TOP_2021_Solicitation_Questions_10-1-19.pdf

TOP 2021 Solicitation Questions and Responses

HT9402-19-R-0001

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No: Solicitation Citation & Paragraph

Question/Comment DHA Response

1 Section B, Supplies or Services and Prices/Costs

There is no CLIN for the current Preferred Provider Network (PPN) in the Philippines. Is the contractor not required to establish any PPNs overseas?

The contractor is required to establish a PPN in the Philippines in accordance with Section J, Attachment J-17, Draft TOM Chapter 24, Section 29. See Section B, Supplies or Services and Prices/Costs Continuation, CLIN X001 description which states in part, “administrative and support services associated with providing managed care services to TOP Prime Enrolled beneficiaries and any other TRICARE beneficiaries who are not included in CLINs X002 and X003.”

2 Section B, Supplies or Services and Prices/Costs and Section L, Instructions, Conditions, and Notices to Offerors, paragraph L.8.7., “Any costs for administrative and support services associated with TRICARE beneficiaries who are not included in CLINs X001 and X002 should be incorporated into the price proposed under CLIN X001.”

The contractor is assuming a significant risk for costs associated with a population (e.g. non-TOP Prime or Prime Remote) that is based on a population (e.g. TOP Prime) that it has no control over. Would DHA consider adding a CLIN for these additional beneficiaries and the service they require specifically?

The DHA provided the TRICARE Select enrollment by region as part of the data package. See Section L, Attachment L-1a, List of Data Files, 3. Enrollment Data. “TRICARE Select.”

The DHA does not expect the TOP TRICARE Select population to vary significantly. To address risk, DHA revised Section G. to add paragraph G.17., Variation in Quantity. See Solicitation Amendment 0001 revised Section G, Paragraph G.17., Variation in Quantity.

Section C, Description/Specifications/Work Statement (PWS), paragraph C.8.4, bulleted list, 10th bullet

Please define “Beneficiary Communications.”

Currently, DHA Communications is responsible for this area.

Can the DHA please adjust the bullet point to state only

See Solicitation Amendment 0001 revised Section C, paragraph C.8.4.

HT940219R0001 Page 2 of 31 beneficiary communications produced by the contractor?

4 Section C, Description/Specifications/ Work Statement (PWS), paragraph C.8.4, bulleted list, last bullet

What is DHA’s QM/QI measurement expectation to ensure the Contractor is fulfilling “Direct and Purchased-Care Integration” to an acceptable standard?

Section C, paragraph C.8.3.

directs the contractor to “employ best business practices to facilitate and improve integration between the purchased and direct care systems.” The Government expects the contractor to develop and implement best business practices, adhere to these practices, and continue to improve the integration through the contractor’s QM/QI program as specified in paragraph C.8.4.

The Government will monitor the requirement at Section C, paragraph C.8.4.

utilizing CDRL P100, Internal Quality Management/Quality Improvement Program Plan and CDRL Q020, Internal Quality Management/Quality Improvement Report to ensure that the contractor’s QM/QI program is acceptable.

5 Section C, Description/Specifications/ Work Statement (PWS), paragraph C.8.4 a.) Does Translation Quality Monitoring apply to both translators and interpreters?

Does DHA consider those to be the same skillset?

Translation Quality Monitoring applies to any translation action, documentation translation as defined in Section C, paragraphs C.11.16 and C.13, and translation support at the time of service as identified in paragraph C.11.12. The DHA does not use the term “interpreter” in the Solicitation. The DHA views document translation as a separate skill set from

HT940219R0001 Page 3 of 31 interpretation. See response to question 33

6 Section C, Description/Specifications/ Work Statement (PWS), paragraph C.11.1, Network Development.

C.11.1. Network Development states: The contractor shall provide a managed, stable, high-quality network of individual and institutional PCSPs which promotes access, clinical quality, beneficiary and provider satisfaction, and best value health care for TOP enrollees in the MTF locations identified in Section J, Attachment J-1, TOP Prime Locations, and the network-designated remote locations identified in Attachment J-2, TOP Prime Remote Locations.

The contractor shall refer to TOM, Appendix B, for definition of best value health care.

a.) Q: There is no Appendix B in the Change 50 version of the TOM. Should this refer to Appendix A?

See Solicitation Amendment 0001 revised Section C, paragraph C.11.1.

7 Section C, Description/Specifications/ Work Statement (PWS), paragraph C.11.1.5.

Part of C.11.1.5. states: The contractor shall automatically add non-network designated remote locations when ADSMs/ADFMs are assigned to overseas locations in which a TOP Prime or a TOP Prime Remote/non-network designated remote location does not exist and notify the TOPO who will request the Contracting Officer to modify the contract to add the location to Section J, Attachment J-3.

The contractor is responsible for performing enrollment functions and therefore will be aware when an ADSM/ADFM is assigned to a non-network designated remote location.

See Solicitation Amendment paragraph C.11.1.

HT940219R0001 Page 4 of 31 a.) Q: Would DHA consider notifying the Contractor when an ADSM/ADFM is assigned to these locations, so that the Contractor can begin to identify possible PCSPs? The concern is that by the time an ADSM/ADFM needs care, it could add time to their need for a Contractor to identify possible PCSP non-network contacts.

