E.4 Answers to Draft Solicitation Questions.xlsx
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- Unified Program Integrity Contract (UPIC) Federal contract opportunity
- Solicitation number
- HHSM-500-2015-RFP-0122
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E.4 Answers to Draft Solicitation Questions
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CPI Sheet
| Type of Question | Attachment | Page # | Section | CPI Component | Questions | Answers | |
| Technical | A-UPIC Draft USOW | 7 | 1.1 | CMG/DASP | What is the anticipated geographic breakdown of UPIC reponsibility? | See jurisdicition map in RFP package. | |
| Technical | A-UPIC Draft USOW | 7 | 1.1 | CMG/DASP | Who are "Medicare and Medicaid partners"? | There are multiple references to these partners in the SOW. Please see Section 1.6 Roles and Responsibilities and Section 2.6 Healthcare Fraud Prevention Partnership, to name a few. | |
| Technical | A-UPIC Draft USOW | 8 | 1.3 | CMG/DASP | The UPIC USOW does not require contractor offices to be in Heat Cities as in the 4/24/14 Draft USOW. Please confirm. | This is correct. | |
| Technical | A-UPIC Draft USOW | 8 | 1.2 | CMG/DASP | Who are the current CMS contractors performing payment integrity functions for Medicare and Medicaid? | This information is publicly available on FPDS. | |
| Technical | A-UPIC Draft USOW | 8 | 1.3 | CMG/DASP | Where can the map of the jurisdictions be found? | See jurisdicition map in RFP package. | Duplicate |
| Technical | A-UPIC Draft USOW | 8 | 1.3 | CMG/DASP | "The UPIC shall operate in CMS defined geographic areas, or jurisdictions, as found in the map in Appendix__ . At a minimum, the UPIC shall have the majority of its offices and staff located in the jurisdiction. See Section 8.3 on Key Personnel for additional requirements." |
| Can CMS please confirm that this reference is to USOW Section 7.3 Key Personnel Requirements? | This is correct. | ||||||
| Technical | A-UPIC Draft USOW | 14 | 1.6.4 | CMG/DASP | It would be helpful to elaborate some more about CMS' vision on what the framework and structure will be on promoting open, cooperative, and transparent relationships between Contractors and with CMS. This will help the vendors to proposal the appropriate solutions that fit CMS's needs | CMS believes that its vision and needs are clearly described in the current statement of work. | |
| Technical | A-UPIC Draft USOW | 14 | 1.6.4 | CMG/DASP | The 4th paragraph indicates that "the government shall retain intellectual ownership; not only of products, such as software and models but also concepts and approaches that are based in data made available for the use of the UPIC." |
| How does CMS want contractors to document/identify software, models, concepts, etc. that they developed prior to and outside of UPIC but which the contractor plans on using while performing as a UPIC? | CMS will revise the SOW and incorporate the following: "To promote open, cooperative, and transparent relationships between Contractors and with CMS, the government shall have rights in data, including items such as models, concepts, approaches, and software in accordance with FAR clause 52.227-17 Rights in Data - Special Works. | ||||||
| Technical | A-UPIC Draft USOW | 20 | 4.1.4 | CMG/DASP | Will any systems be transitioned from Outgoing ZPICs, PSCs, and MICs? Does CMS have "rights in data" to any of the systems? - the FAR clause Ken gave us? | We do not anticipate transitioning any systems from Outgoing ZPICs, PSCs and MICs. | |
| Technical | A-UPIC Draft USOW | 22 | 5.2.2 ("d") | CMG/DASP | The statement references analyzing data from multiple Healthcare databases, extenal to CMS. Will the incumbent be given access to these external databases during implementation period for establishing system connectivity | Section 7.5 Information Technology and Security provides information on CMS-internal databases and systems. CMS will not determine which external databases the UPIC must use and will not be providing access to those external databases. | |
| Technical | A-UPIC Draft USOW | 25 | 5.2.2.b | CMG/DASP | "Through the OnePI portal, the Medicaid data will be placed in a secure and private space in the IDR to perform data matching and analytics." |
| Does the Medicaid data in this statement refer to T-MSIS data only or will MMIS extracts be included where T-MSIS is not yet available? | See Section 7.5.1.5 of the SOW, entitled Medicaid Data. | |||||
| Technical | A-UPIC Draft USOW | 26 | 5.2.1.b | DASG/SMD | Section 5.2.1.b states " The planned source for the majority of the data and tools to be used will be in the OnePI/IDR. While awaiting data sources that may not be fully available in the IDR..." |
What data sources and data should offerors assume will be available through One PI/IDR at the award of the first Task Order? For example:
What Medicare data sources?
What Medicaid data sources and from which states?
Claims data? Provider Data?
Age of claims?
Adjudication status?
In addition, what is the anticipated timeline for any additional data sources becoming available? National Claims History (Medicare Part A/B/DME):
• Post Payment
• Data Range: CY 2006-Present
• Frequency: Weekly
Shared Systems (FISS, VMS, MCS):
• All Phases and Locations
• Data Range: FY 2012-Present
• Frequency: Daily
Medicare Part C (Encounter):
• Data Range: CY 2012-Present
• Frequency: Biweekly
Medicare Part D (PDE, NDC):
• Data Range: CY 2006-Present
• Frequency: Daily
Medicare Beneficiary Eligibility (CME):
• Medicare Beneficiary Database (MBD)
• Eligibility Database (EDB)
• Medicare Advantage & Part-D Inquiry System (MARx)
• SSA Death Master File (DMF)
Medicare Provider Enrollment:
• Provider Enrollment, Chain, and Ownership System (PECOS)
• National Plan and Provider Enumeration System (NPPES)
• National Provider Identifier Crosswalk System (NPICS)
• Provider of Services (POS)
• Part B Provider Extract (ProvBX)
• National Council for Prescription Drug Programs (NCPDP)
Medicare Program Integrity:
Relative Value Units Physician Fee Schedule Compromised Number Checklist Medicare Exclusion Database Fraud Investigation Database Beneficiary Integrity Unit (BIU) Medical Review/Utilization Review (MRUR) Technical A-UPIC Draft USOW 26 5.2+ DASG/SMD The following questions refer to all instances of UCM and OnePI/IDR throughout the draft USOW, beginning with page 26, Section 5.2 Data Analysis and Matching Requirements.
