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BFCC-QIO Amendment Number 1 Industry Questions CMS Responses December 24, 2013
| Question # |
| Section Name |
| Section Number |
| Question Received |
| CMS Response/Comment |
| Can a QIO serve as a subcontractor to more than one BFCC prime contractor? |
| You cannot be a prime and or a sub-contractor on any more than 4 BFCC areas. |
| Can reviews be conducted by nurses/physicians that are not physically located within the BFCC-QIO Area? |
| The QIO should make an effort to utilize reviewers in the service area; however, reviews may be conducted by nurses/physicians not physically located within the BFCC-QIO area provided that they are familiar with characteristics of the local community that may be significant to addressing the case under review. |
| Is the BFCC-QIO required to be a physician sponsored organization |
| No. The requirement that a QIO be a physician sponsored organization was removed from the QIO regulations and is not a requirement under this RFP. |
| Is a ZPIC eligible to be a BFCC-QIO? |
| They are not excluded; however there is a considerable risk for conflict of interest and a detailed, acceptable mitigation plan must be provided, if necessary. |
| Is a QIC eligible to be a BFCC-QIO? |
| They are not excluded; however there is a considerable risk for conflict of interest and a detailed, acceptable mitigation plan must be provided, if necessary. |
| Is a MAC eligible to be a BFCC-QIO? |
| They are not excluded; however there is a considerable risk for conflict of interest and a detailed, acceptable mitigation plan must be provided, if necessary. |
| Does CMS require the BFCC-QIO office facility to be physically located in at least one of the states in the Area? |
| No. Local presence includes the ability to interact with and have quick access to a participating community and the providers in that community. The QIO should have knowledge of the culture, practices, and improvement needs of a community in which it is working and apply that knowledge to its case review and quality improvement projects. Local presence does not necessarily require a brick-and-mortar presence. The QIO should be located in the geographic location(s) in which it can best meet the needs of its populations and communities and establish the necessary strong relationships within the states and at the facility and practice level necessary to accomplish the goals of the contract. The term also does not mean that the QIO must allocate its resources equally within each state of its area but CMS does expect local activity and resources dedicated to each state served. The ability of a QIO to meet the needs of its entire area is paramount. CMS will monitor to ensure that each state in the area is improving in the established goals based on the terms of the contract. |
| Would you please immediately share the list of interested parties for BFCC to permit conversations and "usage" of talented staff in bidder’s teams? |
| No, a list of conference attendees is provided in an amendment. |
| Do the CMS systems permit tracking and viewing electronic/imaged medical records? |
| CMS is developing an electronic Medical Record viewing, storage and transmission system. We plan to have this functionality available for QIO and provider use by the start of the 11th SOW. An enhancement to allow the same functionality for off-site peer reviewers will also be added in a subsequent release of this same system. |
| Will there be time prior to award to have an accounting system audit? |
| Yes there will be time to have an accounting system audit prior to award. |
| What happens if a contractor (potential) determines they may need an accounting system audit due to potential change in organizational structure? |
| CMS will not audit potential “accounting system” changes. CMS will only audit systems after changes have taken place. |
| Does the small business accounting system need to be approved for the QIO opportunities? |
| Yes, the small business accounting systems need to be approved for the QIO opportunities. |
| What are the subcontractor’s expectations for an acceptable/adequate accounting system? |
| The requirements are the same as the Prime contractor. An adequate accounting system is required for a cost-type contract for prime and subcontractors. Subcontractors without an adequate accounting system may have a fixed-price arrangement with the prime. |
| If submitting a Joint Venture with creation of new entity, how soon will CMS conduct an Accounting System Review after bid submitted? Note all members of JV have current approved accounting systems. |
| CMS will conduct an accounting system review prior to contract award. |
| If we plan to make changes to our pools and/or allocation structure, do we need to have a government audit prior to receiving an award? |
| No. CMS will not audit potential “accounting system” changes. CMS will only audit systems after changes have taken place. The business proposal (including your indirect rates) should reflect your estimated assumptions to complete the work. |
| What does CMS define as the minimum requirements necessary to be considered an “adequate” accounting system capable of supporting “cost-plus-fixed-fee” and “cost reimbursement” contract types |
| Refer to the SF-1408 for the minimum requirements. |
| For determining adequate account system: How recent must the DCAA audit be in order to be a valid determination, assuming no changes have been made to the accounting system or methodology? |
| In general, if no changes were made, a term of three (3) to five (5) years. |
| VIQRC has “Appeals Only” in parenthesis. Does this mean that only the appeals portion of VIQRC is prohibited or that we may only perform Appeals? |
| This means that only the appeals portion of VIQRC is prohibited to be performed by another VIQRC awardee. |
| How many MIDS Contractors have already been awarded? |
| Eighteen (18) IDIQ contracts and three (3) Task Orders have been awarded. |
| Can an organization bid on a QIN and BFCC contract recognizing they can’t be awarded both? |
| Yes, offeror’s can bid on both but once they are awarded one, they will be removed from consideration of any other awards. |
