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HHSM-500-2014-RFP-QIN-QIO
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Amendment 0003 Technical Q A's

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HHSM-500-2014-RFP-QIN-QIO

Amendment 0003 Responses to Solicitation Questions

No.
Section
Section Number & Title
Question
Answer
1
Base Contract, Section B
B.2 QIO Program Structure and Requirements
Where will the majority of the national level data analysis take place, at the QIN-QIO NCC level or with the Program Collaboration Center?
The majority of the national-level data analyses will take place with the QIN-NCC.
2
Base Contract, Section B
B.2 QIO Program Structure and Requirements
In its role as a resource to BFCC-QIOs, a QIN-QIO may be called on to make recommendations for evidence-based tools to be used in performance of various reviews (for example, appropriateness of setting, medical necessity, and readmission reviews). How should QIN-QIOs determine which tools to recommend? Is there a preference among the commercially available criteria sets?
The QIN-QIO may choose its own solution for culling evidence-based guidelines, provided that the technical assistance the QIO provides to its clinical partners is vendor neutral (i.e., it does not appear to endorse the products of any particular guideline publisher).
3
Base Contract, Section B
B.2 QIO Program Structure and Requirements
As it relates to representatives for the healthcare provider and consumer, are there any other specific requirements for those representatives to be declared acceptable representatives?
CMS does not have any other specific requirements.
4
Base Contract, Section B
B.3 QIN-QIO Contract Limitations
With regard to the BFCC and the transition of review cases:

a) Will quality improvement activities fall to the QIN QIOs’ responsibilities and be handed off from the BFCC case review entity, or will the QINs simply be a resource for assistance to providers in developing QIAs?

b) Will the ongoing quality of care complaint/HWDRG cases be taken over by the BFCC entity mid-stream?

c) Should we continue requesting quality improvement plans as a result of confirmed quality of care concerns and expect to transition those cases to the new BFCC entity?

These details will need to be addressed and agreed upon as part of the transition plan in collaboration with the QIN-QIO and BFCC-QIO.

5
Base Contract, Section B
B.3 QIN-QIO Contract Limitations
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”?
QIOs are defined in the regulation at 42 CFR 475.
6
Base Contract, Section C
C.2. Background and Overview
How does CMS define “professionally recognized standards of care”?
“Professionally recognized standards of health care” are state-wide or national standards of care issued broadly, either in writing or otherwise, and which are recognized by local peers as being applicable to the care contexts and settings within a particular QIO area or state.
7
Base Contract, Section C
C.3.2 Information Technology Architecture
It is not obvious how the requirements in this section advance the purpose of the contract as stated in section C.1. If they are essential to the purpose of the contract, please explain, so that Offerors can assure fully aligning with Government requirements. If they are not essential to fulfilling the purpose of the contract, would CMS accept alternative proposals that meet security and confidentiality requirements of the Government at lower cost than the specified hardware and software? Specifically, may an offeror that is already FISMA compliant provide its own hardware and software, receiving reimbursement for this service under the contract, instead of using the Government-provided solution, if doing so would reduce costs to the Government?
Any work requiring access to the CMS infrastructure will need to be performed on Government Furnished Equipment (GFE). FISMA responsibilities are shared between the awarded contractor and infrastructure contractor. Corporate-owned equipment shall not be used to access secure HCQIS resources.
8
Base Contract, Section C
C.3.2.1 Hardware/Software
Since this SOW is a 5-year contract, it is assumed that there will be a hardware/software refresh at some point, especially for those QIOs that were successful in maintaining their contracts. QIOs do not have control over the refresh cycle, and as such, it is difficult to adequately plan or fund for the refresh. Should the QIO anticipate a hardware/software refresh during the 11th SOW? If so, should the QIO include the estimated cost for a refresh as part of the IT proposal?
CMS will fund the refresh ONLY for the CORE equipment that was provided as part of the base contract, as alluded to in Section C.3.2.1 of the base SOW, and as detailed in Section J, Attachment J.16, HCQIS QIO Basic IT Configuration Baseline. If a QIN procures any additional hardware such as laptops/workstations outside of the CORE equipment, the QIN will need to fund its own refresh of those items.
9
Base Contract, Section C
C.3.2.1 Hardware/Software
Is it a correct assumption that equipment needed above and beyond what will be supplied should be budgeted for in the business proposal?
Yes. The offeror shall propose equipment needed beyond that CORE equipment alluded to in Section C.3.2.1 of the base SOW, and as detailed in Section J, Attachment J.16, HCQIS QIO Basic IT Configuration Baseline.
10
Base Contract, Section C
C.3.2.1 Hardware/Software
Will the print/server, domain controller, database server, network/telecom equipment be provided on a state level basis?
See the revisions to Section C.3.2.1, Hardware/Software, of the base contract SOW.
11
Base Contract, Section C
C.3.2.1 Hardware/Software
The base contract SOW section, Equipment and Property, states, “If additional equipment must be acquired, you must include in your business proposal the description and estimated cost of each item and whether you propose to furnish the item with your own funds. As per the RFP, this is a Government Furnished Equipment. Further, under Hardware/Software Section it is also stated: “Please note that this listing in not an all-inclusive list and should be used to identify basic IT needs and current associated costs for a startup office. The list and pricing identified should be used for budgeting purposes only as they are subject to change.” Please provide additional guidance as to what is considered GFE and what would be outside of the essential equipment for startup office costs.
See the revisions to Section C.3.2.1, Hardware/Software, of the base contract SOW.
12
Base Contract, Section C
C.3.2.1 Hardware/Software
Question: Anticipating an office in each state within a QIN-QIO service area primarily dedicated to serving the need of the QIN/QIO contract. Will each office, regardless of whether it is serving in the capacity of a Prime or Subcontractor, be provided a file/print server, a domain controller, a database server, network/telecom equipment for the data for that state area? Or does the subcontractor need to include the cost in its proposal?

