HFS B50676 QIO Revised Emergency-purchase-extension.pdf

EMERGENCY PURCHASE EXTENSION APPROVAL

State of Illinois Chief Procurement Office for General Services Emergency Purchase Extension Approval v.25.2 Page 1 of 5

Section 20-30(a) of the Procurement Code provides that a contract for an emergency may be extended beyond 90 calendar days with the approval of the chief procurement officer (CPO). Prior to execution of the extension, the CPO shall receive this completed form justifying the extension. The duration of the extension shall be limited to the scope of the emergency.

Zip: 70809State: LACity: Baton Rouge Address: 8440 Jefferson Highway

Vendor: Keystone Peer Review Organization, LLC dba Acentra Health

Zip: 62704State: ILCity: SpringfieldAddress: 201 South Grand Ave E

Requesting Agency: HFS - Health and Family Services Division: Bureau of Quality Management

Extension Justification BidBuy Reference #: 26-478HFS-MEDPR-B-54470

Amount of original contract: $ 450,000

Actual or Estimated: Estimated

Original BidBuy Reference #: 27-478HFS-MEDPR-B-53500

Original Emergency Term Start Date:07/27/2026 Original Emergency Term End Date: Oct 24, 2025

Expected Extension Start Date: Oct 25, 2026 Expected Extension End Date: Mar 31, 2027

Amount of extension contract: $ 750,000 Actual or Estimated: Estimated

Is there BEP participation on this contract? If no, explain why

No. BEP participation is not included in this emergency contract. The Vendor requested, and HFS approved, removal of the BEP goal due to the short contract term, which does not allow adequate time to recruit, train, and onboard the required staff without creating operational and liability risks. BEP goals will be restored and incorporated into the forthcoming competitive solicitation.

Has this emergency contract been extended before? Please detail in the space below:

BidBuy Reference # Amount Start Date End Date

$0.00

$0.00

$0.00

1. Provide detail about the events that led the agency to conduct an emergency procurement:

The initial term of the competitively procured contract with eQHealth Solutions, LLC, Contract No. 2021-35-001, for Quality Improvement and Utilization Management Services expired on October 29, 2025.

HFS had anticipated exercising the available renewal options and completing any necessary contractual updates associated with the organizational transition involving Keystone Peer Review Organization, LLC, an Acentra Holdings, LLC entity. However, BEP compliance issues were identified during the renewal review. Although the vendor provided some supporting documentation, the information submitted was not sufficient to support external approval of the CPO’s Good Faith Effort Contract Renewal Waiver and Concurrence. As a result, the required concurrence and other external approvals could not be obtained before the

Emergency Purchase Extension Approval v.25.2 Page 2 of 5

Section 20-30(a) of the Procurement Code provides that a contract for an emergency may be extended beyond 90 calendar days with the approval of the chief procurement officer (CPO). Prior to execution of the extension, the CPO shall receive this completed form justifying the extension. The duration of the extension shall be limited to the scope of the emergency.

Zip: 70809State: LACity: Baton Rouge Address: 8440 Jefferson Highway

Vendor: Keystone Peer Review Organization, LLC dba Acentra Health

Zip: 62704State: ILCity: SpringfieldAddress: 201 South Grand Ave E

Requesting Agency: HFS - Health and Family Services Division: Bureau of Quality Management contract expired.

This is HFS' fourth emergency contract for these services (P-89214 & P-92134 & P-98987), P-89214 (1st) was unable to be extended due to inability to obtain required external approvals; P-92134 (2nd) was unable to be extended due to a significant number of contractual changes requested by the Vendor; P-98987 (3rd) was unable to be extended due to a prolonged negotiation process resulting from the significant number of contractual changes requested which ultimately led to the inability to obtain required external approvals to extend prior to contract expiration.

2. What is the scope of work of the initial emergency contract? Please detail below:

The Quality Improvement Organization (QIO) Vendor must provide utilization management and quality assurance services for Medicaid members across multiple levels of care. This includes medical necessity determinations and continued stay reviews for inpatient hospital care, as well as review and oversight for hospital outpatient services, psychiatric residential treatment facilities, long-term acute care hospitals (LTAC), integrated health homes (IHHs), and other community-based treatment settings. The vendor will also conduct pre-payment and post-payment utilization reviews, appeals and reconsideration reviews, and investigations into potential quality of care concerns. The vendor will operate and support the web-based referral and authorization platform, provide provider outreach, training, and technical assistance, complete standard and ad hoc reporting, and perform special projects as directed by the Department. These activities collectively support the State’s surveillance and utilization control program in accordance with 42 CFR Part 476.