8 Section C, Description/Specifications/ Work Statement (PWS), paragraph C.11.7.1.

C.11.7.1 states: The contractor shall profile and monitor provider performance in an ongoing manner using profiling/monitoring parameters that address, but are not limited to, cost of care, clinical quality of care to include population health/prevention practices as appropriate, patient complaints and access. The contractor shall establish its provider profiles and parameters based on the host-nation’s current and evolving sources of outcomes and performance data to include outcome data, preventive measures data, and laboratory data. If the host-nation does not track outcomes and performance data, the contractor shall establish a methodology to profile and monitor provider performance.

No. Provider profiles are propriety to the incumbent contractor, and DHA cannot release them.

HT940219R0001 Page 5 of 31 a.) Question: Will DHA provide the incoming contractor a copy of current provider profiles to maintain past performance and historical tracking of provider’s performance?

9 Section C, Description/Specifications/ Work Statement (PWS), paragraph C.11.5.2., “The contractor shall ensure telemedicine consultation is considered as part of the patient’s plan for medical care prior to, or in conjunction with recommending Medical Temporary Duty (TDY).

Telemedicine shall be utilized only when the patient’s standard of care is guaranteed to be the same whether the patient is seen in person or via teleconsultation.”

a.) To which health care standard shall the contractor guarantee to be the same whether patient is seen in person or via teleconsultation? We presume that the standard is to the host nation.

b.) How will DHA measure this guarantee?

a.) See Solicitation Amendment 0001 revised Section C, paragraph C.11.5.2.

The patient’s standard of care is expected to be the same whether the patient is seen in person or via teleconsultation. This is not necessarily the host nation standard of care since an in-person visit by the patient could occur in a country other than the host nation.

b.) See Solicitation Amendment 0001 revised Section C, paragraph C.11.5.2.

The DHA intends to develop and execute contract oversight needed to review all aspects of the contractor’s telemedicine process, which includes procedures for ensuring the patient is treated under equivalent standards of care, whether the patient is seen in person or via teleconsultation.”

10 Section C, Description/Specifications/ Work Statement (PWS), paragraph C.11.7.1., “The contractor shall establish its provider profiles and parameters based on the host nation’s current and evolving

Can DHA clarify what is meant by “outcomes and performance data” as it relates to laboratory data?

“Laboratory outcome data” is a standard term used in the health care industry.

The offeror determines how it will incorporate laboratory outcome data into its

HT940219R0001 Page 6 of 31 sources of outcomes and performance data to include outcome data, preventative measures data, and laboratory data.”

profiling methodology if the host nation tracks outcome/performance data for laboratories.

11 Section C, Description/Specifications/ Work Statement (PWS), paragraph C.11.7.2., “In locations identified in Section J, Attachment J-1, TOP Prime Locations and Attachment J-2, TOP Prime Remote Locations, the contractor shall ensure 75% of network providers are in the 75% percentile or higher with respect to clinical quality as defined in paragraph C.11.6.”

Is it a correct assumption that the contractor shall determine through a defined process the denominator (75% percentile with respect to the clinical quality defined in C.11.6.)? If this is not the case, then this statement is not able to be calculated or insufficient information has been provided by DHA.

Yes. The contractor is responsible for developing and specifying the methodology for determining the 75% percentile in CDRL P030, Network Implementation Plan.

12 Section C, Description/Specifications/ Work Statement (PWS), paragraph C.11.10.1., “One measure of network adequacy or inadequacy shall be the percentage of paid claims for TOP Prime and TOP Prime Remote enrollees that are submitted by network providers, after excluding certain claims associated with care that was not specifically authorized by the contractor including, but not limited to, Point of Service (POS) claims, Other Health Insurance (OHI), pharmaceuticals, ancillary services except MRIs and PET scans, any durable medical equipment (DME) that does not require an authorization, preventive services, medical supplies that do not require an authorization, emergency care, etc. The contractor shall refer to Section H, Special Contract requirements, paragraph H.6.4.

for a description of the network adequacy calculation. Section J, a.) The calculations for TOP Prime and TOP Prime Remote should be separate.

TOP Prime Remote locations continue to change and one of the TOP contract objectives is to provide a flexible and adaptable delivery model. This adequacy requirement constrains the contractor to deliver a flexible and adaptable delivery model in high evolving locations.

b.) TOP Prime remote has various non-network designated locations identified in J-3. These locations need to be excluded from the calculations and identified in J-6 as excluded.

a.) The DHA does not believe including both TOP Prime and TOP Prime Remote in the network adequacy calculation prevents the contractor from delivering a flexible and adaptable delivery model.

The DHA will not calculate TOP Prime and TOP Prime Remote network adequacy separately.

b.) Section J, Attachment J- 6, Network Adequacy Calculations/Exclusions, states that Prime Remote enrollees in TOP Prime Remote-Unspecified DMIS locations are excluded. This exclusion applies to non-network designated locations.

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Attachment J-6, Network Adequacy Calculations/Exclusions, identifies those services and supplies excluded from the Government’s network adequacy calculations.”

13 Section C, Description/Specifications/ Work Statement (PWS), paragraph C.11.11. and Section J, Attachment J-12, Negotiated Rate Locations.

Health care costs in Japan are regulated by the Ministry of Health, Labor and Welfare;

“The government regulates almost all aspects of the universal public health insurance system. By law, the national and local governments endeavor to ensure to the nation a system that will efficiently provide high quality, appropriate medical care (Medical Care Law, Article 1-3). The national government sets the fee schedule and subsidizes local governments, insurers, and providers. It also establishes and enforces detailed regulations for insurers and providers (4a).”