| "CMS shall not enter into a contract under this part with any entity (prime or subcontractor) which is, or is affiliated with (through management, ownership, or common control), a health care facility, within the area served by such entity or which would be served by such entity if it entered into a contract with the CMS under this part. An entity shall not be considered to be affiliated with a health care facility by reason of management, ownership, or common control if the management, ownership, or common control consists of no more than twenty (20) percent of the members of the governing board of the entity being affiliated (through management, ownership, or common control) with one or more of such facilities." Does the 20 percent governing board provision apply to a single health care facility or all health care facilities combined? For instance, is an organization eligible to apply if its governing board is made up of a variety of stakeholders but includes more than 20% health care providers overall (eg, physicians, hospital representatives, public health, etc.) but no single health care facility has more than 20% of board members? |
| The 20 percent limit on ownership, management or common control applies to the greater of any facility, chain or health care system. If a facility is independent/free-standing, it applies to the facility. If a facility is part of or affiliated with a chain or a health care system, the 20 percent applies to the chain or system. |
| Will there be multiple NCC subcontractors? |
| CMS anticipates awarding 1 single CPFF type contract for the BFCC-NCC. |
| Scenario: Company C subcontracts under company A in a proposal for BFCC QIO. Company C Subcontracts under Company B in a proposal for QIN-QIO. Company A wins a BFCC QIO contract. How will this impact company B’s proposal/bid for QIN QIO contract, especially if company C was considered a likely winner? How will this impact Company C, a subcontractor based on the BFCC prime contractor win or the QIN QIO prime contractor’s likely win? |
| Company B’s bid on QIN would be withdrawn. Please refer to Section M.3.C “… any offeror’s subcontractors proposing on this BFCC-QIO RFP are prohibited from receiving awards for the following…….1. QIN-QIO contracts.” Since BFCC-QIO is scheduled to be awarded before the QIN-QIO contracts, the BFCC-QIO would take precedence over the QIN-QIO procurement. |
| Please clarify a subcontractor cannot submit for the BFCC and the QIN-QIO. |
| A subcontractor cannot submit for the BFCC and the QIN-QIO. Please refer to Section M.3.C “… any offeror’s subcontractors proposing on this BFCC-QIO RFP are prohibited from receiving awards for the following…….1. QIN-QIO contracts.” |
| When are NCC and PCC RFPs going to be released, and when are proposals due? |
| NCC and PCC RFP’s are scheduled to be release early 2014. There are no established proposal due dates at this time. |
| Will the PCC contract be a full and open competition? If so, when will the RFP be released? |
| The acquisition strategy has not been decided for the PCC contract at this time. |
| Is it sufficient for contractors to ask key personnel if they have any actual or potential Personal COI, and if “no”, simply sign and attest to that, but if “yes”, then be required to list specifics (i.e., percentage of ownership income generated, etc.)? or Are contractors required to collect financial-investment information up front and review it to determine if it is a potential or actual personal COI? |
| Offeror’s are required to disclose all current and known future financial business interests and positions related to health care. CMS will review this information during the pre-award process, and it will be expects that compliance officers will review during the post award process. CMS also expects that offeror’s will be able to put together a robust and comprehensive disclosure form for Key Personnel, Managers and Board Members to fill out based upon both Section H.11 of the Solicitation and attachment J.20, Organizational Conflict of Interest Sample Disclosure Template. Please refer to the BFCC Solicitation in section L.14.E Tab B, number 2 entitled “Conflicts of Interest (Personal) – Information and Detail.” |
| Many QIOs (and others) perform Medicaid UR and EQR, which requires that the contractor be a QIO or QIO-like entity for the higher match. The existing definition of a QIO-like entity is based on pre-trade bill statute and regulations. If an existing QIO is no longer a prime contractor – perhaps as a result of a new joint venture --will it still be considered a QIO-like entity? |
| The post-Trade Bill statutory requirements, as implemented through the recent regulation, is effective 1/27/2014; that is, the new regulatory criteria would apply for QIO-like entity certifications granted after 1/27/14. Because the Medicaid statutory provisions (Social Security Act §§ 1902(a)(30)(A), 1902(d) and 1903(a)(3)(C)) all discuss the use of a QIO or QIO-like entity by a Medicaid State agency to perform “medical or utilization review” functions, QIO-like entities would need to meet the criteria particular to BFCC-QIO awardees. Organizations that have 10th SOW contracts but do not win 11th SOW BFCC-QIO contracts would need to apply for certification as a “QIO-like entity” for CMS review on a case-by-case basis. See the procedure on the CMS website at http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/QualityImprovementOrgs/HowtoBecomeaQIO.html. |
| Due to the fact that QIN bidders will be eliminated from further consideration of those bids if they are awarded a BFCC contract, if an awardee for a BFCC contract is also a potential partner on a QIN-QIO contract, would the other QIN bidders be afforded an opportunity to rework their proposal with another potential partner? |
| No. In Volume 3, Offeror's shall submit a mitigation plan in response to potentially receiving a BFCC-QIO contract. |
| Will the FY2014 Contracting with CMS Conference planned for January 31 duplicate information from the December 16 conference in Baltimore, will there be new material pertaining to the QIO program, or will there be minimal content regarding the QIO program at that conference? |
| No |
| Neither the BFCC nor the QIN RFP defines "QIO" or "QIO-like" status. This is not addressed in the OPPS ruling, either. Can these be defined? |
| The post-Trade Bill statutory requirements, as implemented through the recent regulation, is effective 1/27/2014; that is, the new regulatory criteria would apply for QIO-like entity certifications granted after 1/27/14. Because the Medicaid statutory provisions (Social Security Act §§ 1902(a)(30)(A), 1902(d) and 1903(a)(3)(C)) all discuss the use of a QIO or QIO-like entity by a Medicaid State agency to perform “medical or utilization review” functions, QIO-like entities would need to meet the criteria particular to BFCC-QIO awardees. |
