ACADM Phase 1 QA 082126.pdf

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Request for Solutions (RFS): Autonomous Coding (AC) and Automated Appeals & Denials Management (ADM)
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HT0038RFSACADM
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This is a Questions and Answers document for a Defense Health Agency (DHA) Request for Solutions (RFS) soliciting prototype Other Transaction Agreements (OTAs) for Autonomous Coding (AC) and Automated Appeals & Denials Management (ADM) capabilities. The document comprises 149 vendor questions with Government responses addressing technical, commercial, security, and programmatic requirements.

The Government seeks AI/ML-enabled solutions to improve medical coding accuracy and manage aged accounts receivable across the Military Health System (MHS), integrating with MHS GENESIS as the primary EHR platform. White papers were due August 28, 2026, with a three-phase evaluation approach: Phase 1 (white paper evaluation against RFS problem statements), Phase 2 (down-select discussions with cost breakdowns), and Phase 3 (live demonstrations using vendor-provided sample data). The Government anticipates awarding one or more fixed-price prototype OTAs, potentially to separate vendors for AC and ADM capabilities, or to a single vendor proposing both. Key requirements include: minimum DoD Impact Level 4+ authorization (with ATO-C as Milestone 3), collaboration with Leidos for MHS GENESIS integration, Government-furnished deidentified test data for pre-production testing, and vendor-provided sample datasets for Phase 3 demonstrations. Performance thresholds include ≥60% autonomous coding coverage at Milestone 2 and ≥80% correlation match for ADM against human-audited claims. The prototype period spans 13-16 months from award, with production delivery targeted for June 30, 2027. Vendors must provide SPRS assessments and CMMC Level 2 self-attestations at white paper submission, possess current security authorizations, and clearly document plans to achieve DoD IL 4+ authorization prior to production integration. The Government will share only minimum technical information necessary for MHS GENESIS integration with Leidos and Oracle Health, excluding pricing and sensitive data. Detailed cost breakdowns, data specifications, baseline metrics, and final milestone payment structures will be established during Phase 2 discussions with down-selected vendors.

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File Type Posted
ACADM Phase 1 QA 082626.pdf PDF
ACADM RFS Rev 1.pdf PDF
Draft SOO ACADM Rev 1.pdf PDF
Request for Solution ACADM.pdf PDF
Draft SOO ACADM.pdf PDF

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Reference Question Gov't Response

1 N/A Does a FedRAMP Moderate authorization anticipated during performance satisfy §5.1.4 at white-paper stage?

Per RFS Section 5, 'Security & Compliance,' the solution must possess, at a minimum, a valid DoD IL 4+ authorization. The RFS and the draft SOO describe a phased approach where authorization is a key milestone (Milestone 3: ATO-C). Vendors must clearly state their current authorization status and their plan to meet all security requirements as outlined in the RFS prior to being allowed to proceed with integration into the Production environment.

2 N/A Given that award is now realistically past the SOO's assumed August 2026, does the ATO-C target shift accordingly?

Per RFS Section 5, 'Security & Compliance,' the solution must possess, at a minimum, a valid DoD IL 4+ authorization. The RFS and the draft SOO describe a phased approach where authorization is a key milestone (Milestone 3: ATO-C). Vendors must clearly state their current authorization status and their plan to meet all security requirements as outlined in the RFS prior to being allowed to proceed with integration into the Production environment.

RFS Section 2 Background (Leidos 2015 contract; teamed with Oracle); RFS Section

5.1.1 (Leidos is current system integrator;

SOO Section 4.1 Milestone 2 (approved test data provided by the Government); SOO Section 4.2 Milestone 2 (MHS GENESIS workflows, user roles, and government-provided test data);SOO Section 8.1 (durations run from defined start points)

GOVERNMENT-FURNISHED DATA RESPONSIBILITY: Which entity is responsible for furnishing that data and for approving the associated interface — the Government directly, Leidos as system integrator, or

Oracle Health as the EHR vendor? Additionally, does the Government anticipate any data access, licensing, or approval constraints arising from the Leidos or Oracle Health relationships that an awardee should plan for?

Per the draft SOO (e.g., Milestone 2), the Government will provide approved test data for the pre-production environment. For the Phase 3 live demonstration, RFS Section 6 states it 'shall use a vendor-provided sample data set.' Further details on Government-provided data will be furnished to vendors selected to advance to later phases.

The Government will facilitate the necessary deidentified data and a sandbox environment leveraging both Leidos and Oracle as our partners. This effort is currently underway and in the planning stages. Majority of data has already been identified. Vendors will be responsible for ensuring personnel meet necessary security clearance requirements to access data once placed in the sandbox environment.

RFS Section 5.1.1 (Government anticipates offeror will collaborate with Leidos to integrate); SOO Section 3.2 Phase 2 (approved MHS GENESIS APIs and integration points as designated by the Government);SOO Section

8.3 (milestone payment schedule — no integration line item)

Leidos Integration Relationship: Section 5.1.1 of the RFS states that the Government anticipates the successful offeror will collaborate with Leidos to integrate the solution into MHS GENESIS. What contractual and cost relationship does the Government anticipate between the awardee and Leidos for that integration? Specifically, will integration effort be funded under the prototype OTA, under the existing Leidos agreement, or separately?

As stated in RFS Section 5, 'EHR Architecture Experience,' the Government anticipates the successful vendor will collaborate with Leidos to integrate the solution into MHS GENESIS. The Government will facilitate this collaboration. Further details on the integration process will be provided during Phase 2 discussions.