Based on this knowledge of Japanese providers, we suggest that Japan be excluded from this requirement.

See Solicitation Amendment 0001 revised Section J, Attachment J-12, Negotiated Rate Locations.

14 Section C, Description/Specifications/ Work Statement (PWS), paragraph C.11.11.1., “The contractor shall establish the cost-per-claim baseline utilizing claims data from FY17-FY20.”

The cost-per-claim baseline should exclude providers that have already offered negotiated rates. Will DHA consider adding a provision to this section that will allow DHA and the successful contractor to establish a proper baseline during transition-in?

No, DHA has determined the baseline development required in Section C, paragraph C.11.11.1, establishes a proper baseline.

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15 Section C, Description/Specifications/ Work Statement (PWS), paragraph C.11.13.1., “The contractor shall produce regional provider education materials. The DHA Strategic Communications and the TOPO will review and approve education materials prior to the contractor disseminating them. The contractor shall produce provider education materials in the following languages: German, Italian, Korean, Japanese, Arabic, Spanish, French, and Turkish.”

a.) Does DHA wish to review only the English version of the provider education materials or the foreign language versions as well?

b.) What KPI will DHA impose with DHA Strategic Communications and TOPO to ensure timely review and return of provider educational materials? We are concerned that having multiple stakeholders in the review process will delay the contractor’s ability to quickly develop and educate providers.

a.) The DHA will review only English versions of provider education material.

b.) The DHA will review and return materials in sufficient time for the contractor to meet the requirements stated in Section C, paragraph C.11.13.

16 Section C, Description/Specifications/ Work Statement (PWS), paragraph C.11.16., “MTFs with internal translation capability may elect to receive untranslated consult reports.”

a.) Can DHA specify which MTFs currently have internal translation capability and wish to translate their own medical reports going forward?

b.) How many pages do the MTFs that want the contractor to translate the medical reports receive per year?

c.) How many providers, by MTF, currently submit medical reports to the MTFs?

It is difficult to establish fixed pricing for this effort without determining how many documents will need to be translated. We suggest that the process remain that the providers submit the medical reports directly to the MTFs including a.) No. DHA does not have information on which MTFs have internal translation capabilities.

b.) DHA does not have that information c.) DHA does not have that information

The DHA provided an estimate on the overall number of translations required. See Solicitation Amendment 0001 revised Section B, Supplies or Services and Prices/Costs Continuation, CLINs X005 and X006.

HT940219R0001 Page 9 of 31 collection facilitated by the contract, the MTFs then decide whether translation is required, and if necessary submit the medical reports back to the contractor to be translated under section C.19.

The contractor will invoice against CLINs X005 and X006 for all medical records translations per Section C, paragraphs C.11.16., C.13.3.3.5., C.13.4.1.1., C.13.4.2.3., and C.13.4.2.3.4.

The contractor is expected to meet the requirements in paragraph C.11.16., which states the contractor will translate and return consult reports to the referring MTF within 30 business days after the appointment unless agreed on in CDRL R190, Statement of Responsibilities

(SOR).

See Solicitation Amendment 0001 revised Section G, Paragraph G.17., Variation in Quantity.

17 Section C, Description/Specifications/ Work Statement (PWS), paragraph C.11.16.1., “The contractor shall ensure network providers provide a complete trauma medical report at the time of transfer to the MTF for all TRICARE Prime and Prime Remote trauma patients.

The contractor shall ensure a complete copy of the medical report is provided to the MTF within 3 calendar days after transfer of a TRICARE Prime or Prime Remote trauma patient from a non-network facility to a

MTF.”

a.) A complete trauma medical report is not feasible to obtain at time of incident.

An initial report is typically provided, but it may not be complete. Will DHA consider changing “complete” to “initial” in this section?

b.) The contractor has limited or no influence over non-network providers.

Furthermore, three calendar days is often outside “usual and customary” processes for many providers. This is not achievable over weekends or holidays. Will DHA consider changing it to five business days and

a) See Solicitation Amendment 0001 revised Section C, paragraph C.11.16.1.

b.) See Solicitation Amendment 0001 revised Section C, paragraph C.11.16.1. This requirement applies to both network and non-network providers.

HT940219R0001 Page 10 of 31 adding a provision that this is on a best efforts basis?

c.) Will DHA consider modifying the service level agreement (SLA) (e.g.

within 3 calendar days) to be identified in the MTF SOR so that host nation laws and regulations are complied with and understood between the contractor, DHA and the MTF?

c.) CDRL R160, SOR with TAO Eurasia-Africa Director; CDRL R170, SOR with TAO Latin America & Canada Director; CDRL R180, SOR with TAO Pacific Director; and CDRL R190, SOR with Military Treatment Facility (MTF), may reference contract requirements as necessary but shall not alter contract requirements.

18 Section C, Description/Specifications/ Work Statement (PWS), paragraph C.11.16.1.2., “A complete trauma medical report shall include an admission history and physical, operative reports, copies of all diagnostic reports (MRIs, CAT Scans, x-rays, labs, etc.), and a formal discharge summary. On a best effort basis, the contractor shall ensure operative reports include pre-and-post surgery diagnoses, patient position and preparation, narrative summary of the surgical techniques and approaches, specimens or tissue samples removed, specific type/brand/location of any implants inserted, estimated blood loss, unexpected findings and/or complications, how the operative site was closed, and patient condition at the end of the operation.”