| By going regional, would IT department be still managing admin accounts on the QualityNet website for all of the states they are responsible for? |
| Yes. |
| When will the QMARS application be implemented in the 11th SOW? It wasn’t noted in the RFP. |
| The QMARS application will be implemented at the start of the 11th SOW. |
| When QualityNet website going away in the 11th SOW and will be using QIMS? |
| The QualityNet Website isn't currently scheduled to be eliminated. |
| If the "prime vendor A" proposes a region with 4-6 states, and one of the states in the "prime vendor A" proposed region is awarded a BFCC contract, will "prime vendor A" still be considered eligible for their proposed QIN IDIQ award, or will they be eliminated as their original proposed region has changed from 4-6 states to a region of 3-5 states? |
| See B.10 - Contract Limitations. |
| Are stakeholder organizations such as hospital and physician associations considered a “Health Care Facility” or “Health Care Affiliate” in these RFPs? |
| The prohibitions against CMS contracting with healthcare affiliates or healthcare facilities as QIOs are described in Section 1153(b)(3)(A) of the Social Security Act and Section 42 CFR 475.105 of the QIO regulations. The regulations define a health care facility affiliate as "an organization in which more than 20 percent of the members of the governing body are also either a governing body member, officer, partner, five percent or more owner, or managing employee in a healthcare facility in the QIO area". |
| Do physicians and nurses need to be licensed in the same states as the quality of care case originated? How does the OPPS impact this requirement? |
| The regulations at Section 42 CFR 475.102 describe the CMS requirements for QIOs performing case review. Although CMS does not require that the healthcare professionals performing case review be licensed in the state where the care was provided, CMS will consider the organizations proposed involvement of and access to physician and practitioners in the QIO area with the appropriate expertise and specialization and the organizations ability to take into consideration urban versus rural, local and regional characteristics in the health care setting where the care under review was provided. |
| In order to process Appeals more efficiently, will CMS consider allowing the use of a non-SDPS application developed by a potential vendor? |
| Yes, provided the QIO is also meeting the expectations for timely data entry into the CMS-designated case review system. |
| We have had an indirect rate audit within the past 5 years; however we have not had a CAS since 2007. Will this meet the requirement for the Cost Accounting Standards compliance Standards? |
| The requirement for a CAS disclosure statement (D/S) is a completely separate requirement from that of provisional rates. While indirect rates are described in the CAS D/S, other practices are described in the D/S as well. The requirement for a CAS D/S is triggered by the award of a contract greater than $7.5M for modified CAS or $50M for full CAS. |
| 40 |
| Type of Contract |
| B.2 |
| If an organization is in the process of setting up an adequate accounting system and requesting government agency review of this system, is it eligible to submit a proposal? |
| Yes, the accounting system must be deemed adequate by contract award. |
| 41 |
| Medical Records Photocopying |
| B.6 |
| Medical records will be inherited from the incumbent. What is the estimated storage cost per year that an awardee should budget for these medical records? Where this cost should be placed? |
| The offeror should estimate the MR storage costs based on the case review volume estimates provided. These costs should be placed in the J-18B, BFCC-QIO ODC Tab, Non-Review Activities Column, line item "e. storage". |
| 42 |
| Medical Records Photocopying |
| B.6 |
| May the contractor apply its G&A rate on medical record photocopying and mailing fees consistent with its established practices which are part of its government approved accounting system? |
| If the G&A rate is predicated with such costs in the allocation base, then the contractor must apply the G&A rate to those costs. The contractor must apply their indirect rates in conformity with the manner in which those rates were developed. |
| 43 |
| BFCC-QIO Areas and Attachment J-19 QIO Pass Thru Costs |
| B.9 |
| The RFP states the Virgin Islands are in Area 1 and Attachment J-19 states the Virgin Islands are in Area 2. Please confirm in which area the Virgin Islands will reside. |
| Virgin Islands are included in Area 1. Please see the revised Section J, Attachment J-19 for the correction. |
| 44 |
| BFCC-QIO Areas |
| B.9 |
| If a contractor determines that it wants to submit a bid for more than one BFCC-QIO area should a cost proposal be submitted which covers the multiple areas combined along with a separate cost proposal for each of the QIN-QIO areas in the event that CMS decides to award multiple areas to the same contractor? |
| Separate proposals - technical and business - must be submitted for each BFCC-QIO Area proposed. Proposals including multiple BFCC-QIO Area submissions will not be accepted. |
| 45 |
| Contract Limitations |
| B.10 |
| CMS indicated at the bidder’s conference that if a company was awarded a BFCC contract, its QIN proposal would automatically be taken out of consideration for a QIN award. If a company submits bids on both BFCC and QIN work, and is subsequently notified of the government’s intent to award it a BFCC contract, may the company decline in order that their QIN proposal remain under consideration for a QIN award? |
| No. CMS reserves the right to make awards to the offeror’s that represent the "Best Value" to the Government. It's estimated that the BFCC-QIO contract will be awarded 2 months prior to the QIN-QIO contract. |
| 46 |
| Contract Limitations |
| B.10 |
| Will a proposing entity’s plan to divest related to its BFCC RFP response be reviewed prior to the submission date of QIN proposals? |
| No, BFCC's offeror’s divesting plans will not be fully reviewed prior to the submission date of the QIN proposals. |
| 47 |
| Contract Limitations |
| B.10 |
| Please provide an estimated timeline for the release of the following procurements: |
a. Program Collaboration Center (PCC);
b. National Coordinating Center (NCC) for BFCC;
c. National Coordinating Center for QIN;
d. Value Incentives and Quality Reporting Centers (VIQRC's);
e. Independent Evaluation Center (IEC); and
f. BFCC Oversight and Review Center (BFCC ORC).
Also, will any of these procurements be issued as a set aside and if so, which ones?