3. Does this extension change the scope of work? Yes No If yes, please detail below:

4. Provide justification for extending the original emergency contract:

The Agency requests an extension from October 25, 2026, through March 31, 2027, to maintain continuity of services while completing a competitive Invitation for Bid (IFB) procurement and transitioning to the resulting contract.

The Agency previously anticipated an extension through June 30, 2027. However, after HFS declined the vendor’s request for a 5% rate increase, the vendor limited its proposed extension to March 31, 2027. These revised terms require an accelerated procurement and transition schedule.

This procurement involves statewide Medicaid utilization management and quality assurance services subject to federal oversight. Completing the IFB requires:

- Finalization of detailed technical, operational, security, privacy, and reporting requirements;

- Coordination among Program, Fiscal, OPM, Legal, DoIT Security, and Privacy;

- Incorporation of applicable federal and program requirements and completion of any required external reviews; and

- Sequencing of solicitation publication, bid opening, responsiveness and responsibility review, award, applicable protest

Emergency Purchase Extension Approval v.25.2 Page 3 of 5

Section 20-30(a) of the Procurement Code provides that a contract for an emergency may be extended beyond 90 calendar days with the approval of the chief procurement officer (CPO). Prior to execution of the extension, the CPO shall receive this completed form justifying the extension. The duration of the extension shall be limited to the scope of the emergency.

Zip: 70809State: LACity: Baton Rouge Address: 8440 Jefferson Highway

Vendor: Keystone Peer Review Organization, LLC dba Acentra Health

Zip: 62704State: ILCity: SpringfieldAddress: 201 South Grand Ave E

Requesting Agency: HFS - Health and Family Services Division: Bureau of Quality Management procedures, contract execution, and transition.

Transition activities may include knowledge transfer, transfer of records and pending reviews, system access, data transfers, staff onboarding, and operational readiness verification. These activities must be completed in time for services under the competitively procured contract to begin April 1, 2027.

Procurement Activities During the Current Emergency Term

During the current emergency term, the Agency has worked to maintain uninterrupted services while developing the replacement procurement. Repeated negotiations over successive emergency contracts and extensions have required substantial time and coordination among OPM, Program, Legal, and Privacy. This work has included resolving changing vendor terms, preparing and revising procurement and contract documents, and obtaining internal and external approvals. These demands have limited the staff capacity available to advance the competitive procurement.

The Agency has also been reviewing existing services and identifying the requirements, documentation, and subject matter expertise needed for the IFB. The designated Team Lead will consolidate prior work, coordinate stakeholder reviews, resolve outstanding comments, and escalate issues that could affect the procurement schedule. Internal reviews will proceed concurrently where feasible.

The procurement timeline identifies the following estimated milestones:

• IFB drafting: November 2026.

• Internal review: December 2026.

• SPO review and publication approval: December 2026.

• Solicitation posting period: December 2026–February 2027.

• Bid opening and responsiveness review: February 2027.

• Notice of Award: March 2027.

• Post-award protest: March 2027.

• Execution: March 2027.

The vendor has offered to continue services only through March 2027. HFS intended to allow time for transition before the extension expires and will work to accelerate the procurement schedule to support that goal.

5. Does this emergency contract correct or eliminate the emergency condition?

Yes No Please detail:

This emergency contract does not fully correct or eliminate the underlying emergency condition. The emergency circumstances will remain in effect until a new vendor is secured through a full competitive procurement process and a transition to the new

Emergency Purchase Extension Approval v.25.2 Page 4 of 5

Section 20-30(a) of the Procurement Code provides that a contract for an emergency may be extended beyond 90 calendar days with the approval of the chief procurement officer (CPO). Prior to execution of the extension, the CPO shall receive this completed form justifying the extension. The duration of the extension shall be limited to the scope of the emergency.

Zip: 70809State: LACity: Baton Rouge Address: 8440 Jefferson Highway

Vendor: Keystone Peer Review Organization, LLC dba Acentra Health

Zip: 62704State: ILCity: SpringfieldAddress: 201 South Grand Ave E

Requesting Agency: HFS - Health and Family Services Division: Bureau of Quality Management contract is completed. The emergency contract serves only as a temporary measure to maintain continuity of critical services while the Agency finalizes and awards the competitive solicitation.

6. Explain why the need cannot be met through a competitive procurement process.

The immediate need cannot be met through a competitive procurement process, as uninterrupted delivery of these critical services is required, and the time necessary to complete a full solicitation far exceeds the timeframe in which services must continue. Recent CMS program changes have introduced substantial new requirements that must be incorporated into the competitive solicitation, necessitating extensive revisions, multilayered internal reviews, and coordination across several offices before the solicitation can be released. Given these conditions, proceeding with an emergency procurement is the only viable option to prevent a lapse in essential services while the comprehensive competitive solicitation is finalized.