Question: Will each office described above be provided access to the SDPS/HCQIS WAN to conduct contract activities?

The prime contractor shall have access to hardware/software at the CORE primary location only. If the prime contractor chooses to locate its operations in more than one physical space, or to engage subcontractors, those additional locations will need to be maintained and funded separately. For more details, see revisions to Section C.3.2.1, Hardware/Software, of the base contract SOW.

13
Base Contract, Section C
C.3.2.1 Hardware/Software
For 10SOW incumbent QIOs, will all IT resources be new/refreshed, or will current resources be utilized?
If current QIOs are awarded one or more QIN-QIO contracts, the current resources will be utilized based on assessment of IT needs for the 11th SOW.
14
Base Contract, Section C
C.3.2.1 Hardware/Software
Will there be method for requesting VPN access for groups of people (e.g., the Offeror’s nursing home team) to enable broader field interaction with stakeholders and program participants?
Yes. CMS has a process for requesting HCQIS VPN access, which will be available to successful offerors through the QIOnet system once QIN-QIO contract awards are made.
15
Base Contract, Section C
C.3.2.1 Hardware/Software
Will CMS provide a file/print server, a domain controller, a database server, and network/telecomm equipment for each IDIQ, each task order, or for each physical location?
CMS will fund the refresh ONLY for the CORE equipment that was provided as part of the base contract, as alluded to in Section C.3.2.1 of the base SOW, and as detailed in Section J, Attachment J.16, HCQIS QIO Basic IT Configuration Baseline. If a QIN procures any additional hardware such as laptops/workstations outside of the CORE equipment, the QIN will need to fund its own refresh of those items.
16
Base Contract, Section C
C.3.2.1 Hardware/Software
Relative to the potential partnership plans (Prime contractor, partnership, etc.) does CMS expect to deliver hardware and software to one location per IDIQ or will equipment be distributed to each task order location or physical location?
CMS will fund the refresh ONLY for the CORE equipment that was provided as part of the base contract, as alluded to in Section C.3.2.1 of the base SOW, and as detailed in Section J, Attachment J.16, HCQIS QIO Basic IT Configuration Baseline. If a QIN procures any additional hardware such as laptops/workstations outside of the CORE equipment, the QIN will need to fund its own refresh of those items.
17
Base Contract, Section C
C.3.2.1 Hardware/Software
Is the intent of the structure of this contract to create more home-based or remote access network users? If so, has CMS made network and support provisions for an increased number of VPN users?
CMS is prepared to support the VPN growth for the 11th SOW.
18
Base Contract, Section C
C.3.2.1 Hardware/Software
Relative to a prime-sub partnership plan, can you explain how FISMA audits will be conducted using the new contract structure? Additionally, can you explain how the inventory procedure will work for a partnership spread over multiple states?
FISMA audits may be conducted at any site acting as a primary or sub to the main contract. All prime QIN-QIO contractors must maintain their inventories in Remedy to allow for proper tracking of all GFE.
19
Base Contract, Section C
C.3.2.1 Hardware/Software
Should each location budget for a separate fax solution or can one solution be used for all the awarded locations?
It is up to the QIN to determine how the organization wants to set up its FAX solution.
20
Base Contract, Section C
C.3.2.1 Hardware/Software
Will equipment such as network printers, server rack with console and Uninterruptible Power Source (UPS) listed in attachment J.16 be considered as a ‘base need’ and funded by CMS?
See revised Section C.3.2.1, Hardware/Software, of the base contract SOW.
21
Base Contract, Section C
C.3.2.1 Hardware/Software
How should an organization budget for equipment (hardware) to account for the inevitable event that some pieces of equipment will not last the term of the contract?
QIN-QIOs may wish to set up an IT-related line item as part of the budget for your projects.
22
Base Contract, Section C
C.3.2.1 Hardware/Software
If the amount of hardware/software being provided will be dependent on the agreement between CMS and the contractor based on the work identified, how can a proposed budget be calculated?
The contractor should be able to identify the amount of resources (e.g., personnel) that will be needed to support the contract. From that, determine what the IT costs should be to support these resources (printers, Faxes, etc.). See revised Section C.3.2.1, Hardware/Software, of the base contract SOW for more information about the types of equipment the QIN-QIO should plan to procure. Keep in mind that CMS will fund only one primary CORE physical location per QIN-QIO.
23
Base Contract, Section C
C.3.2.1 Hardware/Software
For current QIO contractors that become subcontractors of a prime QIN-QIO, these will no longer be direct CMS contractors. Will they be allowed to keep their CMS/SDPS-provided IT server?
This depends on the needs of the primary contractor. If current QIOs are awarded one or more QIN-QIO contracts, the current resources will be utilized based on assessment of IT needs for the 11th SOW.
24
Base Contract, Section C
C.3.2.1 Hardware/Software
Assuming CMS officials will primarily interact with the prime/awarded QIN-QIO, will CMS IT/Data systems only send data to the QIN-QIO which would be responsible to get data to each state assuming there is a mechanism for states to receive the data?
Connectivity and data requirements will be outlined as part of the QIN-QIO contract review prior to award.
25
Base Contract, Section C
C.3.2.1 Hardware/Software
Will CMS IT systems only grant access to CMS databases such as CASPER or Clinical Data Warehouse to the prime QIN-QIO or will subcontractors or “local presence” entities have a mechanism to gain access to CMS databases?
CMS will provide direct access to CMS resources to the primary contractor. Subcontractor access will be evaluated based upon each QIN primary contract award.
26
Base Contract, Section C
C.3.2.1 Hardware/Software
Can we assume that a current entity that loses QIO status (such as becoming a subcontractor to a prime QIN-QIO) but also holds or gains other contracts of its own with CMS (for example a QIN-QIO NCC or a special project with CMS) will continue to act independently from the QIN-QIO prime with regard to its other CMS contracts?