RFS Section 6 Phase 3 (vendor-provided sample data set; showcase solution in its entirety);RFS Section 5.2 (whether the engine has processed real, non-synthetic clinical documentation); SOO Section 9.2 Security

(PHI handling, DoD 5200.01, HI)

PHASE 3 LIVE DEMONSTRATION DATA: Section 6 of the RFS states that the Phase 3 live demonstration shall use a vendor-provided sample data set. Will the Government accept synthetic data for this demonstration, or is de-identified real clinical documentation required or preferred?

Per the draft SOO (e.g., Milestone 2), the Government will provide approved test data for the pre-production environment. For the Phase 3 live demonstration, RFS Section 6 states it 'shall use a vendor-provided sample data set.' Further details on Government-provided data will be furnished to vendors selected to advance to later phases.

RFS Section 6 Phased Evaluation Approach (three phases before award); RFS Section 9

(white papers due 19 Aug 2026); SOO Section

8.1 (durations from date of award, stated as

Aug 2026; ATO-C ~June 2027; PoP 13–16 months) vs. SOO Section 8.2 (30 June 2027 delivery target, both capabilities)

AWARD TIMELINE AND SCHEDULE BASIS: Section 8.1 of the SOO expresses schedule objectives as durations from the date of award and identifies that award date as August 2026. White papers under this

RFS are not due until August 19, 2026, and the RFS establishes two subsequent evaluation phases including team discussions with a cost breakdown, followed by a live demonstration before award. Can the Government further provide clarity on the anticipated award date, and confirm whether the durations and estimated timeline in Section 8.1 will be rebaselined to that date? Relatedly, Section 8.1 estimates

ATO-C at approximately June 2027 with a 13 to 16 month period of performance, while Section 8.2 sets a delivery target of 30 June 2027 for both capabilities integrated and validated in production. Which governs for purposes of proposing our schedule?

Per RFS Section 5, 'Security & Compliance,' the solution must possess, at a minimum, a valid DoD IL 4+ authorization. The RFS and the draft SOO describe a phased approach where authorization is a key milestone (Milestone 3: ATO-C). Vendors must clearly state their current authorization status and their plan to meet all security requirements as outlined in the RFS prior to being allowed to proceed with integration into the Production environment.

Q&A: Autonomous Coding and Automated Appeals & Denials Management Request for Solutions

RFS Section 5.2 Data Rights, Intellectual Property, and Engine Provenance (propose data rights for trained model, tuned parameters, Government-derived datasets);

SOO Section 7 Deliverables (must NOT be marked proprietary; must carry Distribution

Statement C) vs. Section 6.2 Data Rights and Engine Provenance

DATA RIGHTS AND DELIVERABLE MARKING: Section 7 of the SOO states that deliverables must not be marked proprietary and must carry Distribution Statement C. Section 5.2 of the RFS and Section 6.2 of the SOO invite vendors to propose data rights for the trained model, tuned model parameters, and Government-derived datasets. Are model artifacts, including trained models and tuned parameters, considered deliverables subject to the Section 7 marking requirement? If so, how does the Government intend to reconcile that requirement with vendor-proposed data rights in those same artifacts?

This response will be provided at a later date.

RFS Sections 4.1 Page Limits & Structure (cover page, BOM, and addenda excluded from the 10-page limit — NTDC statement not listed); RFS Section 4.1 Non-Traditional

Contractor (should not take more than a page)

NONTRADITIONAL DEFENSE CONTRACTOR STATEMENT — PAGE TREATMENT: Section 4.1 of the RFS requires identification of nontraditional defense contractor status and states this should not take more than a page to provide. The same section lists the cover page, Bill of Materials, and addenda as excluded from the ten-page limit, but does not address the nontraditional contractor statement. Does that statement count against the ten-page limit, or is it treated as excluded?

The NTDC statement can be included on the cover page or included in the ten page count.

RFS Section 8 Award (Government may award multiple agreements); SOO Section 3.2(2) Interdependent Algorithm Learning (share learning insights across both vendors' platforms); SOO Section 8.3 (milestone payment schedule — no joint integration line);

SOO Section 7.4 (production invoiced per encounter)

SHARED OBJECTIVES (SOO SECTION 3.2): If separate vendors are selected for AC and ADM, Section 3.2 requires the vendors to implement interdependent machine learning algorithms that share learning insights across both platforms. Vendor is prepared to collaborate on unified dashboards, secure data exchange, joint integration plans, and testing protocols. What information does the Government expect to be shared between vendor platforms — outcome data and denial root-cause taxonomies, or model parameters, architecture, and training data? What protections would apply to each vendor's proprietary models? The milestone payment schedule at Section 8.3 does not identify a funding basis for the joint integration work required by Section 3.2. Should vendors include that effort in the Phase 2 cost breakdown?

This response will be provided at a later date.

10 Submission Format Section 4.1 excludes the cover page, the Bill of Materials, and addenda from the ten-page limit. Does the non-traditional defense contractor statement also fall outside that limit, or should it be counted within the ten pages?

The NTDC statement is part of the main body and counts toward the limit, but may also be placed on the cover page if space allow

11 Submission Format Do diagrams and figures count against the ten-page limit on the same basis as text?

As stated in RFS Section 4, 'Page Limits & Structure,' the ten-page limit is for the main body of the white paper. The cover page, Bill of Materials, and specified addenda do not count toward this limit. Diagrams and figures included in the main body of the white paper count against the ten-page limit. The NTDC statement is part of the main body and counts toward the limit, but may also be placed on the cover page if space allows.