Awards are estimated as following:
a. PCC - May 2014 - Acquisition Strategy is TBD b. BFCC NCC - May 2014 - Full & Open Competition c. QIN NCC - May 2014 - Anticipated Full & Open Competition d. VIQRC's - May 2014 - Anticipating competing five (5) task orders under the current MIDS IDIQ contract e. IEC - December 2014 - Acquisition Strategy is TBD f. BFCC ORC - January 2015 - Acquisition Strategy is TBD
| 48 |
| Contract Limitations |
| B.10 |
| Would a QIC be prohibited due to OCI issues from working as a sub to a prime on the BFCC? |
| QICs are not excluded from being BFCC QIOs however, there is a considerable risk for COI and a detailed mitigation must be provided if a conflict exists. |
| 49 |
| Contract Limitations |
| B.10 |
| What is the rationale for not allowing an organization to be involved with a QIN and a BFCC contract, even in non-overlapping geographic areas? This appears to limit competition unnecessarily. Couldn't mitigation be used to address perceived or actual conflict of interest? |
| The harm to the QIO program caused by the appearance of a conflict of interest is equal to the harm caused by an actual conflict of interest. This separation has been made to resolve any conflict of interest issues. |
| 50 |
| Contract Limitations |
| B.10 |
| If there is an existing QIO entity that has a holding company with 3 wholly owned subsidiaries and 1 is divested, must the divestment be complete prior to the submission of the response to the BFCC RFP? |
| The decision to divest is a business decision. Should an offeror decide to divest, it must be a full divestment leaving no affiliation between the two entities. The Government perceives a debt interest to be a financial/ownership interest, therefore if an offeror is divesting, a divestment plan should include a short term divestment strategy with milestones. |
| 51 |
| Contract Limitations |
| B.10 |
| If there is an existing QIO entity that has a holding company with 3 wholly owned subsidiaries and 1 is divested, will the BFCC response to the RFP from the company being divested be considered an independent bid from the remaining organizations’ QIN response to the RFP |
| Yes. |
| 52 |
| Contract Limitations |
| B.10 |
| Can an organization that wins a BFCC contract purchase infrastructure services such as finance and accounting and HR from a QIN contract holder? |
| No, see B.10 - Contract Limitations |
| 53 |
| Contract Limitations |
| B.10 |
| Can an organization that wins a BFCC contract purchase infrastructure services such as IT from a QIN contract holder? |
| No, see B.10 - Contract Limitations |
| 54 |
| Contract Limitations |
| B.10 |
| Does the Agency interpret and/or apply the term “Quality Improvement Organization” as a status designation, and if so, how does the Agency determine whether a company is a “Quality Improvement Organization”? |
| An organization becomes a QIO when it is awarded a QIO contract. |
| 55 |
| Contract Limitations |
| B.10 |
| Please confirm that there is no prohibition against a QIN-QIO subcontracting with a BFCC-QIO awardee to perform a BFCC-QIO contract? |
| Please refer to Section M.3.C “… any offeror’s subcontractors proposing on this BFCC-QIO RFP are prohibited from receiving awards for the following…….1. QIN-QIO contracts.” |
| 56 |
| Contract Limitations |
| B.10 |
| Under this new contract arrangement, if an organization is a QIN-QIO can it perform other types of hospital claims review or appeals review for the Medicare program outside of the QIO program, e.g., as a subcontractor to a MAC, RAC or QIC? The answer to this question is important in making a decision on whether to submit a bid for the BFCC-QIN versus the QIN-QIO. |
| Depends on the work they are completing. They are not excluded; however there is a considerable risk for conflict of interest and a detailed, acceptable mitigation plan must be provided, if necessary. |
| Will the BFCC-QIO be required to have access to multiple evidence-based guidelines? |
| The BFCC QIO is required to use evidence based guidelines in making its case review decisions. CMS will not require that the QIO use any specific guideline or source. |
| Will BFCC-QIOs be allowed to enter into exclusive arrangements to provide or utilize evidence - based guidelines? |
| The BFCC QIO is required to use evidence based guidelines in making its case review decisions. Although exclusive arrangements are not prohibited, the use of only one source may not provide appropriate standards for the various types of cases QIOs are directed to perform. |
| Inter-Rater Reliability Measures for QIO monitoring - are they standard or proprietary to the QIO? |
| There will be standard IRR measures used to evaluate all QIOs. |
| 60 |
| QIO Program Structure and Requirements |
| C.3.1 |
| How will the BFCC ORC determine the sample for independent reviews for case reviews performed by BFCC-QIOs? |
| There will be standard IRR measures used to evaluate all QIOs. The methodology has not been determined. This will be shared with QIOs as soon as methodology has been developed. |
| 61 |
| QIO Program Structure and Requirements |
| C.3.1 |
| BFCC QIO to send appeals to VIQRC. Does this include appeals of quality of care complaints? |
| The BFCC QIO will not send appeals to the VIQRC. The BFCC QIO is responsible for processing all appeals it receives. The appeals received and processed by the VIQRC are related to the quality reporting program determinations. |
| 62 |
| Technical Considerations |
| C.4.1 |
| The current QIO manuals are outdated. Will new updated manual for BFCC QIOs be provided prior to the beginning of the 11 SOW? |
| We are in the process of updating the QIO Case Review Manuals. CMS plans to have an update available prior to the start of the 11th SOW. |
| 63 |
| Technical Considerations |
| C.4.2.1 |
| Currently each QIO is given one dedicated “node” to the CMS data warehouses for securing data entry. These lines are expensive and may take several months to build. Will the successful bidders get new dedicated data lines separate from the current QIO connections? With the considerable size expansion of these contracts, can a vendor get more than one line so they can locate staff in more than one location for efficiency? What is the anticipated lag time from award to active connection? |