Will CMS provide detailed specifications or additional documentation for the functionality contractors should assume will be present within the UCM (or alternative environments) on Day 1, and projected for the contract term? Such information would assist offerors in knowing what additional tools or capabilities might be necessary to support their internal operations. CMS will provide documentation regarding UCM with the RFP.
Technical A-UPIC Draft USOW 26 5.2.3 DASG/SMD "The UPIC shall collaborate with the states in their jurisdiction to develop a comprehensive strategy for data analysis involving Medicaid data."
| Does this statement refer to a strategy using the OnePI portal T-MSIS data exclusively or may a comprehensive strategy involve MMIS extracts or other Medicaid data provided by the State? Will the UPIC be allocated space within the OnePI environment to store this data? | CMS will make Analytic Data Marts (ADM) available in the IDR for each UPIC jurisdiction. The UPIC may utilize the ADM to perform analysis, upload data sets and download extracts via SAS Enterprise Guide in One PI. Standard Size is 2 TB however additional space may be allocated. We will work with each UPIC jurisdiction to determine the sequence and timeframes for implementing its states' Medicaid data into One PI. | |||||
| Technical | A-UPIC Draft USOW | 26 | 5.2.4.a | DASG/SMD | "The UPIC shall use a variety of Medicare, Medicaid, and non-CMS data to perform data analysis." |
| Will the non-CMS data be available via the OnePI portal or will the UPIC be alloacted space to store additional non-CMS data within the OnePI environment? | CMS will make Analytic Data Marts (ADM) available in the IDR for each UPIC jurisdiction. The UPIC may utilize the ADM to perform analysis, upload data sets and download extracts via SAS Enterprise Guide in One PI. Standard Size is 2 TB however additional space may be allocated. | |||||
| Technical | A-UPIC Draft USOW | 29 | 5.2.4.b | CMG/DASP | Section 5.2.4.b states "In some cases, data dictionaries may already exist; however, when data dictionaries do not exist or are not adequate for Medi-Medi purposes, they must be developed or modified." |
| Can CMS specify for which States a data dictionary exists? | CMS anticipates that the UPIC will establish these with the states in its jurisdiction. | |||||
| Technical | A-UPIC Draft USOW | 30 | 5.2.4.f | CMG/DASP | Section 5.2.4.f "The UPIC shall perform data analysis within their assigned jurisdiction, across jurisdictions or states, or from a national perspective (i.e., special projects or studies) as assigned by CMS." |
| When performing a cross-jurisdictional or national data analysis, does CMS intend for the UPIC to complete the analysis independently? Or in cooperation with another UPIC(s)? | Overall, with UPICs CMS expects a very collaborative approach. CMS anticipates that these decisions will be made on a case-by-case basis in consultation with CMS and the contractors and other appropriate stakeholders. | ||||||
| Technical | A-UPIC Draft USOW | 36 | 5.4 | CMG/DASP (after consultation with IAG) | As a UPIC, are Medicaid provider claims (claims for medical services, prescription drugs, supplies/equipment, etc.) identified for UPIC review/investigations (which encompasses audits, per page 36) to be performed in accordance with GAGAS or is the UPIC only required to follow GAGAS audit requirements when cost report audits are to be performed, as noted on page 39, section 5.5.1? | For cost report audits, GAGAS is required. For reviews/investigations, CMS requires that the UPIC, at a minimum, adhere to professional standards as well as adhere to additional standards as agreed upon with the state in which the investigation is being conducted. | |
| Technical | A-UPIC Draft USOW | 39 | 5.5.1 | CMG/DASP | "The UPIC may conduct cost report audits of Medicaid providers/suppliers. The audits shall be conducted in accordance with Generally Accepted Government Auditing Standards (GAGAS).” |
| Does the Government require for the cost report audits of Medicaid providers to be conducted by a CPA firm under the supervision of a CPA? | CMS does not require a CPA firm to conduct these audits. | |||||
| Technical | A-UPIC Draft USOW | 39 | 5.5.2 | CMG/DASP | “The UPIC shall establish a point of contact with the MAC to access cost reports as part of an investigation.” |
| What will be the scope of the cost report reviews? Will it include the analytical procedure? Does the Government require for this review to be conducted by a CPA? | CMS conducts cost report reviews of Medicare providers. CMS would expect UPICs to use the information from these reports to inform their own investigations. | |||||
| Technical | A-UPIC Draft USOW | 41 | 5.4.4 | CMG/DASP | Section 5.4.4 Appeals states “ In the case of Medicare appeals, this support includes, upon request, participating in Administrative Law Judge (ALJ) hearings with participant status.” |
Does this mean the UPIC will only participate in Medicare Appeals if requested to support the determination?
| Additionally, according to the Program Integrity Manual Ch 3 sec 3.9.3 – the MAC may request party status from CMS for ALJ proceedings. Will the UPIC be able to request party status as well, or will the UPIC only be allowed participant status? | The UPIC is expected to participate in all Medicare appeals. 'Upon request' will be removed from the SOW for clarity. The UPIC will invoke participant status in ALJ proceedings. | |||||
| Technical | A-UPIC Draft USOW | 43 | 5.6 | CMG/DASP | Section 5.6 Medical Review Requirements states "The UPIC is authorized to conduct medical and utilization reviews". |
| As medical review and utilization review are generally used interchangeably, is there a difference in how CMS is using the terms in the UPIC SOW? | There is no difference in how CMS is using the term and CMS will strike the phrase "and utilization" from this sentence. | |||||
| Technical | A-UPIC Draft USOW | 45 | 5.7.3 | CMG/DASP | Section 5.7.3 Evaluating Edit Effectiveness states "The UPIC shall consider an edit to be effective when it has a reasonable rate of denial relative to suspensions/revocations and a reasonable dollar return on cost of operation or potential to avoid significant risk to beneficiaries". |
| What does CMS consider a reasonable rate of denial relative to suspensions/revocations and a reasonable dollar return on cost of operation? | CMS anticipates making these determinations in consultation with individual UPICs. | |||||
| Technical | A-UPIC Draft USOW | 45 | 5.7.4 | DASG/SMD | Section 5.7.4 Edit Implementation states "As the functionality becomes available, the UPIC shall coordinate with CMS to develop edits in the FPS, as appropriate. " |
As edits are traditionally implemented in Shared Claims Processing System, can CMS please expand upon the planned functionality to develop edits in FPS?