12 Draft SOO

The draft SOO carries bracketed values at several points, including the Milestone 2 threshold of autonomously coding greater than or equal to [60] percent of approved test volume, the [80] percent correlation match under Capability 2, and the milestone durations of [90], [90] and [120] days. Should offerors treat these as the Government's intended values for purposes of the white paper, or will they be finalized after Phase 1?

The values in brackets in the draft SOO represent the Government's current objectives. Vendors should use these values for planning purposes in their white paper submissions. These figures may be finalized during Phase 2 discussions or agreement negotiations.

13 Draft SOO Will white papers be evaluated against the quantitative success criteria in the draft SOO, or against the problem statements in the RFS alone?

White papers will be evaluated against the problem statement in the RFS.

14 Authorization & Hosting Section 5.1.4 requires a minimum of DoD IL 4+ authorization. Is an offeror responsive if it proposes to deploy its solution into an environment that already holds an IL 4+ or IL 5 authorization, rather than holding a FedRAMP authorization in its own name?

Per RFS Section 5, 'Security & Compliance,' the solution must possess, at a minimum, a valid DoD IL 4+ authorization. The RFS and the draft SOO describe a phased approach where authorization is a key milestone (Milestone 3: ATO-C). Vendors must clearly state their current authorization status and their plan to meet all security requirements as outlined in the RFS prior to being allowed to proceed with integration into the Production environment.

15 Authorization & Hosting Is FedRAMP or IL 4+ authorization required to be held at the time of white paper submission, or is a credible path to authorization by Milestone 3 sufficient at this phase?

Per RFS Section 5, 'Security & Compliance,' the solution must possess, at a minimum, a valid DoD IL 4+ authorization. The RFS and the draft SOO describe a phased approach where authorization is a key milestone (Milestone 3: ATO-C). Vendors must clearly state their current authorization status and their plan to meet all security requirements as outlined in the RFS prior to being allowed to proceed with integration into the Production environment.

16 Authorization & Hosting At what point must SPRS assessments and CMMC Level 2 self-attestations be posted for named teaming partners and subcontractors — at white paper submission, or prior to award?

As required by RFS Section 5, 'Security & Compliance,' vendors must provide the status of their SPRS assessment and CMMC Level 2 self-attestation at the time of submission for all proposed team members.

17 Performance Measurement Will the Government provide the measured baseline manual coding accuracy referenced in SOO Section

5.1, and if so, at what point in the process?

The Government acknowledges the question. For the purposes of the white paper, vendors should base their submission on the information provided in the RFS and the attached draft SOO. Further clarification may be provided to vendors who are invited to subsequent phases.

18 Performance Measurement Regarding the Government-provided test data at Milestone 2, can the Government indicate the approximate volume, specialty mix, and whether the data is real or synthetic, and when it would be made available following award?

Per the draft SOO (e.g., Milestone 2), the Government will provide approved test data for the pre-production environment. For the Phase 3 live demonstration, RFS Section 6 states it 'shall use a vendor-provided sample data set.' Further details on Government-provided data will be furnished to vendors selected to advance to later phases.

19 Performance Measurement Is the stated volume of approximately 143,000 encounters daily the full enterprise in-scope volume, or the volume anticipated at the select military treatment facilities identified for Milestone 4 validation?

This response will be provided at a later date.

20 Invoicing Section 7.4 refers to per-encounter invoicing by complexity tier. Will the Government define the complexity tiers, or should offerors propose a tier structure?

The Government acknowledges the question. For the purposes of the white paper, vendors should base their submission on the information provided in the RFS and the attached draft SOO. Further clarification may be provided to vendors who are invited to subsequent phases.

21 N/A Request for a One-Week Extension to Submit White Papers Interested vendors will have until 28 Aug 2026 to submit white papers.

22 Scope

RFS §3 / SOO §1 — The problem statement references aged A/R “across multiple systems.” Beyond MHS GENESIS, which systems (e.g., legacy CHCS, TPOCS/ABACUS, DFAS financial systems) contain in-scope

A/R records, and will the Government provide extracts from each for ingestion?

This response will be provided at a later date.

23 Scope SOO §4.2 — Can the Government share the size and profile of the in-scope denied/aged A/R portfolio — total dollars, claim counts, aging distribution (30/60/90/120+), OHI payer mix, and number of MTFs in scope — to support an accurate Bill of Materials and Phase 2 pricing?

This response will be provided at a later date.

24 Scope

SOO §4.2, Milestone 2 — Will Government-provided pre-production test data include historical claim

(837) and remittance (835) transactions and denial history? What volume, time span, and payer mix should vendors plan for?

Per the draft SOO (e.g., Milestone 2), the Government will provide approved test data for the pre-production environment. For the Phase 3 live demonstration, RFS Section 6 states it 'shall use a vendor-provided sample data set.' Further details on Government-provided data will be furnished to vendors selected to advance to later phases.

25 Scope

SOO §4.2, Milestone 2 — Regarding the ≥[80]% “correlation match” against a human-audited sample of no less than 500 claims: how is a correlation match defined and scored (e.g., agreement on denial root cause, classification, recoverability determination)? Will the Government provide the human-audited sample, or is the vendor expected to fund the independent audit?

The values in brackets in the draft SOO represent the Government's current objectives. Vendors should use these values for planning purposes in their white paper submissions. These figures may be finalized during Phase 2 discussions or agreement negotiations.