| See the section C.4.3 Infrastructure Operations Support and Data Management. It is dependent on local circuit providers schedule but generally takes between 45-60 days. Time varies by location around the Country. |
| Technical Considerations |
| C.4.6 |
| Is the Offeror expected to have addressed prior identified FISMA items that require funding? |
| All CMS Contractors shall comply with Federal and CMS security policies. Please refer to Attachment J-7. |
| 65 |
| General Requirements |
| C.5.3 |
| Attachment J-4 lists data CMS will supply to the BFCC-QIO. Page 23 of the RFP states, “CMS will not provide all data that is needed by a BFCC-QIO….” Would CMS elaborate on the data that will not be provided to the BFCC-QIO? |
| The RFP states the BFCC-QIO is responsible for determining what additional data is necessary and collecting it as appropriate. |
| 66 |
| General Requirements |
| C.5.4 |
| What data abstraction services will the Clinical Data Abstraction Center (CDAC) provide for the BFCC-QIO? |
| There is no specific data abstraction services planned at this time. This section was included in the event data abstraction needs are identified. |
| 67 |
| General Requirements |
| C.5.4 |
| Although there will be a subcontract between the BFCC-QIO and the CDAC for data abstraction services, will the CDAC be paid directly by CMS for its services? If not, what assumptions should be used in this proposal to price out CDAC services? |
| There is no specific data abstraction services planned at this time. This section was included in the event data abstraction needs are identified. If other services are identified as necessary, such as data entry or records management, sub-contracting shall be handled separately with negotiating between the BFCC-QIO and CDAC, subject to approval by the CO. |
| 68 |
| General Requirements |
| C.5.5.1 |
| This section discusses coordination with stakeholders and may involve joining and/or supporting partnerships, coalitions, and teams of organizations when that teaming would be consistent with the terms of the SOW.” Does this mean that membership fees for such organizations would be automatically approved if identified in the technical response? |
| Costs/fees are subject to approval by COR and CO. |
| 69 |
| General Requirements |
| C.5.5.2 |
| “At the minimum, the BFCC-QIO shall participate annually in collaborative activities that are sponsored by the applicable CMS Regional Office and focus on CMS-identified priority initiatives.” Should BFCC-QIO budget travel costs for the annual collaborative activities? |
| Yes. |
| 70 |
| General Requirements |
| C.5.5.4 |
| The paragraph states, “…the BFCC-QIO shall use systematic, communications-industry standard methods to assess how well communications activities meet their intended objectives and how these communications objectives ultimately help the BFCC-QIO meet its contractual objectives.” One of the most effective industry standards for measuring communication messages and tactics is pre- and post-assessments conducted via survey. In accordance with Chapter 12 of the QIO Manual, if the BFCC-QIO is to utilize pre-and post-surveys to measure effectiveness, can it send closed-ended pre- and post-surveys to less than nine persons for every strategy and tactic implemented and disseminated, regardless of the distribution method? |
| Any survey of Medicare beneficiaries must adhere to the Paperwork Reduction Act (PRA) requirements listed at the following link. |
http://www.hhs.gov/ocio/policy/collection/infocollectfaq.html#8
| 71 |
| General Requirements |
| C.5.5.4 |
| The paragraph states, “…the BFCC-QIO shall use systematic, communications-industry standard methods to assess how well communications activities meet their intended objectives and how these communications objectives ultimately help the BFCC-QIO meet its contractual objectives.” One of the most effective industry standards for measuring communication messages and tactics is pre- and post-assessments conducted via survey. In accordance with Chapter 12 of the QIO Manual, can this type of survey be replaced by an evaluation/assessment of current circumstances/conditions pre- and post-dissemination? |
| Any survey of Medicare beneficiaries must adhere to the Paperwork Reduction Act (PRA) requirements listed at the following link. |
http://www.hhs.gov/ocio/policy/collection/infocollectfaq.html#8
| 72 |
| General Requirements |
| C.5.5.4 |
| This section states that the QIO “shall use systematic, communications-industry standard methods to assess how well communications activities meet their intended objectives.” Is there a template the QIO is expected to use to evaluate communications, such as the IISS that is used in the 10 SOW? |
| Included as part of the Communications Handbook J attachment is a series of documents that demonstrate how CMS has historically asked the QIOs to meet this requirement, using a deliverable called the “Integrated Innovation Spread Strategy” (IISS). Please note that this is NOT a required deliverable for this SOW; however, it is provided to offeror’s as an example of one way a QIO could implement internal controls to ensure that its communications work meets the standard of the BFCC-QIO SOW. It is important to note that a COR may request documentation of a QIO at any point about how it is meeting communications-industry standard methods; however, the explicit format of the IISS is not a requirement under Schedule F of this SOW. Frequently asked questions, an example and template is added to the RFP as Attachment J-24. |
| 73 |
| General Requirements |
| C.5.5.5 |
| “Only use the website for informational purposes and not for any application (software) design/usage unless approved in writing by CMS ISSO.” Is this guidance referring to the lifting of code from a QIO website for use to another website, or is it referring to the development of active applications within the code? |
| Any use of CMS code and websites must be approved by CMS prior to any use. |
| 74 |
| General Requirements |
| C.5.5.6 |
