HEDIS_J A_-_FBO_Posting.pdf

Justification for Other than Full and Open Competition

“Source Selection Information – see FAR 2.101 and 3.104”

1. Identification of the agency and contracting activity.

a. Federal agency and contracting activity. HHS. Centers for Medicare &

Medicaid Services (CMS).

b. Sponsoring organization. Center for Medicare (CM) / Medicare Drug Benefit and C & D Data Group (MDBG) / Division of Consumer Assessment and Plan Performance (DCAPP).

c. Project Officer information:

Project Officer: Lori Teichman

Mailing address:

7500 Security Boulevard Mailstop C1-25-05 Baltimore, MD 21244-1850

E-mail address: Lori.Teichman@cms.hhs.gov

Telephone number: 410-786-6684

2. Nature and/or description of the action being approved.

a. Acquisition purpose and objectives. The purpose of this acquisition is to award a new non-competitive contract to the National Committee for Quality Assurance (NCQA). NCQA owns the HEDIS® system which is integral to CMS’s Star Ratings.

b. Project background. NCQA has developed, continually updated, and annually collected the HEDIS® performance measurement set for CMS for 17 years. Since 1997, NCQA has been collecting Medicare, Medicaid and commercial HEDIS® results annually from health plans on a nationwide basis. The acronym “HEDIS®” is a registered trademark of NCQA, and is a brand name for a set of quality performance measures in managed care, that has become the industry standard in healthcare quality for health plans. It is essential for the Agency to award this contract noncompetitively to NCQA to continue the summary-level data collection and management of the annual Healthcare Effectiveness Data and Information Set (HEDIS ) submission for Medicare Advantage Organizations (MAOs). As the industry leader in quality assessment and reporting for managed care organizations, as well as the current CMS contractor, NCQA is uniquely situated to provide this continued service to

CMS.

3. Description of the supplies or services required to meet the agency’s needs (including the estimated value).

a. Project title. HEDIS® Summary Level Data Collection

b. Project description:

The contractor shall provide and maintain an information system and IT infrastructure to collect and support submission of HEDIS® measures data for MA plans and generate a database on Medicare plans. In addition to providing MA plans with data submission tools and instructions with detailed technical specifications for submitting HEDIS® measures, the contractor must facilitate and provide technical support and assistance to individual MA plans, as they submit data according to Medicare requirements. The contractor will be supporting CMS in the collection and management of the annual HEDIS® summary-level data submission for Medicare Advantage contracts.

Requirement type.

Research & development (R&D) R & D support services Support services (non-R&D) Supplies/equipment Information technology (IT) Construction Architect-engineer (A & E) services Design-build Other (specify): Professional, administrative, and management support services

Type of action.

New requirement Follow-on Other (specify): ______________________

Proposed contract/order type.

Firm-fixed-price Other fixed-price (specify, e.g., fixed-price award-fee, fixed-price incentive-fee): __________ Cost-plus-fixed-fee Other cost reimbursement (specify, e.g., cost-plus-award-fee, cost-plus-incentive-fee): ___________ Time and materials Indefinite delivery (specify whether indefinite quantity, definite quantity, or requirements): ___________ Other (specify): ___________ Completion Form Term form

Acquisition identification number. 150893

c. Total estimated dollar value and performance/delivery period.

The total estimated value of this acquisition is $2,200,000 over a 5 year period of performance. The proposed period of performance for the resulting contract is a Base Year and Four (4) 12-month Option Years.

4. Identification of the statutory authority permitting other than full and open competition.

This acquisition is conducted under the authority of 41 United States Code (U.S.C.) 253(c)(1) as set forth in Federal Acquisition Regulation (FAR) 6.302- 1.

This acquisition is conducted under the authority of section 4202 of the Clinger-Cohen Act of 1996.

This acquisition is conducted under the authority of the Services Acquisition Reform Act of 2003 (41 U.S.C. 428a).

5. Demonstration that the proposed contractor(s) unique qualifications or the nature of the acquisition requires use of the authority cited.

a. Name and address of the proposed contractor(s).

National Committee for Quality Assurance (NCQA) 1100 13th Street Suite 1000, NW Washington, DC 20005

b. Nature of the acquisition and proposed unique qualifications of the contractor(s):

NCQA has developed, continually updated, and annually collected the HEDIS® performance measurement set for CMS for 17 years. Since 1997, NCQA has been collecting Medicare, Medicaid and commercial HEDIS® results annually from health plans on a nationwide basis. The acronym “HEDIS®” is a registered trademark of NCQA, and is a brand name for a set of quality performance measures in managed care, that has become the industry standard in healthcare quality for health plans.

HEDIS® Measures Development & Technical Specifications

Since NCQA possesses the HEDIS® trademark, only NCQA can add, delete or modify measure specifications to the HEDIS® measurement set and the HEDIS® Volume 2 technical specifications. NCQA convenes interdisciplinary multi-stakeholder panels and groups for its HEDIS® measure development and technical specification maintenance activities.

These expert groups are all widely respected by the managed care industry and have stakeholder representation.

NCQA develops the measures and makes all of the updates to HEDIS® Volume 2, and is uniquely qualified to provide the needed technical assistance to health plans and auditors during data collection season.

