FAR 13.5 Sole Source Justification.pdf

Clinical Documentation36C25524AP3415 VHAPG Part 813.5 Simplified Acquisition Procedures for Certain Commercial Items Attachment 1: Request for Sole Source Justification >SAT-$7.5M under FAR13.5

Effective Date: 02/01/2022 Page 1 of 5

REVISION: 00

Acquisition ID#: 36C25524AP3415

DEPARTMENT OF VETERANS AFFAIRS

SOLE SOURCE JUSTIFICATION UNDER SIMPLIFIED PROCEDURES FOR CERTAIN COMMERCIAL

ITEMS IN ACCORDANCE WITH FAR 13.5

Acquisition Plan Action ID: 36C25524AP3415

1. Contracting Activity: Department of Veterans Affairs, VISN 15, Kansas City VA Medical Center 589-24-4-1916-0045

2. Nature and/or Description of the Action Being Processed:

This requirement is for training for Clinical Documentation Improvement (CDI) for Kansas City VAMC Hospital and CBOC facilities within Kansas and Missouri. Kansas City VAMC HIMS Department is in need of an online and face-to face comprehensive CDI training curriculum for CDI Specialists and RN Advisors.

3. Description of Supplies/Services Required to Meet the Agency’s Needs:

Clinical Documentation Integrity (CDI) is a process where the health record is manually reviewed either concurrently or retrospectively for ambiguous, conflicting, incomplete, or nonspecific provider documentation. A Clinical Documentation Integrity Program requires specialized training to review health records for completeness and appropriate documentation. Training should include the ongoing access for a period of one year. This will be required to allow staff the ability to take the online CDI training curriculum on their own time and whenever new staff are hired at the facilities.

With the CDI training curriculum, the attendee (CDI Coder Specialists & RN Advisor) should be able to:

Understand and apply the ICD-10-CM Official Guidelines for Coding and Reporting from a CDI perspective Identify diagnoses frequently in need of documentation clarification to support accurate code assignment

Understand best practices associated with VHA, CMS and TJC compliant query process’s Learn and understand tips for working, communicating and educating Providers to improve clinical documentation How to recognize the important clinical indicators for diagnoses across major body systems Understand MS-DRG assignment is calculated and the impact of diagnosis assignment Understand how correct code assignment impacts reimbursement Assessment of documentation workflow practices

Specific Requirements

Customized CDI and Coding specialty education for large and/or small groups

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Acquisition ID#: 36C25524AP3415

Association of Clinical Documentation Integrity Specialists (ACDIS) Pocket Guides for Inpatient and Outpatient Coding Rules and Regs

Certified CDI and/or ICD-10 Coding Trainers (AAPC, ACDIS and AHIMA approved) VA attendees will have access to web-based AAPC, ACDIS, and AHIMA approved training curriculum.

Performance Monitoring Provide follow-up training to reinforce CDI objectives Contractor work will be evaluated upon completion by the KCVA HIMS Management staff, along with assigned COR to ensure contract requirements are completed.

Process assessment

4. Statutory Authority Permitting Restricted Competition:

FAR 13.5 Simplified Procedures for Certain Commercial Items. The statutory authority for applying the Simplified Procedures for Commercial Items of FAR 13.5 is 41 U.S.C. § 1901 and is implemented by FAR 13.106-1(b)(2) for restricting competition on this procurement. Competition is restricted on this procurement for the reason below:

(X) Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements

Demonstration that the Contractor’s Unique Qualifications or Nature of the Acquisition Requires the Use of the Authority Cited Above (applicability of authority):

American Health Information Management Association (AHIMA) is the current provider of Clinical Documentation Improvement training. Continuation of AHIMA Clinical Documentation Information services is necessary as current VA coders are certified by Association of Clinical Documentation Integrity Specialists (ACDIS), which is partnered with American Health Information Management Association (AHIMA). AHIMA provides training and access to proprietary resources.

ACDIS has joined forces with (AHIMA) to become the largest and leading industry standard in the United States dedicated to the clinical documentation improvement/Integrity profession. ACDIS provides proprietary resources and support for Coding and CDI professionals, including a career center, CDI Journal, CDI and Coding Forums, sample forms and tools, and more. It also offers advocacy and leadership from a peer-elected ACDIS Advisory Board, including peer-reviewed Position Papers and White Papers. All of these materials are proprietary.