26 Scope

SOO §4.2, Milestone 4 — For the requirement to autonomously generate appeal artifacts for ≥50% of “prioritized, recoverable claims”: is the prioritized, recoverable population defined by the vendor’s ranking model (subject to Government approval), or by Government-defined criteria?

The Government acknowledges the question. For the purposes of the white paper, vendors should base their submission on the information provided in the RFS and the attached draft SOO. Further clarification may be provided to vendors who are invited to subsequent phases.

27 Scope

SOO §5.2 — Will the Government provide pre-prototype baseline metrics (historical recovery rates, denial rates, aged A/R levels, net third-party collections per billable encounter) and define the measurement window against which improvement will be credited?

The Government acknowledges the question. For the purposes of the white paper, vendors should base their submission on the information provided in the RFS and the attached draft SOO. Further clarification may be provided to vendors who are invited to subsequent phases.

28 Automation Authority & Financial Controls

RFS §3 / SOO §6.1 — Please confirm that autonomous generation and submission of appeals to OHI payers without per-case human approval is permissible, provided each action carries a complete FFMIA-aligned audit trail — i.e., the human-approval requirement applies only to financial dispositions (write-off, adjustment, settlement), not to appeal generation or submission.

The Government acknowledges the question. For the purposes of the white paper, vendors should base their submission on the information provided in the RFS and the attached draft SOO. Further clarification may be provided to vendors who are invited to subsequent phases.

29 Automation Authority & Financial Controls

SOO §4.2 — Which channels are authorized for submitting appeals on the Government’s behalf (EDI 837, payer web portals, mail/print)? Does DHA have existing clearinghouse or EDI connectivity that vendors are required or encouraged to use?

The Government acknowledges the question. For the purposes of the white paper, vendors should base their submission on the information provided in the RFS and the attached draft SOO. Further clarification may be

30 Automation Authority & Financial Controls SOO §6.1 — Are there DHA policy or payer-agreement constraints on automated interaction with payer portals (e.g., credential management, portal terms of use) that the Government will facilitate or that vendors should account for?

The Government acknowledges the question. For the purposes of the white paper, vendors should base their submission on the information provided in the RFS and the attached draft SOO. Further clarification may be provided to vendors who are invited to subsequent phases.

31 Integration & Environment

SOO §3.2 / §5.2 — Success criteria specify data exchange with MHS GENESIS “via file transfer,” while Shared Objective 3 (Phase 2) references approved MHS GENESIS APIs and integration points. For the prototype period of performance, is integration limited to secure file transfer, or will FHIR R4 / HL7 APIs and Oracle Health integration points be available? Which integration points are currently approved?

As stated in RFS Section 5, 'EHR Architecture Experience,' the Government anticipates the successful vendor will collaborate with Leidos to integrate the solution into MHS GENESIS. The Government will facilitate this collaboration. Further details on the integration process will be provided during Phase 2 discussions.

32 Integration & Environment

RFS §5.1.1 — What is the process and expected timeline for engaging Leidos as the MHS GENESIS system integrator (technical onboarding, interface specifications, and access to test environments), and is Leidos support Government-furnished during the prototype?

As stated in RFS Section 5, 'EHR Architecture Experience,' the Government anticipates the successful vendor will collaborate with Leidos to integrate the solution into MHS GENESIS. The Government will facilitate this collaboration. Further details on the integration process will be provided during Phase 2 discussions.

33 Integration & Environment

SOO §4.2, Milestone 2 — Will the Government furnish the pre-production test environment and MHS GENESIS test workflows/data within a Government enclave, or is the vendor expected to host preproduction testing within its own IL4+ cloud environment?

Per the draft SOO (e.g., Milestone 2), the Government will provide approved test data for the pre-production environment. For the Phase 3 live demonstration, RFS Section 6 states it 'shall use a vendor-provided sample data set.' Further details on Government-provided data will be furnished to vendors selected to advance to later phases.

The Government will facilitate the necessary deidentified data and a sandbox environment leveraging both Leidos and Oracle as our partners. This effort is currently underway and in the planning stages. Vendors will be responsible for ensuring personnel meet necessary security clearance requirements to access data once placed in the sandbox environment. If this is determined to not be achievable in the time period allotted, vendor will be asked to host/test as an alternative option.

34 Integration & Environment

SOO §3.2 — If separate AC and ADM vendors are selected, how will the Government facilitate cross vendor coordination (interdependent algorithm learning, unified dashboards), and will the joint integration effort be separately scoped and funded?

As stated in RFS Section 5, 'EHR Architecture Experience,' the Government anticipates the successful vendor will collaborate with Leidos to integrate the solution into MHS GENESIS. The Government will facilitate this collaboration. Further details on the integration process will be provided during Phase 2 discussions.

35 Security & Authorization

RFS §5.1.4 / SOO §4.2 — Must the DoD IL4+ authorization be in place at white paper submission, at award, or by Milestone 3 (ATO-C)? Is a solution deployed within a partner’s or cloud service provider’s FedRAMPauthorized boundary acceptable to satisfy this requirement?

Per RFS Section 5, 'Security & Compliance,' the solution must possess, at a minimum, a valid DoD IL 4+ authorization. The RFS and the draft SOO describe a phased approach where authorization is a key milestone (Milestone 3: ATO-C). Vendors must clearly state their current authorization status and their plan to meet all security requirements as outlined in the RFS prior to being allowed to proceed with integration into the Production environment. Existing approvals outside the DOW may aide in acceleration but are not guaranteed reciprocity or approval. Once documentation is provided and assessed a better determination can be made by Government cyber teams.