| For example, is FPS going to be able to interface with claims processing systems such as FISS, MCS, and VMS to implement edits? | Currently, FPS does interface with the Shared Systems and will continue to do so into the future and works through the normal Fee For Service business processes. | |||||
| Technical | A-UPIC Draft USOW | 49 | 5.9 | DASG/DOM | The last paragraph in Section 5.9 states "As outlined in this SOW, the UPIC shall develop a plan for coordinating with State Medicaid Agencies and CMS and the states will routinely assess the effectiveness of Medicaid program integrity efforts to assure UPIC resources are appropriately utilized." |
Would CMS consider including the "sentinel" effect in the assessment of program effectiveness?
| For instance demonstrating the effect using data reflecting a change in cost per beneficiary, a decrease in denied claims, or decreased Cesarean births? | CMS will consider a variety of methodological approaches to appropriately measure program effectiveness. That will include looking at "sentinel effects" that are often difficult to measure, but will be considered. | |||||
| Technical | A-UPIC Draft USOW | 49 | 5.9.d | CMG/DASP | In Section 5.9 Support to States, the first item d) states: "d) Streamlined program integrity efforts and support continued efforts to move beyond pay and chase to an expanded focus on prevention". |
| Does the stated goal to move beyond pay and chase allow the option for the UPIC to work with the individual states to set up pre payment medical review and pre payment authorization? | CMS envisions a consultative role for UPICs, as appropriate. | ||||||
| Technical | A-UPIC Draft USOW | 52 | 7.3 | CMG/DASP | Will CMS require a Systems Security Officer as a Key Personnel? | CMS does not anticipate changing its key personnel requirements. | |
| Technical | A-UPIC Draft USOW | 52 | 7.3 | CMG/DASP | Will CMS require an IDIQ Program Director in addition to a Program Director for each jurisdiction? | CMS does not anticipate changing its key personnel requirements. | |
| Technical | A-UPIC Draft USOW | 53 | 6.1 | CMG/DASP (after consultation with IAG) | All actions listed in Section 6.1 Recommending Administrative Actions are pre-payment activities, with the exception of "6.1.f Civil Monetary Penalties." |
| Does CMS mean to include post-payment activities as well? | CMS will revise this section to clarify. Section 6.1 states "The range of administrative actions to be supported, developed and recommended by the UPIC to the appropriate Federal or state authority include but are not limited to the following" - Post payment and prepayment reviews are additional administrative actions that the UPIC could pursue to help ensure all provisions in the Social Security Act are being adhered to by providers/suppliers. However, CMS does not feel every admin action needs to be listed in the USOW since guidance is provided in the PIM. | |||||
| Technical | A-UPIC Draft USOW | 53 | 6.2 | CMG/DASP | In Section 6.2 Prepayment Review, there is a reference to Sections 6.6 and 6.7: "The UPIC shall use prepayment reviews as outlined in Sections 6.6 and 6.7 above." |
| Should this be 5.6 and 5.7? | Yes. | |||||
| Technical | A-UPIC Draft USOW | 54 | 6.5 | PEOG | CMS indicates in Section 6.5 Coordination "When the UPIC recommends an administrative action to CMS (or the MAC) for a provider/supplier that is also enrolled in Medicaid, the UPIC shall notify the State Medicaid agency." |
In the Program Integrity Manual, Ch 15 Sec 15.27.2 I - Regarding Revocations, its states Medicaid is notified of revocations by CMS via the SharePoint Ensemble site. Will the SharePoint Ensemble site continue to operate in the UPIC environment?