Yes.
27
Base Contract, Section C
C.3.2.1 Hardware/Software
Assuming there is a state-level “local presence” site, are they required to have equipment hosted on premise, and, if so, will there be mechanisms in place to accommodate a common WAN infrastructure between the local site and the Prime QIN-QIO?
The connectivity of satellite offices to the HCQIS Network will depend on the requirements each QIN-QIO has. Offerors should submit information about how they could keep satellite offices interconnected as part of their proposal responses for CMS review and consideration.
28
Base Contract, Section C
C.3.2.1 Hardware/Software
Current HCQIS infrastructure is sized to accommodate a single state QIO presence. Will equipment with larger capacities be provided to accommodate aggregation of multiple state regions?
This depends on the needs of the primary contractor. If current QIOs are awarded one or more QIN-QIO contracts, the current resources will be utilized based on assessment of IT needs for the 11th SOW.
29
Base Contract, Section C
C.3.2.1 Hardware/Software
Assuming there is a state-level “local presence” site will these sites require a file/print server, domain controller, DB server and telco-equipment?
As C.3.2.1 of the base contract SOW, states, QIN-QIOs may expect CMS funding ONLY for the CORE equipment listed in the solicitation, as well as only in the primary location of the contractor. However, -because other (non-primary) locations may need connectivity to the HCQIS Network, the QIN-QIO will need to determine its requirements for inter-connectivity and how it plans to accomplish this connectivity. This detail shall be submitted within the technical and business proposals for CMS review and consideration.
30
Base Contract, Section C
C.3.2.1 Hardware/Software
Regarding acquiring equipment, if an existing QIO is awarded the QIN-QIO and/or an existing QIO is a local-presence subcontractor to an awarded QIN-QIO, will the primary QIN-QIO contractor be the entity required to procure equipment? Will all new equipment be provided or will current equipment remain within respective entity organizations and just be transferred?
This depends on the needs of the primary contractor. If current QIOs are awarded one or more QIN-QIO contracts, the current resources will be utilized based on assessment of IT needs for the 11th SOW and as they compare with the core equipment furnished under this contract as stipulated in Section C.3.2.1 of the base contract SOW.
31
Base Contract, Section C
C.3.2.1 Hardware/Software
This section states that CMS either directly or through a CMS contractor, shall provide each QIN-QIO with certain equipment list. Are QINs to put these projected expenses in our cost proposals?
See revised Section C.3.2.1, Hardware/Software, of the base contract SOW.
32
Base Contract, Section C
C.3.3.1 Certification by Security Point of Contact (SPOC) for Compliance with CMS Security Requirements
Will eligible bidders need to be FISMA compliant to enter into negotiations with the government, or rather, fully FISMA compliant by the contract start date on August 1st?
To meet CMS Acceptable Risk Safeguard Controls, the contractor shall be fully FISMA compliant as of the start of the QIN-QIO work on August 1, 2014. (For the CMS Acceptable Risk Safeguard Controls, see the "ARS" entry in the CMS Information Security Library, as referenced in Section C.3.3.3.1 of the base contract SOW, as well as in Section J, Attachment J.2, Items Incorporated by Reference.)
33
Base Contract, Section C
C.3.3.1 Certification by Security Point of Contact (SPOC) for Compliance with CMS Security Requirements
For a joint venture of multiple QIOs, will each of the subcontract QIOs be subject to a FISMA audit or just the IDIQ umbrella entity?
Any part of the base contract is subject to audit. This may also include subcontract locations that hold/store CMS IT data systems (servers/databases, etc.).
34
Base Contract, Section C
C.3.3.1 Certification by Security Point of Contact (SPOC) for Compliance with CMS Security Requirements
Prior FISMA audits identified deficiencies in the QIOs infrastructure, which requires monetary funding to mitigate (e.g., a fire suppression system for a server room). The QIO was told by CMS not to pursue mitigating the deficiencies as CMS was determining how to fund the items. How should the QIO address these items with the 11th SOW? Should the QIO request funding as part of the proposal, or is CMS going to provide funding as part of the CORE setup?
There are no plans at this time for CMS to appropriate funds for FISMA deficiencies for the 11th SOW. The QIN shall be FISMA compliant per CMS' Acceptable Risk Safeguards for all controls that fall within the responsibility of the QIN. For specifics on how to address fire suppression specifically, please refer to the CMS Acceptable Risk Safeguards for Moderate level systems document (control PE-13). (For the CMS Acceptable Risk Safeguard Controls, see the "ARS" entry in the CMS Information Security Library, as referenced in Section C.3.3.3.1 of the base contract SOW, as well as in Section J, Attachment J.2, Items Incorporated by Reference.)
35
Base Contract, Section C
C.3.3.1 Certification by Security Point of Contact (SPOC) for Compliance with CMS Security Requirements
With the requirement to be FISMA compliant, becoming FISMA compliant and maintaining that status requires a significant amount of manpower. Will the Level of Effort attachment address the manpower and resources required to be FISMA complaint? If not, will CMS provide an estimated cost for FISMA compliance? Should the contractor include the estimated resource costs for FISMA compliance in the IT proposal?
Each awarded contract requires at least 1 primary and 1 backup Security Officer or Security Point of Contact (SPOC) to oversee all security compliance. Security Officer resources may be included with other IT workloads and resources.
36
Base Contract, Section C
C.3.3.1 Certification by Security Point of Contact (SPOC) for Compliance with CMS Security Requirements
The current System Security Plan (SSP) includes a Risk Assessment section. Is the new requirement to provide an SSP and a separate Risk Assessment?
The Risk Assessment (RA) may be added as an appendix to the System Security Plan (SSP).
37
Base Contract, Section C
C.3.3.1 Certification by Security Point of Contact (SPOC) for Compliance with CMS Security Requirements
