment data elements and their related HIT standards. The goals of the DEL are:

– To support standardization efforts across CMS assessments and quality measures.

– To serve as the centralized resource for CMS patient assessment data elements and electronic health information technology (HIT) terminology and exchange standards.

– To promote the sharing of electronic CMS assessment data sets and information standards.

– To influence and support industry efforts to promote Electronic Health Record (EHR) interoperability and health information exchange to support patient care coordination.

Minimum Government Requirement

- PAC quality reporting and payment programs, CMS patient assessments, the IMPACT Act, and patient assessment data for the following quality reporting programs: LTCH, IRF, SNF, Hospice and HHA;

- Standardized, interoperable patient assessment data used across PAC settings and possibilities for use and exchange across the continuum of care, as well as internal processes for PAC assessment development, maintenance and change control governance;

- Policy development related to the implementation of new standardized data and quality measures, and PAC assessment manuals; and

- Health information technology vocabularies and technical standards; as well as specific HIT code procurement (e.g.- collaboration with Regenstrief Institute and other standards development organizations).

- DEL application (infrastructure, databases, coding, etc.) and CMS infrastructure/security policies and procedures, as well as timelines for agile development coordinated with other CMS contractors and components.

- HL7 FHIR standards and processes and how the DEL supports health information exchange using FHIR.

4. Authority:

____:ORDER AGAINST FSS: Authority of the Multiple Award Schedule Program, Title III of the Federal Property and Administrative Services Act of 1949 (41 U.S.C. 251, et seq.); Title 40 U.S.C. 501, Services for Executive Agencies;and Section 803 of the National Defense Authorization Act of 2002 (PL 107-107) and implemented by FAR 8.405-6. Mark the applicable exception and for each discuss how the cited authority applies in accordance with FAR 8.405-6(c)(2)(iv).

__X__: Only one source is capable of providing the supplies or services required at the level or quality required becausethe supplies or services are unique or highly specialized (FAR 8.405-6(a)(i)(B));or

The DEL project is currently at a critical junction to advance health information exchange and interoperability in PAC settings, an agency priority. This project reaches across multiple federal agencies, numerous CMS components, and requires the collaboration of many contractors to realize the potential benefits that standardized interoperable data exchange could provide to payers, providers, and patients. The NIC team is one cog in the wheel and essential to the success of other efforts such as establishment of a FHIR API to the DEL application, development of a FHIR server that includes PAC requirements. This requirement is necessary to ensure PAC is included in the next phase of development for the FHIR server activities. The current contractor is the only source that can fulfill this requirement at the level of quality required due to the specialized knowledge of PAC assessment data element standardization, interoperability, internal CMS processes, and understanding of the many stakeholders required for coordinated efforts, (including standards development organizations, Health Level (HL7) authorities, other Centers for Medicare and Medicaid Services (CMS) components, Office of the National Coordinator for Health Information Technology (ONC), National Institutes of Health (NIH), and external stakeholders who use the Data Element Library (DEL) application. It is not logical to compete this contract as the quality of services and support received will be at risk due to the transition and learning curve for the specialized DEL work.

5. Market Research:

Knowledgeable Government Subject Matter Experts for the DEL requirement were consulted to conduct market research. Federal subject matter experts identified key skills and necessary knowledge for contractor expertise and associated acquisition vehicles. Based on the results of the market research and the identification of contractors who could potentially perform this effort in the industry, it is determined no offeror could execute the requirement without an adverse impact to cost, schedule and performance risks to the Government.

6. Actions to Increase Competition:

The Government will conduct market research for the future state of the requirement and execute successor services using an acquisition strategy consistent with the Government’s need.

7. Any other facts supporting the justification:

The Government will utilize the various proposal analysis techniques described in FAR 15.404- 1. The contractor proposed pricing will be compared to an Independent Government Cost Estimate, market research, and historical data to include other contracts for similar efforts. Based on this analysis, the Contracting Officer will negotiate a fair and reasonable price. A further determination will be made by the Contracting Officer that the action represents a fair and reasonable cost to the Government by conducting both a technical and price evaluation as part of a fair and reasonable price determination.