7. Is a competitive procurement in process to replace this emergency contract?

Yes No Status: in development

Yes. The Agency is developing an Invitation for Bid (IFB) to replace the emergency contract. The designated Team Lead will build upon work already completed, consolidate existing specifications and stakeholder comments, and coordinate Program, OPM, Fiscal, Legal, IT, and Privacy to finalize the solicitation.

The Team Lead will track the milestones identified in Response #4 and the attached procurement timeline, coordinate resolution of outstanding issues, and escalate delays affecting publication, award, contract execution, or transition. Internal reviews will proceed concurrently where feasible.

HFS will work to accelerate the procurement to allow time for transition before the requested extension expires in March 2027.

8. What is the effect of a denial of this extension request?

If an emergency contract is not executed Illinois will be out of compliance with the federal mandate; non-compliance with 42 CFR Part 476 could open the State up to federal audit findings, corrective action requirements, and potential loss or deferral of federal financial participation (FFP) at a 75% match rate. HFS is unable to immediately hire the number and level of medical professionals required to meet the federal requirements to perform this surveillance and the utilization control services in-house.

Additionally, the following consequences could occur as a result of a loss of services.

Failure to perform timely medical necessity determinations, continued stay reviews, or authorization processing could cause care delays, inappropriate utilization, and increased appeals.

Insufficient oversight, investigations, or quality assurance activities could result in unidentified or unresolved quality-of-care

Emergency Purchase Extension Approval v.25.2 Page 5 of 5

Section 20-30(a) of the Procurement Code provides that a contract for an emergency may be extended beyond 90 calendar days with the approval of the chief procurement officer (CPO). Prior to execution of the extension, the CPO shall receive this completed form justifying the extension. The duration of the extension shall be limited to the scope of the emergency.

Zip: 70809State: LACity: Baton Rouge Address: 8440 Jefferson Highway

Vendor: Keystone Peer Review Organization, LLC dba Acentra Health

Zip: 62704State: ILCity: SpringfieldAddress: 201 South Grand Ave E

Requesting Agency: HFS - Health and Family Services Division: Bureau of Quality Management concerns, placing Medicaid customers at risk.

Inadequate provider outreach, training, or technical assistance could lead to provider noncompliance, dissatisfaction, or reduced participation, impacting access to care.

BidBuy Reference #: 26-478HFS-MEDPR-B-50676

Signatures below cannot be delegated.

APO Signature I am requesting an extension of the requested emergency contract. I believe all statements herein are true and correct to the best of my knowledge.

APO Signature: Date: Oct 20, 2026

SPO Signature

SPO Signature: Date: Oct 20, 2026

CPO Signature Based on my review, I approve the Agency to proceed in accordance with the emergency contract extension detailed in this document.

Based upon my review, I approve the Agency to proceed with the following changes:

If the anticipated competitive procurement results in an executed contract prior to the expiration of this emergency extension contract, the agency should consider terminating this emergency extension contract.

CPO Signature: Date: Oct 23, 2026

Page of

Section 20-30(a) of the Procurement Code provides that a contract for an emergency may be extended beyond 90 calendar days with the approval of the chief procurement officer (CPO). Prior to execution of the extension, the CPO shall receive this completed form justifying the extension. The duration of the extension shall be limited to the scope of the emergency.

State of Illinois Chief Procurement Office for General Services Emergency Purchase Extension Approval v. 25.2

EMERGENCY PURCHASE EXTENSION APPROVAL

State of Illinois Chief Procurement Office for General Services Emergency Purchase Extension Approval v.25.2 Page of Section 20-30(a) of the Procurement Code provides that a contract for an emergency may be extended beyond 90 calendar days with the approval of the chief procurement officer (CPO). Prior to execution of the extension, the CPO shall receive this completed form justifying the extension. The duration of the extension shall be limited to the scope of the emergency.

Extension Justification Actual or Estimated:

Has this emergency contract been extended before? Please detail in the space below:

BidBuy Reference # Amount Start Date End Date

1. Provide detail about the events that led the agency to conduct an emergency procurement:

2. What is the scope of work of the initial emergency contract? Please detail below:

3. Does this extension change the scope of work?

If yes, please detail below:

4. Provide justification for extending the original emergency contract:

5. Does this emergency contract correct or eliminate the emergency condition?

Please detail:

6. Explain why the need cannot be met through a competitive procurement process.

7. Is a competitive procurement in process to replace this emergency contract?

8. What is the effect of a denial of this extension request?

Signatures below cannot be delegated.