| If yes, can the UPIC leverage the SharePoint Ensemble site to notify States? Or does CMS contemplate a separate outreach? | The SharePoint site will continue to operate in the UPIC environment. However, CPI currently has a process in place to share revocation data with the Medicaid states. We do not anticipate that this will be a necessary function of the UPIC. | |||||
| Technical | A-UPIC Draft USOW | 57 | 7.3 | CMG/DASP | In Section 7.3, there is a reference to Section G of the task order regarding the key personnel requirements: "The UPIC shall adhere to the requirements set forth in Section G of the task order regarding key personnel." |
| Should this reference be Section C? | Yes. | |||||
| Technical | A-UPIC Draft USOW | 58 | 7.3.2 & 7.3.3 | CMG/DASP | In the Work Experience requirements for 7.3.2 Medicare Operations Lead and 7.3.3 Medicaid Operations Lead, the minimum years of experience in a progressive management capacity is 5 years for the Medicare Operations Lead and 3 years for the Medicaid Operations Lead. |
| Is that what CMS intended or should they both require the same number of years of progressive management experience? | CMS will revise the number of years of experience so that both the Medicaid Operations Lead and the Medicare Operations Lead are required to have the same number of years of experience. There will be 5 years of progressive management capacity required for both. | |||||
| Technical | A-UPIC Draft USOW | 61 | 7.5.1.2 | CMG/DASP | "The One PI/IDR system will replace the numerous and standalone data warehouses that are currently in place for this purpose." |
| Are there estimated dates indicating availability of T-MSIS data for each state in OnePI? | Updates regarding the status of T-MSIS can be found by searching on the Medicaid.gov website. There is also a T-MSIS resource mailbox at: T-MSIS@cms.hhs.gov. | |||||
| Technical | A-UPIC Draft USOW | 62 | 7.4.5 | CMG/DASP | In Section 7.4.5, there is a reference to Section 8.5: Information Technology: "Additional information on OnePI and the IDR can be found in Section 8.5: Information Technology. " |
| Should this be Section 7.5 Information Technology and Security? | Yes. | ||||||
| Technical | A-UPIC Draft USOW | 65 | 7.5.1.9 | CMG/DASP | Is Medicare Part D data to be used by the UPIC only as a portion of the total data analyzed for Medicare and Medicaid medical services, supplies or equipment and Medicaid prescription drug claims? Is it anticipated that the UPIC may find information from their reviews that the MEDIC could use in the Part D program integrity work, but the UPIC is not to actually review/investigate anything related to Part D as a UPIC work item? | Yes. | |
| Technical | A-UPIC Draft USOW | 67 | 7.5.1.6 | CMG/DASP | "The UCM will serve as the central repository for all contractor workload reporting. See Section 8.6 for specific requirements." |
| In Section 7.5.1.6, there is a reference to Section 8.6 for specific UCM workload reporting requirements. Should this be Section 7.6? | Yes. | ||||||
| Technical | A-UPIC Draft USOW | 73 | 7.6.3 | CMG/DASP | The draft USOW indicates that "The UPIC shall not use the Unified Case Management system as the system of record for the data." However, Section H9, Systems of Records, in the UPIC draft Solicitation on page 47 indicates that the UCM system is a system of records. Please clarify. | CMS will delete this sentence from the USOW. | |
| Technical | A-UPIC Draft USOW | 77 | 7.6.1 | CMG/DASP | Section 7.6.1 states "The UCM will eventually integrate actions such as prepay integration into the Medicare shared systems, or provide suspension or removal from participation in any of the CMS programs." |
Is it planned that when the UCM is integrated with the Medicare shared systems that updates to claim determination will be auto populated in the system based upon claim review decisions?
| If so, what assumptions should offerors make for when this capability will be available? | See revisions to this section of SOW. | |||||
| Technical | A-UPIC Draft USOW | 78 | 7.6.2 | CMG/DASP | Section 7.6.2 states "i. During the implementation period, CMS will provide the UPIC with the capability to achieve secure access through OnePI, and assist the UPIC with the procedures needed to access the Unified Case Management system. |
ii. During the transition period, the UPIC shall participate in training sessions for the Unified Case Management System, as directed by the CMS COR team..."
| What is the difference between the "implementation period" and the "transition period"? Or is CMS using the terms interchangeably? | These terms were used interchangeably. CMS will revise for clarity. | |||||
| Technical | A-UPIC Draft USOW | 79 | 7.6.4 | CMG/DASP | Section 7.6.4.a MANAGING AND MONITORING states "CMS expects that the information entered into the UCM by the UPIC will be accurate; therefore, CMS will conduct open and closed review of work in the UCM on an ongoing basis and use any such review as an element of performance monitoring." |
| What performance standards and parameters does CMS intend to use for performance evaluations? | Refer to Award Fee Plan. | ||||||
| Technical | A-UPIC Draft USOW | 112 | Is CMS willing to extend the due date? | No. | |||
| Technical | A-UPIC Draft USOW | 26+ | 5.2+ | DASG/SMD | The following questions refer to all instances of UCM and OnePI/IDR throughout the draft USOW, beginning with page 26, Section 5.2 Data Analysis and Matching Requirements. |
Recognizing that CMS continues to develop and/or mature solutions such as One PI, IDR and UCM over time, what assumptions, if any, should offerors use with respect to delivering or pricing short term business solutions that may be necessary to supplement or augment these solutions?
For example:
CMS indicates that certain requirements will be addressed through the UCM, or in an alternative environment as directed by CMS. Can CMS clarify that the alternative environment(s) mentioned in the SOW will be provided by CMS and should not be included in any technical or pricing solution by offerors?
If certain data specified by the SOW or required to support contractor operations is not yet available in One PI/IDR, will the contractor be expected to extract, load, and transform that data into their own data warehouse or directly into the IDR for analysis?
| If the former, will CMS provide any assumptions to offerors for sizing that storage and processing capability, given the variability in scope depending on the availability of data within One PI/IDR? Or will CMS provide any further documentation or specifications particular to each jurisdiction (e.g. timing of TMSIS data by state) that will assist offerors in making their own projections? | CMS is providing access through OnePI to a variety of data sources and to the UCM for case and workflow management, tracking and reporting. These data systems will be the tools utilized by UPICs and appropriate documentation will be provided for these systems. In the event that a UPIC identifies the need for data/systems above and beyond what is provided by CMS, the UPIC shall document the need, as appropriate, in their assumptions so that they are able to complete the tasks outlined in the SOW. In OnePI, CMS will make available Analytic Data Marts (ADMs) for each UPIC jurisdiction. Standard ADM size is 2 TB, however additional space may be allocated. UPICs may use these ADMs to perform analysis, upload data sets and download extracts via SAS Enterprise Guide. | |||||
| Technical | A-UPIC Draft USOW | 53-54 | 6.2 | CMG/DASP | The following question refers to the entirety of Section 6.2. |
| To clarify the extent of the UPIC's prepayment responsibilities mentioned in Section 6.2 Prepayment Review, will UPIC be responsible for adjudicating prepayment decisions? | No. | |||||
| Technical | A-UPIC Draft USOW | 57 - 60 | 7.3 | CMG/DASP | Encompassing the location requirement – “[X position] shall be onsite where the majority of the investigative work is conducted” – specified for the Jurisdiction Program Director, Medicare Operations Lead, Medicaid Operations Lead, Program Integrity Manager, and Medical Review Manager. |
Can CMS clarify this requirement?