36 Security & Authorization SOO §4.2, Milestones 1–3 — Will DHA sponsor reciprocity for existing Federal authorizations (e.g., ATOs held in other agency environments such as the VA Enterprise Cloud) to accelerate IATT and ATO-C timelines?

Per RFS Section 5, 'Security & Compliance,' the solution must possess, at a minimum, a valid DoD IL 4+ authorization. The RFS and the draft SOO describe a phased approach where authorization is a key milestone (Milestone 3: ATO-C). Vendors must clearly state their current authorization status and their plan to meet all security requirements as outlined in the RFS prior to being allowed to proceed with integration into the Production environment.

37 Security & Authorization RFS §5.1.4 — For teamed submissions, must each team member have a current SPRS assessment and CMMC Level 2 self-attestation at the time of white paper submission, or by award? Does this apply to team members who will not directly manage CUI?

As required by RFS Section 5, 'Security & Compliance,' vendors must provide the status of their SPRS assessment and CMMC Level 2 self-attestation at the time of submission for all proposed team members.

39 Schedule

SOO §8.1 / §8.2 — The §8.1 estimated timeline places ATO-C at approximately June 2027 and completion of the six-month audit monitoring period at October–December 2027 (13–16 month PoP), while §8.2 lists a target date of 30 June 2027 for both capabilities “integrated and validated in Production.” Please clarify which governs and what “validated” means for the 30 June 2027 target.

Per RFS Section 5, 'Security & Compliance,' the solution must possess, at a minimum, a valid DoD IL 4+ authorization. The RFS and the draft SOO describe a phased approach where authorization is a key milestone (Milestone 3: ATO-C). Vendors must clearly state their current authorization status and their plan to meet all security requirements as outlined in the RFS prior to being allowed to proceed with integration into the Production environment.

40 Schedule SOO §8.1 — The schedule objectives in §8.1 are expressed in terms of encounter categories and coding tests (Capability 1). Do the same milestone durations apply to Capability 2 (ADM), and what is the ADM analog of category-phased production entry and the six-month audit monitoring period?

Per the draft SOO Section 8, 'Schedule Objectives,' the overall schedule is derived from the authorization critical path and milestone durations from the date of award, not a fixed calendar date. All dates will be re-baselined from the actual date of award. The date to implement in Production will not be adjusted.

42 Pricing & Submission Process

SOO §7.4 / §8.3 — Production invoicing is described on a per-encounter basis by complexity tier, which appears specific to Autonomous Coding. For ADM production operations, will the Government consider alternative pricing structures (e.g., per-appeal, per-resolved-claim, or outcome-based pricing tied to dollars actually recovered)?

Per RFS Section 4, a high-level Bill of Materials is required with the white paper. Detailed cost and pricing information is not required for Phase 1. A 'cost breakdown of the prototype project' will be requested during Phase

2 from down-selected vendors , as stated in RFS Section 6.

43 Pricing & Submission Process RFS §4.1, Addendum 2 — If restrictive markings are applied to protect proprietary information from disclosure to Leidos and Oracle Health, will this limit or otherwise affect the Government’s evaluation of the white paper?

As stated in RFS Section 5, 'EHR Architecture Experience,' the Government anticipates the successful vendor will collaborate with Leidos to integrate the solution into MHS GENESIS. The Government will facilitate this collaboration. Further details on the integration process will be provided during Phase 2 discussions.

44 Pricing & Submission Process RFS §4.1 — May offerors include additional addenda beyond Addenda 1 and 2 (e.g., a security compliance matrix or architecture diagrams as an appendix), and if so, do they count against the ten-page limit?

As stated in RFS Section 4, 'Page Limits & Structure,' the ten-page limit is for the main body of the white paper. The cover page, Bill of Materials, and specified addenda do not count toward this limit. Diagrams and figures included in the main body of the white paper count against the ten-page limit. The NTDC statement is part of the main body and counts toward the limit, but may also be placed on the cover page if space allows.

46 Pricing & Submission Process

RFS §6, Phase 3 — For the live demonstration, may the vendor-provided sample data set consist of deidentified commercial (non-DoD) claims and denial data, or must it conform to MHS GENESIS data structures?

Per the draft SOO (e.g., Milestone 2), the Government will provide approved test data for the pre-production environment. For the Phase 3 live demonstration, RFS Section 6 states it 'shall use a vendor-provided sample data set.' Further details on Government-provided data will be furnished to vendors selected to advance to later phases.

47 N/A Based on the presentation by Dr. Rebecca Morrell at MHS, it was stated that MHS would supply one years' worth of data for the pilot or proof of concept. Can the Government clarify what the estimated volume/census of that one years' worth of data will comprise of - multiple MTFs, case specialty mix, etc.?

The Government acknowledges the question. For the purposes of the white paper, vendors should base their submission on the information provided in the RFS and the attached draft SOO, as Government requirements have changed. Further clarification may be provided to vendors who are invited to subsequent phases.

48 N/A What criteria is determined when the Government considers a case-type or sub-specialty validated?

The Government acknowledges the question. For the purposes of the white paper, vendors should base their submission on the information provided in the RFS and the attached draft SOO, as Government requirements have changed. Further clarification may be provided to vendors who are invited to subsequent phases.

49 RFS Section 1

Has DHA identified any attributes of the current process that are particularly burdensome or resistant to alteration that call for unique solutions or new approaches? Are there known causes for increased coding errors, a growing volume of denied claims, and limited ability to predict which claims will be denied before submission?

