Approved_-_Tracking__JA15-0153__Final_Redacted.pdf

Tracking #JA15-0153

SOURCE SELECTION INFORMATION

(See FAR 2.101 and 3.104-4)

Justification and Approval “Limited Sources” Justification

1. Identification of the Agency and Contracting Activity: The agency this requirement is being procured for is the Defense Health Services System (DHSS). The Contracting Activity is the Defense Health Agency, Contract Operations Branch-San Antonio (DHA COB-SA).

2. Nature and or description of Action Being Approved: Approval is requested for Limited Sources Justification to procure the Coding Compliance Editor (CCE) enhancement and migration to capacity services. This requirement will be procured with Defense Health Program (DHP) FY15 Operations and Maintenance (O&M) funding.

3. A Description of Supplies/Services required to meet the agency’s needs: Department of Defense Instruction Number 6040.42 issued June 10, 2004, subject Medical Encounter and Coding at Military Treatment Facilities required all Military Health Systems (MHS) medical encounters to be accurately and promptly documented and coded, adhering to legal and medical coding classification standards, as permitted by MHS data collection systems. This Instruction also required that a coding compliance editor be resident in the Composite Health Care System (CHCS). In February 2004, 3M health Information Systems went live with a comprehensive suite of 3M coding, compliance, and data analysis software which was deployed at the Naval Hospital Pensacola in Pensacola Florida, the first site of the US Department of Defense Military Health System’s Coding Compliance and Editor Project. The 3M software suite was rolled out to approximately 500 military hospitals and clinics worldwide.

3M provided the DoD MHS with data analysis and reporting tools for coding, grouping and editing;

reimbursement calculation; patient data abstracting; care management evaluation; and medical necessity review. As part of the implementation, 3M also provided process improvement and training services for MHS coding and billing operations. The 3M products comprising the DoD Coding Compliance and Editor project include the 3M Coding and Reimbursement System, 3M Physician Coding and Reimbursement System, 3M Coding Reference Software, 3M All patient Refined DRG (APR-DRG) Software, 3M Audit Expert Inpatient and Outpatient software, 3M health Record Management Software and the 3M Care Management Software.

CCE uses the 3M Health Information Systems commercial off-the-shelf (COTS) application designed to improve data quality, regulatory compliance, and medical claims revenue within the MHS. CCE is the enterprise-wide coding, compliance, data collection and reporting solution for the MHS. This comprehensive, integrated system has been designed to effectively increase data quality, improve third party collections and reduce the risk for non-compliance. CCE is a client-server based coding and compliance COTS solution that resides on Dell or blade servers and has been successfully deployed to over 140 sites and clinics world-wide.

DHSS currently has an agreement with DISA to provide Infrastructure as a Service, with DISA providing the cloud infrastructure. For this requirement, 3M will be tasked with taking the suite

(See FAR 2.101 and 3.104-4) of software above from a local infrastructure to the cloud. Although this has already been accomplished by 3M on the commercial side of industry, it will take additional tweaking to ensure it complies with the strict security and infrastructure of the MHS.

The 3M suite of products utilizing an enterprise license approach is deployed to 140 Military Treatment Facilities (MTF) worldwide. The period of performance will be a base period of 30 Sep 2015 – 29 Sep 2016, with an option period of 30 Sep 2016 – 29 Sep 2017. The estimated dollar value of the base period is . The estimated value of the option period is . The FAR Extension of Services Clause 52.217-8 will be included at a potential value of . The total estimated dollar value for the full operational capability, deployment and training of this requirement, including the Extension of Services Clause, is .

4. Identification of the Authority and Supporting Rationale: Under the authority of 41 U.S.C.

152(3) and in accordance with FAR 8.405-6(a)(1)(i)(B) – Only one source is capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized. This requirement will enable DHA to transition the 3M software products from a local environment to the cloud. In order to meet specific Government requirements, the software will need minor modifications. The 3M suite of software products is proprietary to 3M.

No other vendor has access to the code. Although 3M has identified partners and resellers, they are only allowed to provide the maintenance and Tier III support. Maintenance for these products will be done under a separate acquisition to ensure that competition can be obtained.

5. A determination by the ordering activity contracting officer that the order represents the best value consistent with FAR 8.404(d): This requirement will be offered as a sole source to 3M under their General Services Administration (GSA) Mission Oriented Business Integrated Services (MOBIS) vehicle. The use of the MOBIS vehicle provides pricing that is already been found fair and reasonable; however discounts will be sought and a final price fair and reasonable determination will be made using FAR 15.404-1 as required. The Contracting Officer has determined that use of the MOBIS schedule will provide best value with regards to price, delivery and contractor’s ability to successfully perform.

6. A description of the market research conducted among schedule holders and the results or a statement of the reason market research was not conducted: Market research, in accordance with FAR Part 10, was conducted via the 3M website as 3M Health Information Systems holds the proprietary rights to the software. Although 3M has partners, these partners are not authorized to change the software code. Although other vendors have products that could provide the basic requirement, the Government has expended over $21M (Delivery Order Number N65538-05-F-0106) to purchase the perpetual licenses. This investment would be lost if this requirement was awarded to another vendor using a different application.

7. Other Facts: None

8. A statement of the action, if any, the agency may take to remove or overcome barriers that lead to the restricted consideration before any subsequent acquisition for the supplies or

(See FAR 2.101 and 3.104-4) services is made: No other manufacturer’s products have been found that will meet the program needs. However, the sustainment and Tier III support has and will continue to be competed as the market allows.

Coordination:

9. Technical/Functional Certification:

11. Contracting Officer Certification: I certify that this justification is accurate and complete to the best of my knowledge and belief.

Typed Name:_________________________ Date:___________________________

Title: ________________________________

12. Legal Review:

I have reviewed this justification and approval and it is deemed to be legally sufficient

Typed Name:_________________________ Date:___________________________

Title: ________________________________ Signature ____________ gitally signed by TROFF.ERIK.ANDREW.1138681005

DN: c=US, o=U.S. Government, ou=DoD, ou=PKI, ou=DHA, cn=TROFF.ERIK.ANDREW.1138681005 Date: 2015.07.15 09:27:28 -04'00'

(See FAR 2.101 and 3.104-4)

Approval:

13. Competition Advocate: Based on the foregoing justification, I have reviewed the procurement of CCE Requirement on a limited source justification basis pursuant to the authority of 41 U.S.C. 152(3) IAW FAR 8.405-6(a)(1) (i)(B) and provided that the services and property herein described have otherwise been authorized for acquisition.

I certify that this justification is accurate and complete to the best of my knowledge and belief.

Typed Name: ____ Date:__________________

Title: ________________________________Head of Contracting Activity

15 July 2015