| For example, based on the size of the Jurisdiction, multiple HEAT offices, ensuring effective stakeholder engagement, etc., a contractor might have two offices with relatively equal investigative workloads. In such a circumstance, would it be acceptable for the Jurisdiction Program Director and Medicare Operations Lead to be based in one location while the Medicaid Operations Lead, Program Integrity Manager, and Medical Review Manager were based in the other location? | CMS expects the offeror to propose the most efficient and effective way to conduct business in a jurisdiction based on the requirement as written. | |||||
| Technical | A-UPIC Draft USOW | 60-61 | 7.3.9 | CMG/DASP | Refers to the text in 7.3.9 in its entirety. |
| Considering the importance of data acquisition, processing, analysis, and visualization in effectively performing as a UPIC, a Chief Data Scientist could provide both the skills associated with a Chief Statistician as well as needed data and business intelligence expertise. Would CMS consider replacing the Chief Statistician as a key personnel position and replacing it with a Chief Data Scientist? | After consideration, CMS has decided to keep the key personnel position of Chief Statistician and not replace it with Chief Data Scientist. | ||||||
| Technical | A-UPIC Draft USOW | n/a | n/a | CMG/DASP | It would be helpful for the SOW to include more detailed descriptions about current applications and technologies being employed in sections or attachments | Noted. | |
| Technical | B-UPIC Task Order SOW | 1 | I | CMG/DASP | The Task Order is for Jurisdiction 1 and provides the states that are covered. The UPIC Draft Solicitation references Jurisdiction 2 as the first task order, which currently encompasses the states that are named in the task order as Jurisdiction 1 (see for example pages 102 and 122). Could CMS clarify? | The task order SOW is for the jurisdiction covering the following states: Illinois, Indiana, Iowa, Kansas, Kentucky, Michigan, Minnesota, Missouri, Nebraska, Ohio and Wisconsin. | |
| Technical | B-UPIC Task Order SOW | 2 | I.C | CMG/DASP | Section I.C of the Task Order SOW requires the UPIC to obtain access to FISS and MCS: "• The UPIC shall obtain access to the Fiscal Intermediary Shared System (FISS) and the Multi-Carrier System (MCS)." |
| In addition to FISS and MCS access, would HIGLAS access be provided to facilitate tracking and reporting of overpayment collections, payment suspensions and provider terminations? | CMS has no plans to provide UPICs with HIGLAS access. | ||||||
| Technical | B-UPIC Task Order SOW | 3 | C | CMG/DASP | The next to last bullet states "Receive any applicable Medicare and Medicaid financial reports". Are there varying types of formats to these reports and are they sent via internet email, through some other technical communication (e.g., secure file transfer), or are they available in one of the data portals described in Section 7.5 of the UPIC Draft USOW? | There are varying types of formats for these reports. UPICs should address these formats with the COR during the transition period. | |
| Technical | B-UPIC Task Order SOW | 3 | C | CMG/DASP | The last bullet states "View the claims attachment images, if applicable." Are there varying types of image formats that contractors will need to handle? | Contractors will be expected to handle the HIPAA compliant image formats providers are able to provide. | |
| Technical | B-UPIC Task Order SOW | 4 | II. A. | CMG/DASP | Sixth bullet under Constraints/Assumptions. Will all data required be stored in OnePI and the IDR? | The data required to be stored in OnePI is that having to do with data matching and analysis. | |
| Technical | B-UPIC Task Order SOW | 4 | II.A | IAG/DSPI | Section II.A states "In calculation of the Federal Financial Participation (FFP), the UPIC shall consult the following sources for guidance on calculating the FFP (using the Federal Medical Assistance Percentages (FMAP)) and shall monitor any changes to the FMAP as published in the Federal Register on an ongoing basis." |
How should the contractor handle FMAP when the overpayments are extrapolated across multiple periods? To determine the federal share of the overpayments, follow the same logic outlined in the Statistical Sampling worksheet. Complete the following steps:
1. Apply the appropriate FMAP percentage to each overpayment to compute the federal share amount;
2. Combine all federal share overpayment amounts by Strata and input the information in RAT-STATS;
3. Determine the lower bound for the total overpayment and the federal share; and
4. Summarize both calculations (total overpayment and Federal Share) and the results.
Technical B-UPIC Task Order SOW 4 A CMG/DASP
• Costs associated with development of an investigation shall be allocated based on the focus area(s) of the investigation. Please provide clarification on what CMS considers the focus area of the investigation (ie program, clairm type, administrative actions taken, provider specialty)
| The focus area of the investigation may be Medicaid, Medicare or Medi-Medi and the costs associated must be allocated to the corresponding funding line. | |||||
| Technical | B-UPIC Task Order SOW | 4 | II. A | DASG/SMD | "The UPIC shall use One Program Integrity (OnePI) and the Integrated Data Repository (IDR) for Medicare and Medicaid data matching, analysis and storage purposes." |
| How will storage capacity in OnePI/IDR be allocated to the contractor for this TO? | CMS will make Analytic Data Marts (ADM) available in the IDR for each UPIC jurisdiction. The UPIC may utilize the ADM to perform analysis, upload data sets and download extracts via SAS Enterprise Guide in One PI. Standard Size is 2 TB however additional space may be allocated | |||||
| Technical | B-UPIC Task Order SOW | 4 | II. A | CMG/DASP (in consultation with DASG/SMD) | "The UPIC shall use One Program Integrity (OnePI) and the Integrated Data Repository (IDR) for Medicare and Medicaid data matching, analysis and storage purposes." |
| Will the UPIC be allowed to store data outside of the OnePI/IDR (i.e. within its own environment) in support of audits and investigative activities? | CMS is providing access through OnePI to a variety of data sources and to UCM for case and workflow management, tracking and reporting and will not support duplicative databases or funtionality in a UPIC's own environment. | ||||||
| Technical | B-UPIC Task Order SOW | 5 | II B 2 | CMG/DASP | We assume that the UPIC SOW reference should be 5.3.1 rather than 6.3.1 | Yes. | |
| Technical | B-UPIC Task Order SOW | 5 | II B 3 | CMG/DASP | The UPIC SOW reference 6.10 is missing, concerning LE requests | CMS will correct reference. | |
| Technical | B-UPIC Task Order SOW | 5 | II.B.2 | CMG/DASP | Section II.B.2 designates "Leads prioritized centrally through the Fraud Prevention System: 45%". |
| Will CMS give an estimated number of FPS Leads the UPIC may receive per month in each specific Task Order? | No. | |||||
| Technical | B-UPIC Task Order SOW | 6 | II.B.9 | CMG/DASP (IN consultation with IAG) | Section II.B.9 Medicaid Overpayment Reports states "The process must conclude with a “final report” including, but not limited to the following":… |
| Does CMS require the "final reports" to be in compliance with GAGAS? | CMS will require that UPICs produce a report reflecting the UPIC's findings in a format and to the level of detail agreed upon with the state, as appropriate. In absence of a state’s preference, the reporting format must first be approved by CMS. | |||||
| Technical | B-UPIC Task Order SOW | 6 | B | CMG/DASP | The UPIC shall comply with section 7.8 of the UPIC SOW as described, including but not limited to reporting on the following: |
• Cost per investigation;
• Cost per audit;
• Cost per standalone medical review;
• Cost per administrative action;
Note: the above items shall include a numerical identifier matching UCM and grouped by state.