As the process for training KCVAMC’s CDI, Coding and HIMS staff was started in FY21. They continue to use ACDIS approved best practices for compliant record review, Coding and CDI Practices. The continuation and utilization of ACDIS allows for us to access proprietary resources to complete workload and meet national turn around times for accuracy in selection of diagnosis coding and sequencing which directly impacts facility metrics along with RVU and VERA allocation. Training is recieved for certified Clinical Documentation Apecialists from ICD-10 trainers with specialized training in CDI. If training was provided from a new source, many hours of new training would have to be given to re-certify Clinical Documentation Specialist. New materials and methods would also have to be learned.

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Acquisition ID#: 36C25524AP3415

Access to ACDIS proprietary resources to complete workload and meet national turn around times are essential for accuracy in selection of diagnosis coding and sequencing. This directly impacts facility metrics along with RVU and VERA allocation. Training will be given to certified clinical documentation specialists by ICD-10 trainers with specialized training in CDI.

No other provider of CDI has access to these proprietary resources.

Accordingly, ACDIS is the only firm capable of providing the supplies and services described in Section III above without the Veteran’s Health Administration experiencing substantial duplication of cost that could not be expected to be recovered through competition. ACDIS is also the only source for proprietary resources.

5. Description of Efforts Made to ensure that offers are solicited from as many potential sources as deemed practicable:

A Souces Sought was posted to sam.gov July 29-August 5, 2024. Five responses were received. None of the responding businesses were found to provide ACDIS resources.

Market research was provided with results of no findings of other businesses that could provide the proprietary resources.

Before an option is exercised, market research will be performed to determine if there are other providers.

6. Determination by the CO that the Anticipated Cost to the Government will be Fair and Reasonable: The anticipated cost will be considered fair and reasonable by comparison with the Independent Government Cost Estimate (IGCE) which was formulated using market research of current price lists and historical pricing. Certified cost or pricing data is not required as this is a commercial item.

7. Description of the Market Research Conducted and the Results, or a Statement of the Reasons

Market Research Was Not Conducted: Based on the market research conducted, no two or more VetCert certified and capable SDVOSBs or VOSBs were identified and appeared capable of performing the requirement. In addition, no small business in any of the other targeted socio-economic groups appeared to qualify for a set-aside or sole source procurement. Therefore, it is anticipated that all sources (large and small businesses) will be awarded as sole source to ACDIS, a large business.

BAA/TAA/Exceptions to BAA are not applicable as this is a service.

As described in Section 6 above, market research, in accordance with FAR Part 10, was conducted by synopsis of the proposed acquisition, advising industry of the pending acquisition and soliciting inquiries from interested parties.

8. Any Other Facts Supporting the Use of Other than Full and Open Competition: N/A

Attachment 1: Request for Sole Source Justification >SAT-$7.5M under FAR13.5

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Acquisition ID#: 36C25524AP3415

9. Listing of Sources that Expressed, in Writing, an Interest in the Acquisition:

3M Health Information Systems, Inc.

575 W. Murray Boulevard Murray, Utah 84123-4611

The Codegen 9831 W Tarin Dr Elk Grove, CA 95757-8146

Emerging Consultant Solutions, LLC (ECS) 235 Peachtree St NE, Ste 417 Atlanta, GA 30303

Hyre Harper 1130 Duncan Ave.

Pittsburgh, PA 15237

Paradigm Professional Health Services, Inc.

6856 SW Star Jasmine Pl Beaverton, OR 97008-5177

10. A Statement of the Actions, if any, the Agency May Take to Remove or Overcome any Barriers to Competition before Making subsequent acquisitions for the supplies or services required:

Before an option is exercised, market research will be performed to determine if there are other provicers.

11. Requirements Certification: I certify that the requirement outlined in this justification is a Bona Fide Need of the Department of Veterans Affairs and that the supporting data under my cognizance, which are included in the justification, are accurate and complete to the best of my knowledge and belief.

Date

Attachment 1: Request for Sole Source Justification >SAT-$7.5M under FAR13.5

Effective Date: 02/01/2022 Page 5 of 5

REVISION: 00

Acquisition ID#: 36C25524AP3415

12. Approvals in accordance with the VHAPM Part 806.3 OFOC SOP:

a. Contracting Officer or Designee’s Certification (required): I certify that the foregoing justification is accurate and complete to the best of my knowledge and belief.

Denise Maynard Date Contract Specialist Network 15 Contracting Office (NCO15)

b. One Level Above the Contracting Officer (Required over SAT but not exceeding $750K): I certify the justification meets requirements for other than full and open competition.

Randall D. Combs Date Chief, Division II

Network 15 Contracting Office (NCO15)