h.3. QNET Security Awareness Training (SAT) and Certification Letter. Is SAT actually a Deliverable or is it a Requirement Milestone? Or is the Certification Letter the Deliverable.
The Security Awareness Training (SAT) is a required milestone to be completed before users are given access to the HCQIS IT/Network resources. In addition, SAT shall be completed for all users on an annual basis. The certification letter is the deliverable attesting that all users have completed the annual training.
38
Base Contract, Section C
C.3.3.1 Certification by Security Point of Contact (SPOC) for Compliance with CMS Security Requirements
Is the Offeror expected to have resolved prior-identified FISMA deficiencies that were marked as requiring funding to complete?
To meet CMS Acceptable Risk Safeguard Controls, the contractor shall be fully FISMA compliant as of the start of the QIN-QIO work on August 1, 2014. (For the CMS Acceptable Risk Safeguard Controls, see the "ARS" entry in the CMS Information Security Library, as referenced in Section C.3.3.3.1 of the base contract SOW, as well as in Section J, Attachment J.2, Items Incorporated by Reference.)
39
Base Contract, Section C
C.3.3.1 Certification by Security Point of Contact (SPOC) for Compliance with CMS Security Requirements
Is it the intent of CMS to fund previously unfunded FISMA compliance requirements, (e.g. security cameras, key-card access, advanced fire-protection for server rooms) to transfer the cost to the QIO’s or to continue to operate with those items unfunded and non-compliant?
To meet CMS Acceptable Risk Safeguard Controls, the contractor shall be fully FISMA compliant as of the start of the QIN-QIO work on August 1, 2014. (For the CMS Acceptable Risk Safeguard Controls, see the "ARS" entry in the CMS Information Security Library, as referenced in Section C.3.3.3.1 of the base contract SOW, as well as in Section J, Attachment J.2, Items Incorporated by Reference.)
40
Base Contract, Section C
C.3.3.1 Certification by Security Point of Contact (SPOC) for Compliance with CMS Security Requirements
Will there be a requirement for a SPOC and or any additional IT Staff at each office location or can they be centralized in a single office?
SPOCs may be centralized in a single location--additional SPOCs may be named for secondary/satellite locations, but this is not a requirement. Please note that each awarded contract requires at least 1 primary and 1 backup Security Officer or Security Point of Contact (SPOC) to oversee all security compliance. Security Officer resources may be included with other IT workloads and resources.
41
Base Contract, Section C
C.3.3.1 Certification by Security Point of Contact (SPOC) for Compliance with CMS Security Requirements
Will each state be required to maintain separate documentation or will master plan maintained by prime contractor be sufficient?
Documentation will be required and maintained by the prime contractor. The documentation and master plans must present all FISMA-related information that falls within all states in the QIN-QIO area, as well as the operations of any subcontractors. It is also important to note that both prime and sub-contractors are subject to FISMA auditing.
42
Base Contract, Section C
C.3.3.1 Certification by Security Point of Contact (SPOC) for Compliance with CMS Security Requirements
What FISMA assurance Level will QIN-QIO’s be classified? Currently they are moderate risk. Will this be adjusted to minimum risk?
CMS will determine risk level after the contract is awarded. For the purposes of responding to the solicitation, offerors should assume that the assurance level will be moderate. Section G.33 of the solicitation, Security Clause - Background Investigations for Contractor Personnel, has been amended accordingly.
43
Base Contract, Section C
C.3.3.1 Certification by Security Point of Contact (SPOC) for Compliance with CMS Security Requirements
If the Prime QIN-QIO subcontracts with entities within a state to carry out local-presence work, will each location be required to maintain separate FISMA related documentation and audits?
Documentation will be required and maintained by the prime contractor. The documentation and master plans must present all FISMA-related information that falls within all states in the QIN-QIO area, as well as the operations of any subcontractors. It is also important to note that both prime and sub-contractors are subject to FISMA auditing.
44
Base Contract, Section C
C.3.3.1 Certification by Security Point of Contact (SPOC) for Compliance with CMS Security Requirements
If the Prime QIN-QIO subcontracts with entities within a state to carry out local-presence work, will each subcontractor be required to complete FISMA audit or will each subcontractor be required to attest to compliance independently?
Documentation will be required and maintained by the prime contractor. The documentation and master plans must present all FISMA-related information that falls within all states in the QIN-QIO area, as well as the operations of any subcontractors. It is also important to note that both prime and sub-contractors are subject to FISMA auditing.
45
Base Contract, Section C
C.3.3.1 Certification by Security Point of Contact (SPOC) for Compliance with CMS Security Requirements
Will CMS be conducting FISMA audits or will the primary QIN-QIO contractor be responsible for arranging for and funding this on their own?
CMS may conduct an ad-hoc FISMA audits at any time. It is up to the QIN-QIO to assure that it is meeting CMS Acceptable Risk Safeguards at all times. (For the CMS Acceptable Risk Safeguard Controls, see the "ARS" entry in the CMS Information Security Library, as referenced in Section C.3.3.3.1 of the base contract SOW, as well as in Section J, Attachment J.2, Items Incorporated by Reference.)
46
Base Contract, Section C
C.3.3.1 Certification by Security Point of Contact (SPOC) for Compliance with CMS Security Requirements
Regarding point 4) Corrective Action Plans (CAP), will entities for which CAP findings require special funding be required to include CAP costs with new contract bid or will supplemental funding be provided post contract award?
There are no plans at this time for CMS to appropriate funds for FISMA deficiencies for the 11th SOW. The QIN shall be FISMA compliant per CMS's Acceptable Risk Safeguards for all controls that fall within the responsibility of the QIN. (For the CMS Acceptable Risk Safeguard Controls, see the "ARS" entry in the CMS Information Security Library, as referenced in Section C.3.3.3.1 of the base contract SOW, as well as in Section J, Attachment J.2, Items Incorporated by Reference.)