• Medi-Medi expenditures by state; and
• Medicaid expenditures by state.
Please provide detail on how these costs will be tracked by the UPIC? What cost elements are included in deriving the cost required above?
| Further detail to be provided in the business proposal template | ||||||
| Technical | B-UPIC Task Order SOW | 7 | 1 | CMG/DASP | Examples to depict what vendors need to do to accomplish the mission and goals as UPIC would be a great help for vendors to provide coherent and meaningful responses | Bidders are expected to use the Program Integrity Manual and SOW requirements to inform their proposals on how to conduct this work. |
| Technical | B-UPIC Task Order SOW | 7 | II.B.10 | CMG/DASP | Section II.B.10 UPIC Support of State Medicaid Agency Hearings and Appeals states "The UPIC shall, when directed to do so, support the necessary hearings/testimony which may result from the investigations conducted under this contract. " |
| Will CMS consider incorporating a process similar to the Medicare RAC appeal process -- i.e., specify the UPIC is responsible for working the first level of appeal for any appeal that is generated as a result of a pre-payment review? | CMS does not anticipate changing its appeals-related requirements. | |||||
| Technical | B-UPIC Task Order SOW | 7 | II.C | CMG/DASP | Section II.C Personnel Requirements states, "..all identified key personnel positions are full time for the purposes of this TO." |
| Will CMS consider removing the full-time requirement for Chief Legal Counsel, Medical Director, and Chief Statistician, as these positions are not traditionally required to manage a full time workload? | CMS does not anticipate changing its personnel requirements. | ||||||
| Technical | B-UPIC Task Order SOW | 34 | 5.3.1 | DASG/SMD | Is the Fraud Prevention System a CMS developed system or a COTS? | FPS being a COTS or CMS developed system has no bearing on the offerors submission of proposals for this solicitation. | |
| Technical | B-UPIC Task Order SOW | 48 | 5.9 | CMG/DASP | Is there any particular application or interface CMS is utilizing in supporting and interacting with states? | CMS will determine the sequence and timeframes of implementing Medicaid data in One PI based on awarded UPIC jurisdiction and other strategic CMS programs with the States that support this initiative. | |
| Technical | B-UPIC Task Order SOW | 2 & 3 | I.C | CMG/DASP | Section I.C states"The UPIC shall provide and use hardware/ software to: |
• Communicate efficiently (e.g., e-mail) within its own departments, other specialty contractors (when implemented), CMS, MACs, law enforcement, etc.;
• Provide systems to compile information for management reports.
• Receive any applicable Medicare and Medicaid financial reports; and
• View the claims attachment images, if applicable."
| Should offerors assume that these are the only systems that the UPIC will need to supply in order complete their work? | Refer to the umbrella SOW. | |||||
| Technical | B-UPIC Task Order SOW | 3, 4 | II | CMG/DASP | "For purposes of this TO, the Contractor shall not perform Part C and D audit and investigative activities." and "The UPIC role in Medicare and Medicaid managed care FWA will focus on analysis of managed care data and coordination with appropriate Medicare and Medicaid partners for referral and resolution of identified issues." |
| We ask CMS to confirm our interpretation for this TO. The UPIC will use Part C and D data for data analysis activities in support of Part A, Part B, Medi-Medi, and Medicaid audit and investigative activities, but the UPIC will not perform any Part C and D audits and investigations. If the Part C encounter data can be used, will the Part C encounter data be available through the OnePI portal? | Your interpretation of the TO requirement is correct. Part C encounter data is expected to be available through the OnePI portal as of June 2015. | ||||||
| Technical | B-UPIC Task Order SOW | 3,4 | II, Req | CMG/DASP | Page 3 of the Task Order states that the contractor shall not perform Part C and D audit and investigations. Page 4 says UPIC will focus on analysis of Part D and Medicaid pharmacy data and coordination with the appropriate Medicare and Medicaid partner for referral and resolution of identified issues. Please clarify what work is to be performed by the contractor. | The analysis of Part D data is intended to inform Part A and B audits and investigations. The contractor is not expected to conduct audits and investigations for part C or D. Medicaid pharmacy investigations shall be conducted under the UPIC scope of work. | |
| Technical | C-Jurisdiction Claims Data | CMG/DASP | This attachment changes the prior jurisdiction 2 in the 4/24/14 draft SOW. In the claims data attachment the former Jurisdiction 2 is now 1 and several states are missing: Nebraska, Kansas, Missouri and Iowa. Please clarify Jurisdiction changes and the states in those jurisdiction. | CMS will correct. | |||
| Technical | C-Jurisdiction Claims Data | CMG/DASP | The workload templates provide claims information for Medicare only. Does CMS plan to include workload information for Medicaid claims by state for Jurisdiction 1? | CMS will provide Medicaid demographic statistics by state in the RFP. | |||
| Technical | D-Deliverables List | 3 | CMG/DASP | The State Referral Report is missing from the deliverable schedule. Please reference UPIC SOW 5.4.3.2. | CMS will correct | ||
| Technical | E-UPIC Draft Solicitation | 102 | L.8.D.2 | CMG/DASP | "Additionally, to assess the competitive market for the MA IDIQ all offerors must state which jurisdictions the offeror intends to bid for these jurisdictions in the future." |
| Can CMS please provide the states included in the remaining jurisdictions for review? | Please refer to map in RFP. | |||||
| Technical | E-UPIC Draft Solicitation | 113 | L.8.2 | CMG/DASP | Subsection B: Technical Proposal Organization A.1 states " see attachment UPIC Technical Evaluation Scenarios." |
| Will CMS be providing the scenarios with the final solicitation? | Yes. | |||||