The definition of medical report here will often be beyond what is required to provide medical care continuity. Further, not all lab reports will be available, since many will be in process. Moreover, a full dictated discharge summary within three calendar days is outside usual and customary clinical practice. This includes within the United States. For example, MRIs and CT scans may not be released as they may not be formally read by a radiologist.

a.) Will DHA rephrase the definition of a “complete trauma medical report” to that which is necessary for continuity of care (e.g.

removing the specific listing of reports)? This can be identified in the MTF SORs to accommodate the host nation providers and MTF differences.

a.) See Solicitation

C.11.16.1.2.

HT940219R0001 Page 11 of 31 b.) Will DHA consider decoupling the timeline requirements for a complete medical report from that which is initially necessary for continuity of care? In other words, the contractor can provide what is necessary initially for continuity of care and then pursue a complete medical report in line with the provider’s completion of the relevant medical records.

b.) See Solicitation

Section C, paragraph C.11.16.1.2.

19 Section C, Description/Specifications/ Work Statement (PWS), paragraph C.11.18., “The contractor shall comply with the specific requirements and additional information regarding PCSPs and facilities in TPM Chapters 7 and 11, TOM Chapter 5, and Section J, Attachment J-17, Draft TOM Chapter 24, Section 4.”

TOM Chapter 24, Section 4, paragraph 3.2.3 states, “Network provider agreements shall require network providers to render individual consultation reports to referring MTFs.”

This is in conflict with the requirements as outlined throughout section C regarding medical documentation collection, translation and transmission to the MTFs. Can DHA please specify the process that the contractor must adhere to? Does DHA want the reports transmitted directly to the MTF and then the MTF decides whether translation is necessary or not?

The DHA requires the contractor to obtain, translate and return consult reports to the referring MTF as stated in Section C, paragraph C.11.16.

See Solicitation Amendment 0001 revised Section J, Attachment J-17, Draft TOM Chapter 24, Section 4.

20 Section C, Description/Specifications/ Work Statement (PWS), paragraph C.12.3., “TRICARE Select” a.) Can the DHA please provide a forecast for the life of the TOP contract the number of TRICARE Select beneficiaries and the percentage that pay by credit card? This data is needed to ensure that credit card fees a.) The DHA provided the TRICARE Select enrollment by region as part of the data package. See Section L, Attachment L-1a, List of Data Files, 3. Enrollment Data. “TRICARE Select.”

The DHA does not expect the TOP TRICARE Select

HT940219R0001 Page 12 of 31 can be appropriately forecasted and priced.

b.) Can DHA identify if any Preferred Provider Networks have to be established for the TRICARE Select beneficiaries?

population to vary significantly from the data provide to offerors in Section L, Attachment L-1a, List of Data Files, 3.

Enrollment Data.

“TRICARE Select.”

See Solicitation Amendment 0001 revised Section L, Attachment L-6, TOP TRICARE Select and Total Call Volume Data. The DHA does not have data on the number of TRICARE Select beneficiaries who pay by credit card. Anticipating the volume of credit card payments is an offeror’s business decision.

b.) The contractor is required to establish a PPN in the Philippines in accordance with Attachment J-17, Draft TOM Chapter 24, Section 29.

See Solicitation Amendment 0001 revised Attachment J- 17.

21 Section C, Description/Specifications/ Work Statement (PWS), paragraph C.13.2.1., “The contractor shall provide utilization management for all eligible beneficiaries except for TRICARE-Medicare dual-eligible beneficiaries when they receive care in the Commonwealth of Puerto Rico, Guam, American Samoa, the Northern Marianas, and the United States Virgin Islands.”

The language in these two paragraphs is at odds with each other. The language in C.13.2.3. is more exclusive as it includes MTF enrollees and transient beneficiaries.

Can DHA clarify the language in these two sections?

Section C, paragraph C.13.2.1. describes the scope of the utilization management program.

Paragraph C.13.2.3. details the population subset, which requires constant assessment for possible utilization management based on the criteria specified in paragraphs C.13.2.3.1.

through C.13.2.3.3.

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Paragraph C.13.2.3, “At a minimum, the contractor’s utilization management program shall identify and continually assess all beneficiaries for possible utilization management excluding MTF enrollees, transient beneficiaries, and TRICARE for Life beneficiaries living in US territories or commonwealths…”

22 Section C, Description/Specifications/ Work Statement (PWS), paragraph C.13.3.3.2., “Daily written clinical updates shall be provided to the MTF PCM or designee no later than 1700 hours in the time zone of the MTF.”

a.) We assume that the daily report shall be only applicable after the first full day of admission. In other words it is unreasonable to assume that a daily report shall be expected at 1700 hours if a beneficiary is admitted at 1659 hours. Can DHA please clarify?

b.) Additionally, due to normal working arrangements for treating doctors that do ward rounds and case reviews often between clinics or surgeries;

important clinical information may not be available by 1700 on the day it is received. Will DHA consider submission of the daily written clinical updates to be the next business day?

a.) The daily report is applicable to the first day of admission. Section C, paragraph C.13.3.3.2 states, “If the contractor cannot submit a clinical update by the required time, the contractor shall provide the MTF PCM with a written explanation as why it cannot provide the written update.”

b.) Daily updates shall be provided by 1700, and include any information for the prior 24 hours.

23 Section C, Description/Specifications/ Work Statement (PWS), paragraph C.13.3.3.5., “The contactor shall employ strategies to obtain relevant medical documentation, associated with the inpatient admissions medically managed.