The Government acknowledges the question. For the purposes of the white paper, vendors should base their submission on the information provided in the RFS and the attached draft SOO. Further clarification may be provided to vendors who are invited to subsequent phases.

50 RFS Section 1 If separate AC and ADM vendors are selected, will DHA designate a lead integrator and issue an interface-control architecture?

As stated in RFS Section 5, 'EHR Architecture Experience,' the Government anticipates the successful vendor will collaborate with Leidos to integrate the solution into MHS GENESIS. The Government will facilitate this collaboration. Further details on the integration process will be provided during Phase 2 discussions.

51 RFS Section 3 For the AC and ADM Problem Statements, have targets been established for meaningful improvement levels?

The Government acknowledges the question. For the purposes of the white paper, vendors should base their submission on the information provided in the RFS and the attached draft SOO. Further clarification may be provided to vendors who are invited to subsequent phases.

52 SOO Section 3.1 Is the ~143K encounters/day (4.35M/month) figure (SOO §3.1) the full DHA enterprise-wide steady-state volume at Milestone 4, or specific to the initial pilot facilities/encounter categories tested at Milestone 2?

This directly sizes our database throughput assumptions.

The primary system for integration is MHS GENESIS. The draft SOO Section 4 provides the initial scope and priority encounter categories for testing. Further details regarding scope will be provided to vendors invited to Phase 2.

53 SOO

Is there a comparable scale figure (claim count and/or dollar value) for "active, open, and aged A/R records" to size the ranking/appeal-generation engine?

The Government acknowledges the question. For the purposes of the white paper, vendors should base their submission on the information provided in the RFS and the attached draft SOO. Further clarification may be provided to vendors who are invited to subsequent phases.

54 SOO Section 3.1 Does DHA/DHMSM PMO have an existing cloud enterprise agreement or ATO boundary (a specific hyperscaler GovCloud region, Cloud One, milCloud) vendors are expected to build within, or may vendors propose any independently FedRAMP High/DoD IL4+ authorized commercial environment?

Per RFS Section 5, 'Security & Compliance,' the solution must possess, at a minimum, a valid DoD IL 4+ authorization. The RFS and the draft SOO describe a phased approach where authorization is a key milestone (Milestone 3: ATO-C). Vendors must clearly state their current authorization status and their plan to meet all security requirements as outlined in the RFS prior to being allowed to proceed with integration into the Production environment.

55 N/A Can the government provide a sample file or data dictionary?

The Government acknowledges the question. For the purposes of the white paper, vendors should base their submission on the information provided in the RFS and the attached draft SOO. Further clarification may be

56 RFS Section 3

The government states: "The Government seeks primarily non-rules-based, AI/ML-enabled solutions".

This language is confusing. We believe you do not want a rules-based expert system, rather a modern LLM. However, even a modern LLM based AI will have to make determinations based on existing (and future) rules for AC and ADM processing. The solution must process AC and ADM based upon rules that define coding standards and grounds for ADM.

The Government acknowledges the question. For the purposes of the white paper, vendors should base their submission on the information provided in the RFS and the attached draft SOO. Further clarification may be provided to vendors who are invited to subsequent phases.

57 RFS Section 5.4

"How the solution proactively reduces future denials by optimizing coding accuracy, tuning autonomous coding functionality, and/or implementing configurable enterprise-level business rules.",. Does the government want this requirement to be part of a stand alone ADM system or have the ADM system use the output of the AC effort, not recreate its own AC capability?

The Government acknowledges the question. For the purposes of the white paper, vendors should base their submission on the information provided in the RFS and the attached draft SOO. Further clarification may be provided to vendors who are invited to subsequent phases.

58 RFS Section 9 What is the correct due date and time? The rfs states August 19, 2026 01:00 PM ET, while SAM states Aug

21, 2026 2:00 PM edt The solicitation has been extended to August 28, 2026. Please ensure you are viewing the most up-to-date version by searching by Title/Notice ID, or by using the Version toggle in the top-right corner.

59 Business and Volume Clarification Net Patient Revenue: Can the Government provide the annual Net Patient Revenue associated with the facilities and services included within the scope of this requirement?

The Government acknowledges the question. For the purposes of the white paper, vendors should base their submission on the information provided in the RFS and the attached draft SOO. Further clarification may be provided to vendors who are invited to subsequent phases.

60 Business and Volume Clarification Definition of Specialty Care: Please define what the Government considers to be Specialty Care for purposes of this requirement.

The Government acknowledges the question. For the purposes of the white paper, vendors should base their submission on the information provided in the RFS and the attached draft SOO. Further clarification may be provided to vendors who are invited to subsequent phases.

61 Business and Volume Clarification

Medical Subspecialty Classification: Please define what the Government considers to be Medical Subspecialty Care.

Is Diagnostic Cardiology included within the Medical Subspecialty category?

If so, can the associated encounter, claim, or coding volumes be separately identified and provided?

The Government acknowledges the question. For the purposes of the white paper, vendors should base their submission on the information provided in the RFS and the attached draft SOO. Further clarification may be provided to vendors who are invited to subsequent phases.

62 Business and Volume Clarification Denials Management Pricing Structure: For the Automated Appeals and Denials Management solution, is the Government seeking pricing based on a subscription model, a transactional model, or would either approach be acceptable?

The Government is looking for a vendor proposed model(s).