| Technical | E-UPIC Draft Solicitation | 113 | L.8.2 | CMG/DASP | The following refers to the Page Limits specified in Section L.8.2. |
| The requirements for Past Performance; Corporate Experience; and Key Personnel and Staffing Plan most certainly will exceed a 3 page limit for each section. Please clarify if the page limits are correct. It would appear, for example, for past performance that many contractors will greatly exceed this requirement, as the instructions ask for ALL relevant CMS and other contractors from the prime and significant subcontractors. Similar requirements for Key Personnel and Staffing and Corporate Experience likely each exceed a 3 page limit. | Solicitation has been updated to address this concern. | |||||
| Technical | E-UPIC Draft Solicitation | 113 | A.1 | CMG/DASP | "The Contractor shall provide its approach to accomplishing and integrating the UPIC functional requirements. Technical evaluation scenarios have been presented (see Attachment “UPIC-Technical Evaluation Scenarios”)…" |
| Can CMS provide the scenarios? | Yes. | |||||
| Technical | E-UPIC Draft Solicitation | 114 | L.8.2 | CMG/DASP | Subsection B: Technical Proposal Instructions Volume 2 states: |
…"3. Approach to Meeting Quality Assurance Program Requirements
i. Provide an approach and plan for meeting Quality Assurance Program Requirements that adequately address the following:"
| It appears that there are items missing under 3.i. Please confirm this typo or provide these items in the final solicitation. | This has been corrected for clarification. | ||||
| Technical | E-UPIC Draft Solicitation | 119 | L.8.2 | Section F: Attestations states "The following attestations shall be submitted: |
1. ISO registration or a plan for obtaining ISO registration within one year of contract award;
2. IT Security Requirement Compliance
3. Acceptance of all USOW and TO SOW requirements
4. All proposed Key Personnel meet all SOW requirements including location requirements."
Please clarify the information CMS would like included in the IT Security Requirements Compliance Attestation.
| CMS may want to consider providing a template for all contractors to use. | The contractor shall attest, in a brief statement, that they are capable of meeting, and shall meet, all of the USOW IT Security Requirements. | Update last bullet point of attestation to include T&C's. | |||||
| Technical | E-UPIC Draft Solicitation | 113, 115 | Subsection B: Technical Proposal Instructions Volume 2 | CMG/DASP | The page limitation for "Past Performance" is 3 pages. However, the Government requests that "The Offeror and all its significant subcontractor(s) identified in the proposal are required to provide a summary to disclose all of the following for the past performance information with a period of performance end date within the last 3 years of the date of this solicitation". Please clarify if the individual page limitation of 3 pages is per past performance? Or if the Government wishes for the offeror and all its significant subcontractors to provide the requested information within 3 pages in total. | See answer in row 76. | |
| Technical | E-UPIC Draft Solicitation | 95 |
122 L.5 L.8.D.2
| M.2 | CMG/DASP | References are made to Jurisdiction 2. The UPIC Task Order SOW references Jurisdiction 1. Can CMS please clarify? | This has been corrected for clarification. | ||||
| Technical | F-UPIC MA IDIQ Ordering Guide | 4 | III | CMG/DASP | Can you provide information on the anticipated Jurisdiction structure? Can you provide insights into how the new structure will compare to the current ZPIC structure? | See jurisdicition map in RFP package. | |
| Technical | A-UPIC Draft USOW | 52 | 5 | CMG/DASP | Can the government define more about UPICs' roles in education tasks? | Refer to Section 5.11 of USOW. | |
| Technical | B-UPIC Task Order SOW | 3 | II. Requirements | CMG/DASP | Part C and D investigations are not included in the UPIC but the UPIC will "coordinate with appropriate partners". Does this include data sharing with these entities? | This shall be determined on a case-by-case basis. | |
| Technical | C-Jurisdiction Claims Data | 1 | N/A | CMG/DASP | Will CMS provide outgoing case workload from both ZPICs and the Audit MICs for the states in this jurisdiction - including cases completed, cases in progress, LE referrals, etc...? |
| Also, will CMS provide the average age and other statistics for each case? | These details are addressed between the incoming and outgoing contractors during the transition. | ||||||
| Technical | A-UPIC Draft USOW | 66 | 7.5.1.6 Unified Case Management (UCM) System | CMG/DASP | What is the projected date for UCM deployment and what is the interim approach prior to the UCM being available? | CMS expects to deploy the UCM prior to implementation of the first UPIC. | |
| Technical | B-UPIC Task Order SOW | 1 | Title | CMG/DASP | The Draft Task Order SOW title page indicates: "UNIFIED PROGRAM INTEGRITY CONTRACTOR (UPIC) TASK ORDER |
STATEMENT OF WORK
Jurisdiction 1"
| The Draft Solicitiation refers to this Jurisdiction as Jurisdiction 2 in Section L.5; please confirm the jurisdiction number. | CMS will correct. | ||||||
| Technical | B-UPIC Task Order SOW | 4 | II. Requirements A. General Requirements | DASG/SMD | What is the projected date for Medicaid data to be housed in OnePI? | We will work with each UPIC jurisdiction to determine the sequence and timeframes for implementing its states' Medicaid data into One PI. | |
| Technical | B-UPIC Task Order SOW | 5 | II. B.2 | CMG/DASP | Section II.B.2 Workload Categories states "The UPIC shall assign the following levels of effort to the workload categories identified in UPIC SOW 6.3.1:" |
| Please clarify that the reference to UPIC SOW section 6.3.1 above is really UPIC SOW section 5.3.1. | This is correct. | |||||
| Technical | B-UPIC Task Order SOW | 5 | II. B.3 | CMG/DASP | Section II.B.3 Law Enforcement Requests states "The UPIC shall provide support to Law Enforcement in accordance with 6.10 of the UPIC USOW. The UPIC shall ensure that the level of effort in support of Law Enforcement requests does not exceed ___without approval from CMS." |