APO Signature I am requesting an extension of the requested emergency contract. I believe all statements herein are true and correct to the best of my knowledge.

SPO Signature CPO Signature 11.0.0.20130303.1.892433.887364

HFS had anticipated exercising the available renewal options and completing any necessary contractual updates associated with the organizational transition involving Keystone Peer Review Organization, LLC, an Acentra Holdings, LLC entity. However, BEP compliance issues were identified during the renewal review. Although the vendor provided some supporting documentation, the information submitted was not sufficient to support external approval of the CPO’s Good Faith Effort Contract Renewal Waiver and Concurrence. As a result, the required concurrence and other external approvals could not be obtained before the contract expired.

This is HFS' fourth emergency contract for these services (P-89214 & P-92134 & P-98987), P-89214 (1st) was unable to be extended due to inability to obtain required external approvals; P-92134 (2nd) was unable to be extended due to a significant number of contractual changes requested by the Vendor; P-98987 (3rd) was unable to be extended due to a prolonged negotiation process resulting from the significant number of contractual changes requested which ultimately led to the inability to obtain required external approvals to extend prior to contract expiration.

The Agency previously anticipated an extension through June 30, 2027. However, after HFS declined the vendor’s request for a 5% rate increase, the vendor limited its proposed extension to March 31, 2027. These revised terms require an accelerated procurement and transition schedule.

This procurement involves statewide Medicaid utilization management and quality assurance services subject to federal oversight. Completing the IFB requires:

- Finalization of detailed technical, operational, security, privacy, and reporting requirements;

- Coordination among Program, Fiscal, OPM, Legal, DoIT Security, and Privacy;

- Incorporation of applicable federal and program requirements and completion of any required external reviews; and

- Sequencing of solicitation publication, bid opening, responsiveness and responsibility review, award, applicable protest procedures, contract execution, and transition.

Transition activities may include knowledge transfer, transfer of records and pending reviews, system access, data transfers, staff onboarding, and operational readiness verification. These activities must be completed in time for services under the competitively procured contract to begin April 1, 2027.

Procurement Activities During the Current Emergency Term

During the current emergency term, the Agency has worked to maintain uninterrupted services while developing the replacement procurement. Repeated negotiations over successive emergency contracts and extensions have required substantial time and coordination among OPM, Program, Legal, and Privacy. This work has included resolving changing vendor terms, preparing and revising procurement and contract documents, and obtaining internal and external approvals. These demands have limited the staff capacity available to advance the competitive procurement.

The Agency has also been reviewing existing services and identifying the requirements, documentation, and subject matter expertise needed for the IFB. The designated Team Lead will consolidate prior work, coordinate stakeholder reviews, resolve outstanding comments, and escalate issues that could affect the procurement schedule. Internal reviews will proceed concurrently where feasible.

The procurement timeline identifies the following estimated milestones:

• IFB drafting: November 2026.

• Internal review: December 2026.

• SPO review and publication approval: December 2026.

• Solicitation posting period: December 2026–February 2027.

• Bid opening and responsiveness review: February 2027.

• Notice of Award: March 2027.

• Post-award protest: March 2027.

• Execution: March 2027.

The vendor has offered to continue services only through March 2027. HFS intended to allow time for transition before the extension expires and will work to accelerate the procurement schedule to support that goal.

The Team Lead will track the milestones identified in Response #4 and the attached procurement timeline, coordinate resolution of outstanding issues, and escalate delays affecting publication, award, contract execution, or transition. Internal reviews will proceed concurrently where feasible.

HFS will work to accelerate the procurement to allow time for transition before the requested extension expires in March 2027.

TextField14: If an emergency contract is not executed Illinois will be out of compliance with the federal mandate; non-compliance with 42 CFR Part 476 could open the State up to federal audit findings, corrective action requirements, and potential loss or deferral of federal financial participation (FFP) at a 75% match rate. HFS is unable to immediately hire the number and level of medical professionals required to meet the federal requirements to perform this surveillance and the utilization control services in-house.

Additionally, the following consequences could occur as a result of a loss of services.

Failure to perform timely medical necessity determinations, continued stay reviews, or authorization processing could cause care delays, inappropriate utilization, and increased appeals.

Insufficient oversight, investigations, or quality assurance activities could result in unidentified or unresolved quality-of-care concerns, placing Medicaid customers at risk.

Inadequate provider outreach, training, or technical assistance could lead to provider noncompliance, dissatisfaction, or reduced participation, impacting access to care.