| Regarding 508 accessibility standards, is this referring to all electronic modes of communications including e-mails from federal accounts, website forums, and blog postings? |
| Yes |
| 75 |
| General Requirements |
| C.5.6 |
| The text discusses two plans. Are these to be provided in two separate documents or one document? |
| These are to be provided in one document. |
| 76 |
| Outreach Costs |
| C.5.5.9 |
| First, this paragraph refers to terms included in Section C.7.9, Glossary and Acronyms, of the contract. However, there is no C.7.9 in the BFCC-QIO RFP. All three of the referenced terms are actually in Attachment J-1, BFCC Glossary. Shouldn’t the references to Section C.7.9 be changed to Attachment J-1? Second, this paragraph includes three references to the QIN-QIO. Shouldn’t these references be to the BFCC-QIO? |
| Yes. All reference C.7.9 should read "Section J, Attachment, J-1 Glossary." Yes. All QIN-QIO references should read "BFCC-QIO." Please see revised Section C.5.5.9 included in this Amendment. |
| 77 |
| Continuity of Operations and Contingency Plan |
| C.5.6 |
| The first bullet requires submission of COOP and CP plans that include “how the BFCC-QIO will deliver all five support operations listed above…” There is no list of support operations. The requirement in the BFCC-QIO RFP appears to be identical to a requirement in the QIN-QIO RFP, but the list in that RFP was not included in this RFP. Will the BFCC-QIO RFP be amended to include all of the relevant requirements or will the quoted language be changed? |
| Please see revised RFP incorporating the revised C.5.6 Section. |
| 78 |
| General Requirements |
| C.5.6 |
| The instructions require “A Continuity of Operations Plan (COOP), contingency planning for extended loss of service, identification of risks, and mitigation strategies.” Including this information will extend beyond the page limit for Tab 4. In relation to pages 30-31, could CMS please clarify what is being requested for inclusion in the proposal response? |
| The instructions for Tab 4 do not require a COOP document explicitly—this is a deliverable of the contract itself, and will be a necessary document for those organizations that ultimately perform BFCC-QIO work. Rather, Tab 4 requires the offeror to submit a proposed management plan that demonstrates/documents it has the necessary management structure to successfully perform these COOP activities. |
| 79 |
| General Requirements |
| C.5.6 |
| This section references Attachment J-7 (Information Systems Library); however, this attachment is missing from the CMS documents released with the RFP. Will CMS provide this attachment in a future amendment? |
| Please find Section J, Attachment J-7 included in this Amendment. |
| 80 |
| Overview/Background |
| C.7.1 and J-17 |
| The bullet list identifies nine functions of the BFCC-QIO. Attachment J-17 lists fifteen review categories along with their annual volumes. Please provide a listing that aligns the nine functions with the fifteen review categories. |
| See Attachment 1 to BFCC-QIO Questions and Answers |
| 81 |
| BFCC |
| C.7.1 |
| “The BFCC-QIO will be responsible for using the results of all activities to make recommendations to QINs on quality improvement initiatives….” Is the BFCC-QIO responsible for developing, implementing, and/or monitoring any QII activities as the result of any trending patterns, sanction cases, or confirmed concerns identified by the BFCC-QIO? |
| No. The BFCC QIO is only responsible for the referral of these QIIs. Subsequent monitoring will be performed by the QIN QIO. |
| 82 |
| BFCC |
| C.7.1 |
| In the overview/background, the functions of the BFCC are described as Medical Necessity reviews; however, these reviews are not mentioned in the J-18 B, Business Proposal Forms. Would CMS please clarify? |
| A separate column for this task was not included since this work is a sub-part of the other review categories. |
| 83 |
| BFCC |
| C.7.1 |
| In the overview/background, the functions of the BFCC are described as Medical Necessity reviews; however, these reviews are not mentioned in the J-18 B, Business Proposal Forms. Are Medical Necessity Reviews the same as Utilization Reviews as in previous scopes of work? |
| A separate column for this task was not included since this work is a sub-part of the other review categories. |
| 84 |
| BFCC |
| C.7.1 |
| “The BFCC-QIO will be responsible for using the results of all activities to make recommendations to QINs on quality improvement initiatives…” Does this mean that all QI activities will be undertaken by the QIN? |
| No. The BFCC QIO is only responsible for the referral of these QIIs. Subsequent monitoring will be performed by the QIN QIO. |
| 85 |
| BFCC |
| C.7.1 |
| For each state in each of the 5 QIO areas, what are the estimated volumes for each type of review to be performed daily, weekly, each month, quarterly, and/or annually? (The “each month” category is particularly useful if there are season fluctuations.) The volume estimates broken down in each region by state, will be required for estimating staffing levels of physicians in each local jurisdiction. |
| We do not anticipate any significant seasonal fluctuations in case review volumes. The QIO staffing model should be flexible enough to account for quarterly or seasonal fluctuations in volume. |
| 86 |
| BFCC |
| C.7.1 |
| Do the time zone coverage constraints apply to island territories? |
| Yes |
| 87 |
| Specific Tasks |
| C.7.4 |
| Will Memorandums of Understanding be required for all providers as is now the case in the QIO program? |
| Yes. Quality Improvement Organizations (QIOs) are required to develop, implement, and revise MOAs, acceptable to CMS, with certain providers of health services (i.e., Hospitals, Critical Access Hospitals, Skilled Nursing Facilities, Home Health Agencies, and Medicare + Choice Organizations) who wish to participate or continue to participate in the Medicare program, as specified in the contract with the Secretary. It is the provider's responsibility to sign and return the MOA. In all instances, both the QIO and the provider are expected to honor the terms of the agreement. QIOs are not required to develop MOAs with individual practitioners. |
Please see Chapter 3 of the QIO Manual.