NCQA is the only organization that can ensure that new measures and annual updates to the HEDIS® specifications are accurately and consistently incorporated into the HEDIS® data collection process for Medicare Advantage.

HEDIS® Calculation

For managed care performance data to be officially considered and legally called “HEDIS®,” the data must be:

1) Collected using HEDIS® Volume 2 technical specifications;

2) Annually audited by an NCQA certified HEDIS® auditor according to uniform criteria; and

3) Submitted according to schedule to NCQA for centralized calculation.

NCQA only uses official HEDIS® data in its accreditation scoring and in its information products. Since all Medicare Advantage Organizations are required to participate in HEDIS®, NCQA occupies a unique position regarding the development and collection of performance measures for health plans.

There would be high probability for calculation discrepancies if CMS were to employ a separate federal contractor to collect HEDIS® summary data.

CMS continues to use this data for CMS Star Ratings and to determine CMS quality bonus payments.

Technical Support Integration

The successful collection of HEDIS® data requires a coordinated effort between NCQA units responsible for measure development, measure and technical specification maintenance, and the data collection process.

As the organization that owns, maintains and updates HEDIS® measures, NCQA is the only organization to have successfully developed and implemented health plan performance measures on a nationwide basis. As the stewards of HEDIS®, only NCQA is able to develop new HEDIS® measures and replace outdated measures, and address technical inquiries about the HEDIS® specifications. Moreover, NCQA is the only organization in a position to ensure that new measures and annual updates to the HEDIS® specifications are accurately and consistently incorporated into the HEDIS® data collection process.

NCQA provides two distinct, but often interdependent, types of HEDIS® technical support and assistance to MA plans: responding to inquiries about the HEDIS® submission process; and responding to inquiries about the HEDIS® technical specifications and reporting guidelines. This support is interdependent because questions about HEDIS® technical specifications impact health plan data submission activities. This interdependence is crucial for collecting HEDIS® accurately, and would be lost if data collection operations were to move to another organization.

Real and Perceived Data Validity and Legitimacy

Both NCQA and CMS use this data in publicly reported information products and therefore discrepancies are unacceptable as they would result in widespread confusion among health plans and consumers. If this were to happen, since NCQA is the industry leader in managed care performance measurement, the industry would most likely regard the CMS data as being inaccurate and unreliable, putting CMS in a position of decreased esteem and legitimacy in the eyes of the healthcare industry. Therefore, CMS cannot risk the possibility of having results that differ from those of NCQA.

With this HEDIS® brand name comes a set of implied assumptions regarding the accuracy and reliability of calculation, consensus-based measure development, and industry endorsement. Because CMS uses this data for CMS Star Ratings and to determine CMS quality bonus payments, any discrepancies would result in widespread confusion among health plans and consumers. Congress maintains a continued interest in the annually-issued CMS Star Ratings and CMS Quality Bonus Payments, and a focus on improving quality and transparency. For these reasons, CMS must continue to receive HEDIS summary-level data from the only source that can guarantee correct calculation.

6. Description of the efforts made to ensure that offers are solicited from as many potential sources as practicable. Indicate whether a FedBizOpps notice was or will be publicized as required by FAR Subpart 5.2 and, if not, which exception under FAR 5.202 applies.

This action will not be competed among other potential sources. While FAR 6.302-1 states that agencies shall request offers from as many potential sources as is practicable under the circumstances, CMS has determined that, for the reasons previously cited, only NCQA has the necessary capabilities to successfully perform this work. In accordance with FAR 5.201, CMS posted a notice of intent to continue contracting on a sole source basis to NCQA on the www.FBO.gov website (the Government-wide point of entry) on March 17, 2015 to the appropriate time of notification, for the Agency to evaluate and consider any responses received (see Section 10).

7. Determination by the Contracting Officer that the anticipated cost/price to the Government will be fair and reasonable.

Upon receipt of the Request for Contract, the CMS Contracting Officer will ensure that the anticipated cost to the Government is fair and reasonable by comparing the proposed cost to the independent government cost estimates for the Base and (four) Option Years.

19, Additionally, a cost realism analysis will be performed to ensure that the proposed costs are reasonable and are commensurate with the technical approach.

8. Description of the market research conducted (see FAR Part 10) and the results, or a statement of the reasons market research was not conducted.

A notice of intent to contract on a sole source basis with NCQA was posted on www.FBO.gov on March 19, 2015. Organizations that wanted to challenge the sole source designation were given until April 3, 2015 to reply to the notice (see Section 10).

9. Any other facts supporting the use of other than full and open competition.

The cost of developing a web-based infrastructure to collect summary-level HEDIS® by a new contractor is estimated to be very large in comparison to awarding the incumbent Contractor (NCQA) to do this work. It is far more efficient, less duplicative, and less expensive for CMS to continue to use the existing infrastructure developed independently by NCQA to collect HEDIS® summary data from MAOs.

10. Listing of sources, if any, that expressed, in writing, an interest in the acquisition.

In reply to the www.FBO.gov notice posted on March 19, 2015, CMS did not receive any challenges to the sole source nature of this requirement.

11. Statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition for the required supplies or services.

Upon expiration of this contract and if this requirement still exists, CMS will conduct market research to see if there are any companies capable of doing this work.