Relevant medical documentation shall include the final discharge a.) We suggest that the Government clarify their definition of “relevant medical information” to mean information required for care continuity as defined by the releasing provider.

a.) The DHA medical staff carefully evaluated MTF medical documentation requirements when defining “relevant medical documentation” The definition in paragraph C.13.3.3.5 accurately describes the requirement and the DHA’s intent.

HT940219R0001 Page 14 of 31 summary, full copies of pertinent labs/pathology reports, pending labs/pathology reports, procedure reports, and specialty services reports. The contractor shall translate and upload relevant medical documentation to the MTF PCM or designee (e.g. case manager) no later than 15 business days after discharge.

The contractor shall obtain and translate relevant medical documentation within 5 days after discharge, for specific cases that are identified by the MTF PCM or designee (e.g. case manager) as urgent for continuity of care.”

b.) “Relevant medical documentation” should read, “medically relevant documentation.”

c.) The language requiring a 15 business day should be on a best effort basis given the various regulations the TOP contractor must comply with on a location by location basis.

d.) Unless DHA can provide a blanket Release of Medical Information Form (ROMIF) for all TRICARE beneficiaries, acquisition of a ROMIF from a beneficiary will prevent securing medical records and translations within 5 days;

thus making this requirement unachievable.

e.) Does the Government mean 5 calendar days or 5 business days? Many provider Records Departments are closed on weekends and holidays.

b.) The DHA believes the term “relevant medical documentation” is an accurate description.

c.) The contactor is expected to use its relationship with network providers and influence as a payer to facilitate the expedient acquisition of medical reports.

d.) See Solicitation Amendment 0001 revised

C.13.3.3.5.

e.) See Solicitation

Section C, paragraph C.13.3.3.5.

24 Section C, Description/Specifications/ Work Statement (PWS), paragraph C.13.4.1.2., “In its capacity as the PCM, the contractor shall review PCSP outpatient medical documentation and verify the beneficiary received recommended follow on care to include purchased-care ancillary services.”

The term “verify” is vague, and requires clarification.

We suggest the term be changed to “assure beneficiary awareness.” As currently stated, “verify” implies the contractor is responsible for beneficiary behavior.

See Solicitation Amendment paragraph C.13.4.1.2.

25 Section C, a.) Please identify what connectivity and security a.) The contractor is expected to adhere to the

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Statement (PWS), paragraph C.13.4.2.3, “The contractor shall translate and upload all purchased-care inpatient medical management documentation to include any admission notes, clinical updates, and discharge summaries to a Government-designated system, such as the Health Artifact and Image Management Solution.”

requirements are needed to upload information into the Government-designated system.

b.) Please clearly identify which Government-designated system it will be since this is a fixed price contract and the system needs to be known in order to ensure costs are considered.

c.) These same statements apply to any other section with an unnamed Government-designated system.

TRICARE Manuals and Statutory and Regulatory Authority citations identified in Section C, paragraphs C.3.1.1. and C.3.1.2.; and Section I, DFARS Clause 252.204-7012.

b.) The Government has not determined the designated system. The DHA will specify the designated system during transition-in.

c.) The Government will identify designated systems during transition-in. The Government designated system for processing referrals (Section C, paragraph C.4.3.) is anticipated to be the existing Referral Management System (RMS). Government designated systems may change during the life of the contract.

26 Section C, Description/Specifications/ Work Statement (PWS), paragraphs C.14.4. and C.14.1, “Medical evacuation services for all beneficiaries listed in paragraph C.14.1. shall be provided on a cashless/claimless basis.”

a.) C.14.1. lists all TRICARE eligible beneficiaries. There is no change in the TRICARE Manual requirements for TRICARE Select beneficiaries to seek aeromedical evacuation care through the TOP contractor.

Therefore, it is impossible to ensure services can be provided on a cashless/claimless basis.

Can DHA please clarify the intent of this paragraph?

a.) Section C, paragraph C.14.1. identifies the TRICARE-eligible beneficiaries entitled to receive cashless/claimless aeromedical evacuation service. The contractor is not required to provide cashless/claimless aeromedical evacuation for TRICARE Select enrollees unless the TRICARE Select enrollee is an ADFM.

Section J, Attachment J-17, Draft TOM Chapter 24, HT940219R0001 Page 16 of 31 b.) There is only one CLIN for medical evacuation administrative support and it is limited to transient beneficiaries. Does DHA intend to add CLINs for all other TRICARE beneficiaries given the administrative costs associated with the requirements in C.14?

Section 7, paragraph 2.1, states that the contractor shall arrange aeromedical evacuation services for ADFMs enrolled to TRICARE Select who require evacuation services.

b). No. The offeror should include administrative costs for evacuation services provided to non-transient beneficiaries under CLINs X001 and X002.

26 Section C, Description/Specifications/ Work Statement (PWS), paragraph C.14.7, “The contractor shall provide copies of the invoices from its air ambulance providers showing the costs for each of these categories.”

Most international air ambulance providers do not provide the level of detail being requested by this paragraph. If this level of detail is requested it can increase the administrative costs for the evacuation.

Will the DHA consider simply receiving a copy of the invoice from the air ambulance provider without the categorical breakdown?

No. The Government requires this information for administrative and auditing purposes. It is part of the contractor’s administrative and support requirements to obtain, retain, and provide (when requested) the required documentation.