| Please clarify that the reference to UPIC SOW section 6.10 above is really UPIC SOW section 5.10. | This is correct. | ||||||
| Other | B-UPIC Task Order SOW | 17 | 4 | Recommendation: The past performance on transition should weigh heavily in evaluation because it is essential to program success | Noted | ||
| Technical | E-UPIC Draft Solicitation | 27 | H.1 | DASG/SMD | Section H.1 CMS INFORMATION SECURITY (APR 2013) states "The contractor shall become and remain compliant with the requirements set forth at the CMS Information Security website" … |
| According to the BPSSM, section 4.1.3, page 33, all contracts with claims data are rated FISMA high. Should offerors assume the UPIC jurisdiction task orders must comply with FISMA High? | The system security level will be moderate not high. | |||||
| Other | E-UPIC Draft Solicitation | 34 | H.4 | CMG/DASG | Section H.4 CONTRACT RENEWAL states "Pursuant to 42 CFR 400 and 421, “Medicare Integrity Program” if this contract is funded by Medicare Integrity Program appropriated funding, the Contracting Officer may unilaterally renew this contract annually by giving the Contractor written notice, within 60 days of the expiration date of this contract (after exercise of all option or renewal years), of its intent to do so." |
| Should offerors assume the contract terms provided apply to the entirety of the MA IDIQ, i.e. for both the Medicare and Medicaid scopes of work? | Yes. | |||||
| Other | E-UPIC Draft Solicitation | 54 | H.17 | CMG/DASG | Section H.17 states "The Contractor personnel shall be required to undergo a background investigation commensurate with one of these position-sensitivity levels:"… |
Will CMS provide a listing of personnel positions and required clearance levels with the final solicitation?
Additionally, as this timeline can be very lengthy, can CMS clarify if personnel will be able to perform on the contract while the Security Clearance process is being completed?
Finally, will CMS permit employees to perform on the contract, on an interim basis until the CMS security clearance process completes, if the contractor and their subcontractors follow a background investigation process that aligns with CMS and OPM guidance for Program Integrity work? Suggested language: Per the clause, the COR and the Security Emergency Management Group, shall perform a position-sensitivity anaylsis after contract award.
CMS Personnel Security has confirmed that the contractor will be abllowed to work on the contract while the investigation is being conducted.
Other E-UPIC Draft Solicitation 34-44 H.5 CMG/DASG 6. UPIC Jurisdictions The UPIC jurisdictions, previously outlined in Draft SOW may further exacerbate the issues outlined above and limit competition. For example, the current UPIC jurisdictions do not align with the MACs, RACs or other CMS contracting structures. Due to these inconsistencies, UPIC offerors that support these contracts as a prime or subcontractor will be limited in the number of Task Orders in which they can ultimately compete. Furthermore, if CMS ultimately finalizes its decision to have five UPIC jurisdictions with expansive geographies, this has a sizeable impact on competition, especially when considering that viable offerors will likely have other government healthcare program business in these geographies.
In light of the expansive government programs that could create an OCI with UPIC, will CMS take into consideration the number of jurisdictions and alignment with other CMS programs to maximize competition and minimize the possible reach of any or all of these conflicts?
| CMS does not anticipate changing UPIC jurisdictions. | ||||||
| Other | E-UPIC Draft Solicitation | n/a | n/a | CMG/DASP | Given the complexity and mission critical nature of the services require, maturity of management methodologies are good to have. CMMI Level 3 and ISO certificate might be good to have for vendors | Refer to USOW for ISO requirement. . |
| Technical | CMG/DASP | CMS released an RFI and conducted an Industry Day, with extensive Q&A, on the UPIC program in July 2013, and subsequently released a draft USOW in 2014. To what extent can the contractor rely on previous guidance (i.e. answers to questions) provided by CMS in regards to the UPIC program if it relates to provisions and requirements in the 2013-2104 documents that are unchanged in the current SOW documents? | Offerors should use current RFP documentation to develop their proposals. | |||
| Technical | A-UPIC Draft USOW | 38 | 5.4 | CMG/DASP | Similar requirements for Medicare Advantage and Part D investigations have historically been included in all ZPIC solicitations, causing bidders to incur additional bid and proposal costs in order to prepare business and technical proposals as well as costs associated with recruiting talent and establishing teaming arrangements. However, to date, no ZPIC task order has operationalized tasks associated with Medicare Advantage or Prescription Drug workloads. In fairness to the contractor community and to ensure that all price quotes are consistently developed, CMS should clarify if and when this workload will be required of the UPIC. | CMS has not yet determined the timeframe for Medicare Advantage and Part D Investigations |
| Technical | A-UPIC Draft USOW | 51, 52 | 5.11 | CMG/DASP | The footnote included in this section refers to section 3.8.2, however no such section is included in the SOW. Please clarify. | CMS will correct |
| Technical | A-UPIC Draft USOW | 51, 52 | 5.11 | CMG/DASP | Comment: This requirement calls for each UPIC to separately develop education that is common to all UPICs. For instance, since the role of the UPIC is the same regardless of region, the requirements for each UPIC to develop and execute stakeholder education on the same subject will result in redundancy, excess cost and inconsistent messaging. | The comment is acknowledged; however, CMS anticipates that there will be variations in the educational needs in specific jurisdictions/states that will be best addressed by the UPIC in each jurisdiction. |
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