47
Base Contract, Section C
C.3.3.2 Transition of Equipment
Will equipment in a transitioning QIO be utilized by the contract winner for the new SOW?
Yes. If current QIOs are awarded one or more QIN-QIO contracts, the current resources will be utilized based on assessment of IT needs for the 11th SOW.
48
Base Contract, Section C
C.4 General Requirements
Must the QIN-QIO (IDIQ) proposal (Volume I) provide evidence of the contractor's ability to comply with all of the requirements set forth in C.3 and C.4? If so please provide examples of appropriate “evidence.”
Details relating to the expected content of Volume I of the proposal are outlined in Section L.14, Volume I: Multi-state Technical Proposal. The process CMS will use to evaluate Volume I is outlined in Section M.3.1, 1. Evaluation Criteria for the Phase I: Multi-State Proposal of the solicitation. The technical considerations and general requirements outlined in Sections C.3 and C.4 of the base contract SOW serve to inform QIN-QIOs of the universally applicable requirements and policies that govern all of their work. For instance, C.4.6 outlines the processes, policies, and requirements QIOs must satisfy as they communicate internally and externally in order to accomplish the specific tasks in the QIN-QIO task orders. As such, any technical approach proposed for the entire contract--whether the multi-state approach in Volume I or the state-specific approach in Volume II--must conform to the policies outlined in C.3 and C.4 to be deemed technically acceptable.
49
Base Contract, Section C
C.4 General Requirements
How will the Technical Considerations and General Requirements outlined in Sections C.3 and C.4 be budgeted for Volume I? For example, Item a. in C.4.6 indicates that the QIN-QIO will create or update a website. Would this (and all the other tasks described in C.3 and C.4) be budgeted as part of Task Order 001?
Yes. In line with the guidelines governing the administration of Indefinite Delivery/Indefinite Quantity (ID/IQ) contracts, all work billable for QIN-QIO effort is charged to the task order, not to the base contract. In many cases, a 1:1 relationship does not exist between a requirement outlined in C.4 and a task in the task order. For instance, C.4.6 states guidelines for QIN-QIO websites. The task order incorporates references to websites throughout, rather than in a single website-focused task. (See E.1.1 as an example.)
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Base Contract, Section C
C.4.1 General Reporting Requirements
…QIN-QIO(s) will provide these data and/or deliverables to their COR and GTL through MyQualityNet; or e-mail; or via hardcopy; as directed by CMS. Should this be a Deliverable in Attachment J.1 (a)?
The language at C.4.1 is part of the base SOW of the ID/IQ, not the task order. See J-1(a), the attachment to Task Order 001, for a list of deliverables.
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Base Contract, Section C
C.4.2 Confidentiality
Will QINs be considered “Health Oversight Entities” per CMS direction in a memo to hospitals dated March 20, 2003?
CMS will provide guidance to offerors and QIN-QIOs about the applicability of the HIPAA Privacy Rule to QIN-QIO work at a later date.
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Base Contract, Section C
C.4.3 Government Data
In the processing and sharing of CMS data with entities outside of the QIO program environment, what determines an external entity (i.e., an academic health science center) from a key stakeholder (i.e., state or local department of health or an ADRC)? Is the standard DUA processing through Remedy system required in both scenarios?
CMS will provide guidance to offerors and QIN-QIOs about this issue at a later date.
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Base Contract, Section C
C.4.3.1 Data Use Agreements
It is stated in this section that a Data Use Agreement (DUA) is required between the QIO and any external entity that is used if the external entity requests and receives personal identifiable information (PII) data. What if the data also includes protected health information (PHI)? Does there need to be a Business Associate Agreement between the QIO and the external entity along with the DUA?
Yes, data that includes Protected Health Information (PHI) would require the development of a Business Associate Agreement between the QIO and the external entity, should the QIO data manager determine that the data is release-able to the external entity (see Section J, Attachment J.6a., Data Use Agreement). The DUA shall include all external entities receiving data.
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Base Contract, Section C
C.4.3.1 Data Use Agreements
Will DUAs be required between the QIN-QIO region primary contractor and any entities with which the QIN-QIO subcontracts to do state-based/local work?
CMS will discuss this issue after contract award.
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Base Contract, Section C
C.4.4 Clinical Data Abstraction Center Subcontract
Should CMS directed subcontracts (e.g., CDACs) be proposed and priced in the business proposals or should they be excluded for costs and pricing?
The CDAC contractor is responsible for paying for the clinical data abstraction and records management costs for services outlined in Section C.4.4.
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Base Contract, Section C
C.4.4 Clinical Data Abstraction Center Subcontract
Could you provide an example of the circumstances in which a CDAC would provide medical records to the QIN?
The CDAC contractor is responsible for paying for the clinical data abstraction and records management costs for services outlined in Section C.4.4.
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Base Contract, Section C
C.4.4 Clinical Data Abstraction Center Subcontract
This requirement seems unsuited to the QIN-QIO contract, as there is nothing in the RFP that requires QIN-QIOs to use abstraction services. Is this actually a BFCC-QIO requirement? If not, please explain why it is needed so that we may address it in our proposal.
Although a rare incident, the CDAC may provide medical record abstraction services to a QIN-QIO for specific quality improvement activities (e.g. Task E of the task order).
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Base Contract, Section C
C.4.4 Clinical Data Abstraction Center Subcontract