28 Section C, Description/Specifications/ Work Statement (PWS), paragraph C.16.9.2, “The TOP contractor shall employ an independent third-party subcontractor to review 100% of the contractor’s audited claims for coding accuracy.”

To achieve this requirement with the necessary skillsets of language, overseas healthcare understanding and US healthcare industry practices the contractor may need to employ several third-party subcontractors. We are unaware of any single organization that could accomplish the requirement.

In order to maximize the potential return on investment will DHA

No. Limiting this requirement to the top 10 foreign countries will leave a substantial subset of claims unaudited. The DHA will not restrict this requirement to apply to the top 10 foreign countries by claims paid.

HT940219R0001 Page 17 of 31 consider restricting this requirement to apply to the top 10 foreign countries by claims paid?

29 Section C, Description/Specifications/ Work Statement (PWS), paragraph C.16.16 and TSM Chapter 2.

a.) Would DHA be open to a Contractor using their own claims/encounter system that would provide claims payment information, as long as the data is in a format that DHA could load into TEDs?

No. The contractor is responsible for meeting the requirements of Section C, paragraph C.16.16 and TSM Chapter 2. The contractor is responsible for submitting data into TEDS.

30 Section C, Description/Specifications/ Work Statement (PWS), paragraph C.19., Translation Services a.) Does DHA intend that all medical records that are required by sections C.11.16., C.13.3.3.5., C.13.4.1.1., C.13.4.2.3., and C.13.4.2.3.4. be billable against CLINs X005 and X006?

b.) If not, can DHA provide the number of medical records that will need to be translated for these requirements? The contractor needs a basis of estimate in order to put in a fixed price under CLINs X001 and X002.

a.) Yes. The contractor will invoice against CLINs X005 and X006 for all medical records that are translated per the requirements stated in translations (Section C, paragraphs C.11.16., C.13.3.3.5., C.13.4.1.1., C.13.4.2.3., and C.13.4.2.3.4.)

b.) See Solicitation Amendment 0001 revised Section B, Supplies or Services and Prices/Costs CLINs X005 and X006.

See Solicitation Amendment 0001 revised Section G, Paragraph G.17., Variation in Quantity.

31 Section C, Description/Specifications/ Work Statement (PWS), paragraph C.19.4.1., “The certifying linguist must be credentialed by a recognized accreditation body for the specific language/dialect of the material translated.

Certifying linguists must also be credentialed by a recognized accreditation body for medical translation.”

Many accreditation bodies such as the American Translators Association provide certification in some languages, but certainly not all of the languages listed on the PWS. Many languages have no accreditation or certification that is commonly available. Can this requirement be waived for those languages where no

See Solicitation Amendment 0001 revised Section C, paragraphs C.19.4.1.C.19.4.2 and C.19.5.

HT940219R0001 Page 18 of 31 accreditation or certification is available?

32 Section C, Description/Specifications/ Work Statement (PWS), paragraph C.19.4.1.

In the alternative, can DHA define a “recognized accreditation body” and give an example of an acceptable accreditation body?

See response to question 31.

33 Section C, Description/Specifications/ Work Statement (PWS), paragraph C.19.4.1.

Most widely known accreditation bodies such as the American Translators Association do not provide a specific accreditation for medical translation. Rather, they provide a general certification in translation.

Will the Government remove the requirement that the certifying linguist have a credential specifically in medical translation?

No. Failure to accurately translate medical documentation may lead to serious medical harm. The DHA will not remove the requirement that the certifying linguist have a credential specifically in medical translation.

34 Section C, Description/Specifications/ Work Statement (PWS), paragraph C.19.4.1.

Would a certificate of completion of a program in medical translation from an accredited college or university be valid as an accreditation from a recognized accreditation body?

See Solicitation Amendment 0001 revised Section C, paragraph C.19.4.1.

35 Section C, Description/Specifications/ Work Statement (PWS), paragraph C.19.4.1.

Would accreditation through an in-house testing and certification program in medical translation be valid as a certification by a recognized accreditation body.

See response to question 34.

36 Section C, Statement (PWS), paragraph C.19.4.1.

If a linguist is accredited by a third-party agency as a Medical Interpreter, will this be valid as a certification by a recognized accreditation body in medical translation?

See response to question 34.

37 Section C, Description/Specifications/ Work Statement (PWS), paragraph C.19.4.1.

Can we submit resumes of linguists showing more than 5 years of professional experience as medical translators as a valid

See response to question 34.

HT940219R0001 Page 19 of 31 certification in medical translation?

38 Section C, Description/Specifications/ Work Statement (PWS), paragraph C.19.4.1.

If a linguist is accredited as a professional interpreter by agencies such as the State Department, Federal Court or other similar Government or NGO, will this be acceptable as a certification from a recognized accreditation body?

The DHA views document translation as a separate skill set from interpretation and will not accept accreditation as a professional interpreter as document translation certification.

39 Section C, Description/Specifications/ Work Statement (PWS), paragraph C.22.1., “The contractor shall develop and provide Medical Capability Reports (MCRs) when requested by the Government.