| 88 |
| BFCC |
| C.7.4 |
| There are currently 72 steps to performing a QIO quality of care review, which is significantly different and longer than most quality reviews being performed outside of the Medicare program. There are also new regulatory requirements for QIO quality reviews that were published but never instituted. Can you provide a detailed flow process for the quality review process that is to be used in the 11SOW so that we can better understanding staffing ratios? |
| The QIO Manual will be updated prior to the start of the 11th SOW but does not include a significant increase in LOE beyond what the current QIO Manual requires. |
| 89 |
| BFCC |
| C.7.4 |
| The solicitation document directs QIOs to conduct various reviews to establish medical necessity, appropriateness of setting, quality of care, and so forth. What sources of evidence-based criteria and guidelines should offeror’s be guided by in making these determinations? For example, is there a preference among the commercially available criteria sets? |
| CMS does not endorse any specific criteria set. CMS will not require that the QIO use any specific guideline or source. CMS relies on QIOs to determine the best tools. The BFCC QIO is required to use evidence based guidelines in making its case review decisions. |
| 90 |
| BFCC |
| C.7.4 |
| Will CMS make CRIS and QMARS available in a demo or in a reading library for prospective offeror’s to review for bidding purposes? |
| No. |
| 91 |
| BFCC |
| C.7.4 |
| Will all quality of care reviews take place at the contractor’s site or will there be circumstances requiring reviews at a healthcare facility, a beneficiary’s resident, etc. |
| There are no requirements that reviews need to take place at a healthcare facility or beneficiary's resident. |
| 92 |
| BFCC |
| C.7.4 |
| If any of the reviews are to be conducted away from the contractor’s site, for each of the 5 QIO areas, please provide an estimate of the number of cases requiring quality care reviews daily, weekly, each month, quarterly, and/or annually, broken down by site in each state? This information will facilitate estimating travel and labor costs. |
| There are no requirements that reviews will be conducted away from the contractor's site. |
| 93 |
| Specific Tasks and Attachment J 18B Business Proposal Forms BFCC-QIO Contract |
| C.7.4 and J.18B |
| There are twelve specific tasks, but not all the tasks are clearly associated with at least one of the budget categories on the Business Proposal forms and not all of the fifteen review categories (with FIVS codes and annual volumes) are clearly tied to the Business Proposal (Budget Categories), nor do all the review volumes tie to a specific budget category. Please provide a crosswalk between the budget categories, the tasks and the review category volumes and, where applicable, please provide the missing volumes. |
| See Attachment 1 to BFCC-QIO Questions and Answers |
| 94 |
| BFCC |
| C.7.4 |
| Will utilization review criteria (i.e. InterQual/Milliman) be provided to the BFCC QIOs by CMS or will it need to be purchased by the contractors? |
| The purchase of criteria will go through the Remedy process. |
| 95 |
| BFCC |
| C.7.4 |
| The BFCC QIOs will be required to perform medical necessity reviews on all cases reviewed by the QIO. Will these reviews be tracked and counted separately from the original review? |
| Medical necessity reviews shall be performed on all cases and will not be counted separately. |
| 96 |
| BFCC |
| C.7.4 |
| Do the standard work hours for staffing the BFCC-QIO which are specified in Section C.7.1 apply to the acceptance of appeals 7 days per week, 24 hours per day? That is, before and after hours appeals must be accepted through a mechanism that does not require staffing with BFCC-QIO personnel during these periods provided that all voice mails are followed up within one calendar day? |
| That is correct. The acceptance of appeals before and after hours does not require staffing of personnel. |
| 97 |
| BFCC |
| C.7.4 |
| Will encoder software (i.e. 3M/QuadraMed) be provided to the BFCC QIOs by CMS or will it need to be purchased by the contractors? |
| The encoder software will continue to be purchased by the BFCC-QIO contractor. |
| 98 |
| BFCC |
| C.7.4 |
| Will Coding Clinic be provided to the BFCC QIOs by CMS or will it need to be purchased by the contractor? |
| The quarterly Coding Clinic is received from AHA as a complimentary copy. It is posted to QIONet when it is received and the QIOs are notified via memo. |
| 99 |
| BFCC |
| C.7.4 |
| This task states that “medical necessity review shall be conducted on all cases reviewed by the BFCC-QIO for any purpose, unless otherwise directed by CMS. The BFCC-QIO shall undertake medical necessity reviews in accordance with the appropriate chapter of the QIO Manual.” Currently, QIOs performs medical necessity reviews only for acute care hospital settings. Will there be any non-hospital settings for which the BFCC-QIO will conduct medical necessity reviews? |
| Yes, medical necessity reviews will be conducted in all settings. |
| 100 |
| BFCC |
| C.7.4 |
| What are the anticipated volumes for Medical Necessity Reviews? |
| Please refer to Attachment J-23. |
| 101 |
| BFCC |
| C.7.4 |
| Sections a. and b. state that for FFS and Medicare Advantage readmission claims, “[t]he BFCC-QIO shall review a sampling of readmission claims, as directed by CMS.” Will the sampling of cases be on a routine, e.g., monthly/quarterly basis, or will it be on an as needed basis? |
| This will be on an as needed basis. |
| 102 |
| BFCC |
| C.7.4 |
| Sections a. and b. state that for FFS and Medicare Advantage readmission claims, “[t]he BFCC-QIO shall review a sampling of readmission claims, as directed by CMS.” How will the BFCC-QIO be notified of the sampling? |
| The mechanism through which BFCC-QIOs will be notified of readmission review sampling is to be determined and will involve the CO/COR. |
| 103 |
| BFCC |
| C.7.4 |
| Sections a. and b. state that for FFS and Medicare Advantage readmission claims, “The BFCC-QIO shall review a sampling of readmission claims, as directed by CMS.” Is there historical information available regarding potential volumes for these reviews? |
| Please refer to Attachment J-23. |
| 104 |
| BFCC |
| C.7.4 |
| With respect to Task 4: Higher Weighted Diagnosis-Related Group (HWDRG) Reviews, what does CMS anticipate the volume of readmission reviews to be for the 11th Statement of Work? |
| Please refer to Attachment J-23. However, this volume can vary depending on the number of claims in which hospitals request a higher weighted DRG payment. |