63 Business and Volume Clarification Outsourced Denials Management Costs: Is the Government willing to provide current outsourced denials management rates, or alternatively, a range of rates (e.g., low, average, and high cost ranges) to support solution modeling and ROI analysis?

Per RFS Section 4, a high-level Bill of Materials is required with the white paper. Detailed cost and pricing information is not required for Phase 1. A 'cost breakdown of the prototype project' will be requested during Phase

2 from down-selected vendors, as stated in RFS Section 6.

64 Business and Volume Clarification Volume Distribution by Category: Can the Government provide volumes and/or percentage distributions by category, including denial types, appeal types, specialties, care settings, or other relevant classifications?

The Government acknowledges the question. For the purposes of the white paper, vendors should base their submission on the information provided in the RFS and the attached draft SOO. Further clarification may be provided to vendors who are invited to subsequent phases.

Organizational Conflict of Interest (OCI)

Questions

Addendum 2 indicates that white paper responses may be shared with Leidos and Oracle Health. Please clarify whether the Government has assessed and addressed any actual, potential, or apparent

Organizational Conflicts of Interest (OCI) associated with these organizations' access to vendor-submitted information.

The Government intends to only share the absolute minimum information necessary to assist with MHS GENESIS integration. This only applies to those vendors whose solutions have been deemed to meet Gov't requirements.

Pricing and other sensitive information will not be shared.

66 Future Procurement Participation

Please confirm whether Leidos, Oracle Health, their affiliates, subsidiaries, teaming partners, or subcontractors will be eligible to compete for, support, advise on, or otherwise participate in any future acquisition resulting from this requirement. If eligibility is retained, please describe the OCI mitigation measures that have been implemented to protect proprietary information and prevent unequal access to information.

The Government intends to only share the absolute minimum information necessary to assist with MHS GENESIS integration. Pricing and other sensitive information will not be shared.

67 Protection of Proprietary Information

Please describe the safeguards, controls, and procedures established to ensure that proprietary, confidential, and competitively sensitive information submitted by respondents is protected from organizational conflicts of interest and is not used to provide any competitive advantage in future procurements related to this effort.

The Government maintains strict access controls for all submitted material. If technical information must be shared with system integrators (Leidos or Oracle Health) to facilitate MHS GENESIS integration planning, only the minimum technical information will be shared.

68 Non-Disclosure and Access Restrictions Please identify any non-disclosure agreements, firewall procedures, access restrictions, or other controls that will govern Leidos' and Oracle Health's review of industry responses to ensure the protection of respondent proprietary data.

Access to submitted material is restricted to specific Government personnel only.

69 RFS 1, 8, pp. 1, 7

The RFS states that the Government intends to award one or more prototype OTAs and may award whole solutions or partial components. What award structure does the Government currently anticipate for the prototype effort? Does the Government expect separate AC and ADM awards, and does it anticipate making more than one award for each Capability?

The Government anticipates awarding one or more fixed-price Prototype Other Transaction Agreements (OTAs).

As stated in the RFS, "The Government reserves the right to award multiple agreements, or make no award at all, resulting from this RFS"

70 RFS 9, p. 7

Would the Government consider extending the White Paper submission deadline to August 28, 2026, or to no fewer than five business days after publication of the Government's consolidated responses, whichever is later? Responses may materially change Offerors' proposed technical approaches, teaming arrangements, and prototype execution plans. Additional time would allow those clarifications to be incorporated into solutions that more accurately reflect the Government's intended prototype approach.

The solicitation has been extended to August 28, 2026. Please ensure you are viewing the most up-to-date version by searching by Title/Notice ID, or by using the Version toggle in the top-right corner.

71 RFS 1, p. 1; RFS 8, p. 7

The RFS states that the Government intends to award one or more prototype OTAs and reserves the right to make multiple awards for whole solutions or partial components. What award structure does the

Government currently anticipate: (a) one award covering both AC and ADM; (b) separate AC and ADM awards; (c) multiple competing awards within one or both capability areas; or (d) another structure?

Does the Government currently anticipate making more than one Autonomous Coding award?

The RFS states "The Government reserves the right to award multiple agreements, or make no award at all, resulting from this RFS. At its discretion, the Government may make awards for whole solutions, or partial components thereof."

72 RFS 9, p. 7

Would the Government consider extending the White Paper submission deadline to August 28, 2026, or to no fewer than five business days following publication of the Government's consolidated responses to industry questions, whichever is later? Responses concerning the required authorization boundary, acceptable hosting/deployment model, available MHS GENESIS interfaces, scope of required coding environments, data-rights expectations, multi-vendor integration requirements, and anticipated award structure may materially alter Offerors' technical architectures, teaming arrangements, cybersecurity approaches, licensing constructs, and implementation strategies. Providing additional time after the

Government's responses will allow Offerors to incorporate those clarifications and submit solutions that more accurately align with the Government's intended technical and acquisition approach.

The solicitation has been extended to August 28, 2026. Please ensure you are viewing the most up-to-date version by searching by Title/Notice ID, or by using the Version toggle in the top-right corner.

73 RFS 5.1.1, 6, pp. 4, 6–7

For purposes of the prototype evaluation, what level of MHS GENESIS integration is expected during each phase? Specifically, should the Phase 1 white paper propose a feasible integration approach, should Phase 3 demonstrate an actual MHS GENESIS interface, or is full MHS GENESIS integration expected only after prototype award in collaboration with Leidos?