MCRs will follow the format and contain at a minimum the information specified in Section J, Attachment J-10, Medical Capability Reporting. The Government reserves the right to request additional information be provided in the MCR. If additional information is requested, the Government will grant additional time to complete the report. The Government will determine the amount of additional time allowed. Upon receiving TOPO approval, the contractor shall prepare and deliver the Medical Capability Report within 7 US business days, 90% of the time.

a.) It is impossible to propose a fixed price product with a set delivery timeline when the Government reserves the right to request additional information. We suggest removal of this statement or requirements to be precisely stated. If there is potential additional information needed for the MCRs we suggest creating a new CLIN for MCRs with extended requirements that can be priced at a higher level for the extra effort.

b.) It is difficult to obtain the minimum information contained in Attachment J- 10 within 7 days. The contractor may have the information in their system based on past visits and the turnaround will be expedient in those cases. However, in cases where information is not available based on past visits obtaining the information identified in J- 10 requires a visit or extensive research.

Therefore, the timeline for turnaround needs to account for both possible situations.

a.) The DHA has only had one request for additional information in the last 3 years. As stated in the Solicitation, the Government will grant additional time to complete reports if DHA requests additional information. The contractor may request additional time on a case-by-case.

b.) The DHA will not change the 7-day requirement. See response to 39.a).

HT940219R0001 Page 20 of 31

40 Section C, Description/Specifications/ Work Statement (PWS), paragraph C.23.4., “The contractor shall participate in MTF disaster/mass causality exercises when an MTF requests. The MTFs will request contractor participation through the appropriate TAO at least 15 business days in advance of an exercise. The contractor is not required to participate in more than one mass causality exercise per MTF per OP.”

a.) Can DHA please explain what is involved in a “MTF disaster/mass causality exercises?”

b.) Will the contractor be required to be onsite?

c.) How long is the event?

d.) What is the expectation from the contractor?

e.) Providing this support to 63 MTFs if evenly distributed would be potentially 5.25 per month.

There is also the possibility of 63 in a single month if this requirement is not framed to a reasonable volume/frequency expectation. We recommend that the last sentence be changed to “The contractor is not required to participate in more than one mass a.) MTF disaster/mass casualty exercises vary by MTF. Exercises typically involve the MTF simulating treatment of multiple trauma casualties. Exercises are often designed to push MTFs to the limits of their capabilities.

b.) The contractor is not required to travel to the

MTF.

c.) Durations vary from MTF to MTF. Exercises typically last 1-2 days.

d.) Possible exercise participation may include, but is not limited to, advising the MTF on the current availability of purchased-care ER services and trauma surgery support in real time.

The contractor and the MTF will define contactor’s role and level of participation in the Statement of Responsibilities (SOR)

CDRL R190.

e.) TAOs will work with the contractor and MTFs to ensure the contractor is not unfairly burdened.

HT940219R0001 Page 21 of 31 casualty exercise per MTF per OP. Furthermore, no more than 2 MTF exercises can be scheduled in by a single TAO in any given month.”

41 Section C, Description/Specifications/ Work Statement (PWS), paragraph C.23.5., “If a location moves from a permissive to a non-permissive environment and the Government requires COCOM Contingency Support, the contractor shall provide the support specified in paragraphs C.23.5.1 through C.23.5.4. for the location.”

Will DHA modify the contract in the case that the contractor is required to provide the support identified in this paragraph?

The sentence uses the word “shall” but the variability of contingency support does not provide enough certainty in order for this effort to be properly priced. Suggest DHA modify the end of this sentence as such, “the contractor shall provide the support specified in paragraphs C.23.5.1 through C.23.5.4 for the location after a unilateral change order and requirements are issued specifying the location of need.”

Yes. In the event COCOM Contingency Support is required, the contracting officer will issue a modification pursuant to FAR Clause 52.243-1, Changes, Fixed Price, Alt 1.

See Solicitation Amendment 0001 revised Section C, paragraph C.23.5.

42 Section C, Description/Specifications/ Work Statement (PWS), paragraph C.23.5.3., “The contractor shall provide assistance to COCOM, TPMRC, etc., in identifying and tracking the location of any ADSMs/ADFMs admitted to a host-nation facility in a non-permissive environment location;

performing inpatient medical management for these ADSMs;

and ensuring necessary follow-on care is identified and provided to the appropriate Government team. The contractor shall coordinate the transfer of deceased ADSMs/ADFMs.”

DHA stipulates a range of services potentially required by a contingency operation.

These services, medical evacuations and liaison support, will be highly dependent on the local situation. A contractor may be limited in the assistance it can provide based on the permissibility of the environment and regulatory requirements. Will DHA consider changing the “shall” to “may” to ensure the variables can be considered at the time of engagement?

Section C, paragraphs C.23.5.2 and C.23.5.3, state the “contractor shall provide assistance.” Implicit in this language is the understanding that the level of assistance may be impacted by the permissibility of the environment and regulatory requirements.

See Solicitation Amendment paragraph C.23.5.4.

HT940219R0001 Page 22 of 31

43 Section C, Statement (PWS), paragraph C.23.5.3, “The contractor shall coordinate the transfer of deceased ADSMs/ADFMs.”

TRICARE Policy does not reimburse repatriation of mortal remains. There is no associated CLIN on Schedule [Section] B to allow for this type of activity. Can DHA clarify the intent of this requirement?

See Solicitation Amendment 0001 revised Section C, paragraph C.23.5.3.

44 Section C, Description/Specifications/ Work Statement (PWS), paragraph C.26.3.2.

The last sentence of this section reads: “The PRV briefing must occur at least 7 calendar days prior to the start of the PRAV process as described in paragraph C.26.5.”

Question: Did DHA intend to reference 26.4 instead?