Should CMS directed subcontracts (e.g., CDACs) be proposed and priced in the business proposals or should they be excluded for costs and pricing?
The CDAC contractor is responsible for paying for the clinical data abstraction and records management costs for services outlined in Section C.4.4.
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Base Contract, Section C
C.4.4 Clinical Data Abstraction Center Subcontract
The CDAC function relates to hospital data reporting, which appears to be moved from the QIO-QIN contract to a yet to be released series of VIQRC contracts. Please confirm that this section is still appropriate to the QIO-QIN contract.
The CDAC contractor is responsible for paying for the clinical data abstraction and records management costs for services outlined in Section C.4.4.
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Base Contract, Section C
C.4.4 Clinical Data Abstraction Center Subcontract
The CDAC function relates to hospital data reporting, which appears to be moved from the QIO-QIN contract to a yet to be released series of VIQRC contracts. Please confirm that this section is still appropriate to the QIO-QIN contract.
The CDAC contractor is responsible for paying for the clinical data abstraction and records management costs for services outlined in Section C.4.4.
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Base Contract, Section C
C.4.4 Clinical Data Abstraction Center Subcontract
Can CMS provide contact information for the 11th SOW CDAC if we are interested in a records management subcontract?
Yes, CMS will provide more information to QIN-QIOs about the CDAC after contract award.
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Base Contract, Section C
C.4.5 Coordination with Stakeholders Outside the QIO Program
The QIN-QIO is required in its Continuity of Operations Plan (COOP) and Contingency Plan (CP) to include “how the QIN-QIO plans to include subcontracts with another BFCC QIO in order to maintain continuity of reviews and appeals during emergency situations, if the QIN-QIO so chooses.” If the QIN-QIO cannot conduct review and appeal services due to potential conflict of interest, how can the QIN-QIO subcontract with a BFCC QIO for those services?
The inclusion of case review functions in Section C.4.7 of the QIN-QIO SOW was a clerical error. We have amended this portion of the SOW accordingly.
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Base Contract, Section C
C.4.5 Coordination with Stakeholders Outside the QIO Program
This activity shall be reported in the QIO’s Quarterly Report Collaboration with CMS contractors and other entities. This is a deliverable that is not identified in J.1(a)?
It should read QIN-QIO monthly COR Report. See revised QIN-QIO solicitation and Schedule of Deliverables J-1(a) Task A.1.7.a.
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Base Contract, Section C
C.4.5 Coordination with Stakeholders Outside the QIO Program
The RFP references " the QIO’s Quarterly Report Collaboration with CMS contractors and other entities.” Please identify the deliverable corresponding to this report.
It should read QIN-QIO monthly COR Report. See revised QIN-QIO solicitation and Schedule of Deliverables J-1(a) Task A.1.7.a.
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Base Contract, Section C
C.4.5 Coordination with Stakeholders Outside the QIO Program
Will the annual collaborative activities described in this section require out-of-state travel? If so, please provide travel assumptions that should be incorporated into the Business Proposal (estimated number of trips per year, required QIO attendees, # nights, location).
It is highly likely that out-of-state travel may be required; however, each QIN-QIO determines its unique needs for travel, CMS will not provide travel assumptions.
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Base Contract, Section C
C.4.5 Coordination with Stakeholders Outside the QIO Program
Must potential stakeholder organizations be identified by name at the time of proposal submission?
Yes, to the extent possible.
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Base Contract, Section C
C.4.5 Coordination with Stakeholders Outside the QIO Program
For costing purposes relevant to travel, how would CMS determine which region’s activities would be the focal point for required participation if the group of applicant states spans two CMS regions?
It is highly likely that out-of-state travel may be required; however, each QIN-QIO determines its unique needs for travel, CMS will not provide travel assumptions.
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Base Contract, Section C
C.4.5 Coordination with Stakeholders Outside the QIO Program
What are the specific responsibilities of Regional Offices in the QIN QIO program?
The CMS Regional Offices will continue their role of oversight monitoring of the QIN-QIO contracts.
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Base Contract, Section C
C.4.6 Communications
The first sentence states that QIOs shall inform “…Medicare beneficiaries and providers about…beneficiary rights under Medicare and how such rights may be exercised….” Does this apply to QIN-QIOs, or is this a responsibility of BFCC-QIOs?
Not necessarily. QIN-QIOs are responsible for engaging in whatever outreach/education/beneficiary support is needed to achieve the contract requirements elsewhere in the SOW. If that outreach/support requires the QIO to reach Medicare beneficiaries or new providers, it may be possible that these groups lack context for working with the QIN-QIO. Thus, part of a QIN's job may be to reach these audiences not just about the immediate clinical task at hand but about the value of working with the QIO Program overall.
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Base Contract, Section C
C.4.6 Communications
Once a submitted document has been approved by the CMS communications lead identified in the contract, the QIN-QIO shall provide a copy of the final version to the COR and CMS communications lead. Does this apply to all tools and materials created by the QIN-QIO?
CMS expects that QIOs will need to generate communications materials as part of their QIN-QIO activities. Every individual piece of communications material will not require COR review; however, QIOs should be prepared to furnish any communications item to the COR at his/her request. Furthermore, certain sensitive publications--such as a research article co-authored with CMS--require particular COR review prior to publication (see Chapter 12 of the QIO Manual for more information).