As stated in RFS Section 5, 'EHR Architecture Experience,' the Government anticipates the successful vendor will collaborate with Leidos to integrate the solution into MHS GENESIS. The Government will facilitate this collaboration. Further details on the integration process will be provided during Phase 2 discussions.

74 RFS 5.1.4, p. 4

The RFS states that the proposed solution must possess a minimum DoD IL4+ authorization and that DHA will use the FedRAMP authorization to issue a mission-owner authorization. At what point in the prototype process must that authorization be in place? Must an Offeror possess the required authorization at white-paper submission or live demonstration, or may authorization be completed as part of prototype performance following award?

Per RFS Section 5, 'Security & Compliance,' the solution must possess, at a minimum, a valid DoD IL 4+ authorization. The RFS and the draft SOO describe a phased approach where authorization is a key milestone (Milestone 3: ATO-C). Vendors must clearly state their current authorization status and their plan to meet all security requirements as outlined in the RFS prior to being allowed to proceed with integration into the Production environment.

75 RFS 5.1.4, p. 4

Is a commercially available SaaS autonomous-coding solution hosted within an authorized commercial cloud an acceptable technical approach for this prototype? If so, please clarify whether the Government expects the application itself to possess a separate authorization or whether it may operate within and inherit applicable controls from an authorized cloud/security boundary.

Per RFS Section 5, 'Security & Compliance,' the solution must possess, at a minimum, a valid DoD IL 4+ authorization. The RFS and the draft SOO describe a phased approach where authorization is a key milestone (Milestone 3: ATO-C). Vendors must clearly state their current authorization status and their plan to meet all security requirements as outlined in the RFS prior to being allowed to proceed with integration into the Production environment.

76 RFS 6, Phase 3, p. 7

The RFS states that the Phase 3 live demonstration will use a vendor-provided sample data set. May an Offeror demonstrate its currently operational commercial AC platform in its existing secure environment, with Government-specific authorization and MHS GENESIS integration completed during prototype performance after award?

Per the draft SOO (e.g., Milestone 2), the Government will provide approved test data for the pre-production environment. For the Phase 3 live demonstration, RFS Section 6 states it 'shall use a vendor-provided sample data set.' Further details on Government-provided data will be furnished to vendors selected to advance to later phases.

77 RFS 5.1.1, p. 4

The Government anticipates collaboration with Leidos to integrate the successful solution into MHS GENESIS. What Government and Leidos integration support, technical documentation, test environments, and interface access does the Government anticipate making available to prototype awardees?

As stated in RFS Section 5, 'EHR Architecture Experience,' the Government anticipates the successful vendor will collaborate with Leidos to integrate the solution into MHS GENESIS. The Government will facilitate this collaboration. Further details on the integration process will be provided during Phase 2 discussions.

78 RFS 5.3, pp. 5–6; Draft SOO 4.1, 5.1, pp. 3–4

The RFS describes AC across inpatient, outpatient, specialty, and ancillary environments, while the Draft SOO identifies an initial set of primarily outpatient/clinic coding tests. For purposes of Phase 1 evaluation and prototype planning, what encounter categories and coding environments should Offerors treat as the required prototype scope? Is inpatient institutional coding required during the prototype, or is it principally an enterprise-expansion objective?

The Government acknowledges the question. For the purposes of the white paper, vendors should base their submission on the information provided in the RFS and the attached draft SOO. Further clarification may be provided to vendors who are invited to subsequent phases.

79 RFS 5.3, p. 5; Draft SOO 2.2, 4.1, pp. 1, 3 Should Offerors use the Draft SOO's proposed ≥95% code-level accuracy and autonomous-coverage thresholds as the Government's current planning assumptions for the white paper, or will specific prototype performance thresholds be established later in the evaluation/award process?

The Government acknowledges the question. For the purposes of the white paper, vendors should base their submission on the information provided in the RFS and the attached draft SOO. Further clarification may be provided to vendors who are invited to subsequent phases.

80 RFS 5.3, p. 5

The RFS asks Offerors to identify excluded encounter volume and projected autonomous coding rates. Is the Government open to a prototype that initially supports a defined subset of encounter categories at high autonomous coverage and accuracy, with additional specialties/care environments phased in during prototype performance?

The primary system for integration is MHS GENESIS. The draft SOO Section 4 provides the initial scope and priority encounter categories for testing. Further details regarding scope will be provided to vendors invited to Phase 2.

81 RFS 5.2, p. 5; Draft SOO 6.2, p. 5 Is a proprietary, commercially available autonomous-coding engine acceptable as the core of the prototype solution where the Offeror can integrate, maintain, patch, and retrain the product but the Government does not receive the vendor's proprietary source code or base-model weights?

This response will be provided at a later date.

82 RFS 1, p. 1; Draft SOO 3.2, p. 2

The RFS permits AC to be proposed independently from ADM. For an AC-only prototype Offeror, what interoperability with a separately selected ADM solution must be demonstrated during the prototype? Is standards-based exchange of agreed data and outcomes sufficient, or does the Government expect direct sharing of models, training artifacts, or proprietary algorithmic components?

This response will be provided at a later date.

83 RFS 1, p. 1; Draft SOO 3.2, p. 2

The RFS permits AC and ADM to be proposed separately, while the SOO requires separate vendors to implement unified reporting and “interdependent algorithm learning.” For an AC-only Offeror, please clarify the minimum required technical integration with a separately awarded ADM solution. Specifically, does the Government expect standardized data/API exchange and shared outcomes, or must independently owned models directly exchange training data, features, model parameters, or other proprietary learning artifacts?

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