| 105 |
| BFCC |
| C.7.4 |
| Will memorandums of agreement be required per contract or another timeframe? |
| MOAs will be required per contract, unless terms of contract change. |
| 106 |
| BFCC |
| C.7.4 |
| Will we need to execute joint operating agreements with QINs, VIQRCs, IECs, etc.? |
| Yes. |
| 107 |
| BFCC |
| C.7.4 |
| Is there a minimum/maximum number of reviews CMS will direct each region to perform? |
| No. |
| 108 |
| BFCC |
| C.7.4 |
| The BFCC QIO is directed to “recommend QI Activities” to the QIN. Task 8 directs the BFCC QIO to carry out Sanction activities as a result of case review. Please clarify. |
| BFCC-QIOs will refer and recommend providers/practitioners to QIN-QIOs for technical assistance with QII. Any action related to Sanction activities will be carried out by the BFCC-QIO. |
| 109 |
| BFCC |
| C.7.4 |
| What is the anticipated volume per region? |
| Please refer to Attachment J-17. |
| 110 |
| BFCC |
| C.7.4 |
| Section b. indicates, “[t]he BFCC-QIO must provide recommendations and referrals to QIN-QIOs or other CMS-designated contractor for technical assistance….” Will the QIN-QIOs be handling all of the follow-up with practitioners/providers who have confirmed concerns resulting from QIO reviews? |
| The QIN-QIOs will handle all follow-up activity with those practitioners/providers who have been referred for technical assistance with QII. |
| 111 |
| BFCC |
| C.7.4 |
| This task states the BFCC-QIO must make recommendations to the QIN-QIO for QIIs associated with quality of care issues. The task goes on to state that the BFCC-QIO will coordinate these recommendations through the BFCC-NCC before being communicated to the QIN-QIO. Will the BFCC-QIO be responsible for performing any quality improvement initiatives for confirmed concerns identified during a quality of care review? |
| The BFCC-QIOs will refer providers/practitioners to the QIN-QIOs. Quality improvement initiatives will be conducted by the QIN-QIOs. |
| 112 |
| BFCC |
| C.7.4 |
| If the QIN-QIO will be responsible for the QIIs, will the BFCC-QIO be required to report/refer every confirmed concern to the BFCC-NCC for follow up by the QIN-QIO? |
| No. |
| 113 |
| BFCC |
| C.7.4 |
| How will QIIs currently in process under the incumbent QIO be handled? Will they be transferred to the QIN-QIO? |
| This will need to be addressed in the transition plan and handled on a case-by-case basis in collaboration with the BFCC-QIO and the QIN-QIO. |
| 114 |
| BFCC |
| C.7.4 |
| Regarding this task, Deliverable D.3 states the BFCC-QIO will report its recommendations and referrals to the QIN-QIO quarterly. Does this mean quality improvement initiatives for providers with a confirmed concern will not be initiated concurrently (following the final quality determination)? |
| It is anticipated that the BFCC-QIO will include in their final quality determination letter that the provider/practitioner is being referred to the QIN-QIO for assistance with quality improvement initiatives. |
| 115 |
| BFCC |
| C.7.4 |
| After the BFCC refers a confirmed concern to the QIN/QIO for a QII, can the QIN/QIO change the recommendation that the provider/practitioner no longer requires a QII? |
| It is expected that this decision will be in collaboration between the QIN-QIO and the BFCC-QIO. This decision must be supported and documented in the QII system that is being developed. |
| 116 |
| BFCC |
| C.7.4 |
| After referral and proper communication with the QIN/QIO, should the BFCC budget for any additional communication/tasks with the QIN/QIO regarding the initial QII referral? |
| No, however it is expected that the BFCC-QIO and the QIN-QIO collaborate as necessary. |
| 117 |
| BFCC |
| C.7.4 |
| How often is the BFCC required to initiate MOAs with providers? |
| MOAs will be required per contract, unless terms of contract change. Please refer to Chapter 3 of the QIO Manual. |
| 118 |
| BFCC |
| C.7.4 |
| The MOA process is a significant start-up cost. What is the number of MOAs for which offeror’s should budget for each BFCC-QIO area (including per state)? |
| Quality Improvement Organizations (QIOs) are required to develop, implement, and revise MOAs, acceptable to CMS, with certain providers of health services (i.e., Hospitals, Critical Access Hospitals, Skilled Nursing Facilities, Home Health Agencies, and Medicare + Choice Organizations) who wish to participate or continue to participate in the Medicare program, as specified in the contract with the Secretary. It is the provider's responsibility to sign and return the MOA. In all instances, both the QIO and the provider are expected to honor the terms of the agreement. QIOs are not required to develop MOAs with individual practitioners. |
| 119 |
| BFCC |
| C.7.4 |
| Should offeror’s include the costs for establishing Memorandums of Agreement with providers (hospitals, home health agencies, nursing homes) under non-review activities? |
| Yes. |
| 120 |
| BFCC |
| C.7.4 |
| Task 8: Sanction Activities requires the BFCC-QIO to carry out sanction and sanction-related activities and Task 9: Recommendations for Quality Improvement Initiatives and Technical Assistance requires the BFCC-QIO to recommend quality improvement initiatives to the QIN-QIO. Can you please clarify the BFCC-QIO’s obligations under Task 8 and Task 9 and how these requirements relate to each other? |
| BFCC-QIOs will refer and recommend providers/practitioners to QIN-QIOs for technical assistance with QII. Any action related to Sanction activities will be carried out by the BFCC-QIO. |
| 121 |
| BFCC |
| C.7.4 |
| With respect to Task 9: Recommendations for Quality Improvement Initiatives and Technical Assistance and Task 10: General Tasks, please clarify the BFCC-QIO’s obligations with respect to conducting trend and pattern analysis and communicating the same to the applicable QIN-QIO. |
| It is expected that BFCC-QIO will be able to identify when a trend or pattern with confirmed quality of care concerns occurs, either a pattern with a specific provider or a trend in the nature of confirmed quality of care concerns, for example, a trend in concerns related to pressure ulcers. |
| 122 |
| BFCC |
| C.7.4 |
| The solicitation document directs QIOs to help identify and document “evidence based standards of care.” Can you elaborate on your definition of “evidence based”? For example, in determining such standards of care, what evidence hierarchy should offeror’s be guided by? Where do consensus-based best practices rank compared to guidance based on randomized controlled trials? |
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