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Base Contract, Section C
C.4.6 Communications
As part of the CMS approval process, which is detailed in the QIO Communications Handbook, the QIN-QIO shall provide a copy of such materials in a file format specified by CMS to the COR. This is a deliverable that is not identified in J.1(a)?
CMS expects that QIOs will need to generate communications materials as part of their QIN-QIO activities. Every individual piece of communications material will not require COR review; however, QIOs should be prepared to furnish any communications item to the COR at his/her request. Furthermore, certain sensitive publications--such as a research article co-authored with CMS--require particular COR review prior to publication (see Chapter 12 of the QIO Manual for more information).
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Base Contract, Section C
C.4.6 Communications
The QIN-QIO shall provide a copy of the final version to the COR and CMS communications lead. This is a deliverable that is not identified in J.1(a)?
CMS expects that QIOs will need to generate communications materials as part of their QIN-QIO activities. Every individual piece of communications material will not require COR review; however, QIOs should be prepared to furnish any communications item to the COR at his/her request. Furthermore, certain sensitive publications--such as a research article co-authored with CMS--require particular COR review prior to publication (see Chapter 12 of the QIO Manual for more information).
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Base Contract, Section C
C.4.6 Communications
Will each state level local presence be required to host a resource (web) site or will QIN-QIO regional representation be sufficient?
QIN-QIOs shall ensure that every part of its QIO area is served by its web presence. CMS does not prescribe whether that means that QIOs host a separate presence for each state or a single presence that unites information about all states in a single location.
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Base Contract, Section C
C.4.6 Communications
Will CMS be specifying the mechanism for sharing, such as posting to the www.healthcarecommunities.org website?
As stated in C.4.8 of the base contract SOW, CMS intends to use the healthcarecommunities.org website as its primary mechanism for facilitating electronic collaboration.
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Base Contract, Section C
C.4.6 Communications
The underlined portion of the excerpt below is unclear. Does this mean that all QIO materials require CMS approval for distribution before making them available to other QIOs? “The QIN-QIO shall make available to other QIOs: (1) any new materials developed by the QIN-QIO and approved in writing by CMS for distribution …”
No. This provision does not compel the QIO to share or to gain CMS clearance for all communications items. Rather, this provision allows QIN-QIOs to share materials with fellow QIOs in a spirit of collaboration/coordination. Under this provision, the COR or GTL would review and clear a QIO-generated communications item before a single QIN-QIO chose to share it with other QIOs as a "best practice" for wider dissemination. This ensures that the sharing taking place among QIOs reflects the standards, guidelines, and messages that support the QIO Program most appropriately.
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Base Contract, Section C
C.4.6 Communications
The QIN-QIO are instructed to refer at least every 90 days for the current standards and guidelines on the CMS Contractor Website Guidelines http://www.cms.gov/About-CMS/Agency-Information/Aboutwebsite/contractorwebguidlines.html. Are QIN-QIOs expected to review all of the links and references to seek out information that may have changed? Or, for efficiency and effectiveness of the QIN-QIOs will the site indicate what content has been changed?
Ensuring that electronic media meet Section 508 guidelines is a responsibility of the QIO. The reference provided in C.4.6 is intended to serve as one of many resources on the Internet about 508 compliance (because 508 compliance is a government-wide requirement that is outside of CMS' legal purview to interpret for QIOs). QIOs are encouraged to use whatever resources they wish to help make their electronic materials more usable for the general public. While many resources, including the CMS.gov resource listed here and others on hhs.gov, provide tips on 508 compliance, no single document provides an exhaustive and absolute catalog of the steps a QIO--or any other entity communicating electronically on the government' s behalf--can take to "be" compliant. The COR or CO will need to discuss whether particular QIO efforts meet the spirit of this requirement on a case-by-case basis.
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Base Contract, Section C
C.4.6 Communications
The base contract SOW states, “The QIO is required to engage in education, outreach and communication activities to inform Medicare beneficiaries and providers about the purpose of the QIO program, beneficiary rights under Medicare and how such rights may be exercised….” Is the QIN-QIO required to conduct communication outreach activities to inform Medicare beneficiaries of BFCC-QIO functions in addition to QIN-QIO functions?
Not necessarily. QIN-QIOs are responsible for engaging in whatever outreach/education/beneficiary support is needed to achieve the contract requirements elsewhere in the SOW. If that outreach/support requires the QIO to reach Medicare beneficiaries or new providers, it may be possible that these groups lack context for working with the QIN-QIO. Thus, part of a QIN's job may be to reach these audiences not just about the immediate clinical task at hand but about the value of working with the QIO Program overall.
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Base Contract, Section C
C.4.6 Communications
Is the QIN-QIO required to translate all communication material targeted to audiences that do not speak English as their primary language?
As stated in C.4.6 of the base contract SOW, QIOs must adhere to the "Guidance to Federal Financial Assistance Recipients Regarding Title XI Prohibition Against National Origin Discrimination Affecting Limited English Proficient Persons." That guidance is on the HHS website at http://www.hhs.gov/ocr/civilrights/resources/laws/revisedlep.html.

As that guidance document states, QIOs are required to take reasonable steps to ensure meaningful access to their programs and activities by persons of Limited English Proficiency (LEP). While designed to be a flexible and fact-dependent standard, the decision about whether translated materials are most appropriate is an individualized assessment that balances the following four factors: (1) The number or proportion of LEP persons eligible to be served or likely to be encountered by the program; (2) the frequency with which LEP individuals come in contact with the program; (3) the nature and importance of the program, activity, or service provided by the program to people's lives; and (4) the resources available to the grantee/recipient and costs.

After applying the above four-factor analysis, a QIO may conclude that different language assistance measures are sufficient for the different types of programs or activities in which it engages, or, in fact, that, in certain circumstances, QIO-offered language services are not necessary. For instance, some of a QIO's activities will be more important than others and/or have greater impact on or contact with LEP persons, and thus may require more in the way of language assistance. QIOs should work with their CORs directly, keeping in mind that the explicit guidance from HHS states, "The flexibility that [QIOs] have in addressing the needs of the LEP populations they serve does not diminish, and should not be used to minimize, the obligation that those needs be addressed."

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Base Contract, Section C
C.4.6 Communications
Will a shared web presence be allowable among the prime QIN-QIO and its subcontractors?
This is up to the QIN-QIO, provided that the consistent voice presented in the Brand Guidelines Manual is achieved. Also, a QIN-QIO should consider the needs of the audience as the paramount factor in making this decision (per the concept of Integrated Communications presented in Section A.1.3 of Task Order 001). QIN audiences may find separate websites for the prime and subs helpful, or they may lead to confusion by presenting a fragmented list of websites based on the names/corporate presences of partners or primes/subs.
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Base Contract, Section C
C.4.6.a.6 Use of Web Technology/Web Content and Communications
Should QIN-QIOs follow branding guidelines in the most recent version of the QIO Program Brand Guidelines Manual, which is dated July 22, 2013 (or as subsequently updated)?
QIN-QIOs will be responsible for adhering to the most recent version of the Brand Guidelines Manual--whenever it has been last updated--throughout the period of performance. Thus, the Brand Guidelines Manual effective as of August 1, 2014, would be the BGM version to which QIN-QIOs would be held accountable at the start of the contract.
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Base Contract, Section C
C.4.6.a.6 Use of Web Technology/Web Content and Communications
The Statement indicates the QIN-QIO is to follow the branding guidelines as enumerated in the QIO Program Brand Guidelines Manual, dated December 5, 2011. However, Attachment J.7(a)—QIO Program Brand Guidelines Manual includes brand guidelines dated July 22, 2013, a later version. Should the QIO adhere to the manual in Attachment J.7.(a) dated July 22, 2013, and not the December 5, 2011, version?
QIN-QIOs will be responsible for adhering to the most recent version of the Brand Guidelines Manual--whenever it has been last updated--throughout the period of performance. Thus, the Brand Guidelines Manual effective as of August 1, 2014, would be the BGM version to which QIN-QIOs would be held accountable at the start of the contract.
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Base Contract, Section C
C.4.7 Emergency Preparedness
Please clarify and/or explain the need for including case review functions in the Continuity of Operations (COOP) and Disaster Recovery (DR) plans.
The inclusion of case review functions in Section C.4.7 of the QIN-QIO SOW was a clerical error. We have amended this portion of the SOW accordingly.
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Base Contract, Section C
C.4.7 Emergency Preparedness
The last bullet under this section refers to planning to cover reviews and appeals in an emergency. Does this apply to a QIN award?
The inclusion of case review functions in Section C.4.7 of the QIN-QIO SOW was a clerical error. We have amended this portion of the SOW accordingly.
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Base Contract, Section C
C.4.7 Emergency Preparedness
Should the following statement be included in this RFP, or is it meant only for the BFCC-QIO RFP ( How the QIN-QIO will deliver all five support operations listed above, as well as maintain mandatory business operations of the QIN-QIO (including statutorily mandated case review functions…..)?
The inclusion of case review functions in Section C.4.7 of the QIN-QIO SOW was a clerical error. We have amended this portion of the SOW accordingly.
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Base Contract, Section C
C.4.7 Emergency Preparedness
There is a statement referring to subcontracting with another BFCC QIO in order to maintain continuity of reviews and appeals during emergency situations “if the QIN-QIO so chooses”. Does this indicate an optional requirement based on needs, resources, etc. and would this only be within the same region of the QIN-QIO?
The inclusion of case review functions in Section C.4.7 of the QIN-QIO SOW was a clerical error. We have amended this portion of the SOW accordingly.
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Base Contract, Section C
C.4.7 Emergency Preparedness

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