Yes. See Solicitation Amendment 0001 revised Section C, paragraph C.26.3.2.

45 Section C, Description/Specifications/ Work Statement (PWS), paragraph C.29.1. TAO/MTF and Contractor Interfaces

CDRLs R160, SOR with TAO Eurasia-Africa Director; R170, SOR with TAO Latin America & Canada Director; R180, SOR with TAO Pacific Director; and R190, SOR with Military Treatment Facility (MTF).

In C.29.1, it states that the SORs (CDRLs R160 – R190) need only be changed as needed. The CDRLs state that these must be submitted annually. Does DHA expect the Contractor to resubmit an SOR CDRL annually even if there are no changes?

No. The contractor submits revised SORs (CDRLs R160-R190) if and when the contractor revises them.

See Solicitation Amendment 0001, Section J, Exhibit A CDRLs zip file.

46 Section F, Deliveries or Performance, paragraph F.5.2 and CDRL zip file.

The following CDRLs were missing from the CDRL zip file that are identified in Section F.5.2.: A030 - Bridge Letter in Support of Service Organization Control Report (SOC1) - Statement on Standards for Attestation Engagements, SSAE No. 18 (Prime with Subservice Organization);

R020 - Appeals Processing Guidelines, Desk

DHA attached the missing CDRLs to FBO on 8-16-19.

See Solicitation Amendment 0001 Section J, Exhibit A CDRLs zip file.

HT940219R0001 Page 23 of 31

Instructions and Reference Materials; R200 - B2B Gateway Questionnaire;

R210 - System Integration Test Plans

47 Section H, Special Contract Requirements, paragraph H.7.10.2.3., “The Government will assess a performance guarantee amount of $500 per incorrectly translated document that resulted in a Potential Quality Issue (PQI). The TAO Medical Director is final determining authority as to whether or not a document was incorrectly translated.”

a.) This penalty / performance guarantee is patently unconscionable.

Courts have largely disallowed penalties that have the sole purpose of deterrence versus a genuine pre-estimate of a loss incurred. We suggest that the performance guarantee be measured as a sum equal to 2x the price of a translation.

b.) This section needs to be modified such that the performance guarantee only apply to those translation services directly paid for by the Government as defined in C.19.

a.) The performance guarantee is a negative incentive consistent with Section C, paragraph C.2.3.

Objective 3, Highest Level of Clinical Quality; and paragraph C.13.6. Clinical Quality Management.

Accurate translation of medical documentation is extremely important to the DHA because incorrectly translated medical documents have the potential to cause serious medical harm to the patient. The DHA has determined $500 is a reasonable negative incentive where the DHA determines the contractor’s incorrect translation actually results in a Potential Quality Issue.

b.) See Solicitation Amendment 0001 revised Section C, paragraph C.19.6.

and Section H, Special Contract Requirements, paragraph H.7.10.2.3.

48 Section H, Special Contract Requirements, paragraph H.7.12.1. and Section C, Description/Specifications/ Work Statement (PWS), paragraph C.14.3.1., “Beginning with OP 2, based on audit results, the Government will assess a performance guarantee amount of $300 per patient narrative which

The contractor is only reimbursed under this proposed contract for administrative effort related to transient aeromedical evacuation care. However, this penalty applies to all aeromedical evacuation care that can be provided by network or non-network

The performance guarantee specified in Section H, paragraph H.7.12. ensures the contractor will provide the written narrative as required by Section C, paragraph C.14.3. for all beneficiaries that receive medical evacuation services.

It is consistent with Section

HT940219R0001 Page 24 of 31 does not fully describe all medical care in the agreed upon format.”

providers. Therefore, the burden on the contractor is unreasonable. Will DHA consider a CLIN for each beneficiary type so that administrative efforts can be reasonably priced into the contract?

C, paragraph C.2.3.

Objective 3, Highest Level of Clinical Quality; and paragraph C.13.6. Clinical Quality Management.

The DHA does not require a separate aeromedical evacuation administrative cost CLIN for each beneficiary type. The offeror should include administrative costs for evacuation services provided to non-transient beneficiaries under CLINs X001 and X002.

See Solicitation Amendment 0001 revised Section G, paragraph G.17.

49 Section J, Exhibit A, CDRL P060, COCOM Contingency Support Plan.

“The plan shall describe how the Contractor will work with the Combatant Commanders, TPMRC, and host nation facilities to facilitate moving American casualties to the facilities in the identified location, ensuring quality care is rendered, and then facilitating movement to the appropriate permissive environment location.”

Is it DHA’s intent to provide services for all American nationals regardless of TRICARE eligibility?

No. See Solicitation

Section J, Exhibit A CDRLs zip file, CDRL P060.

50 Section J, Exhibit A CDRL P060, COCOM Contingency Support Plan.

The plan shall describe how the Contractor shall ensure the aeromedical evacuation assets capable of moving large numbers

Ensuring assets are available is an unreasonable requirement given the unknown nature of the non-permissive environment situation. We suggest that this language should be modified as follows, “The

See Solicitation Amendment paragraph C.23.5.4.

HT940219R0001 Page 25 of 31 of injured ADSMs from a non-permissive environment to the appropriate permissive environment location (facility) are available in a contingency situation.

plan shall describe how the Contractor will survey the commercial market to identify aeromedical evacuation assets capable of moving large numbers of injured ADSMs…”

51 Section J, Attachment J-1, TOP Prime Locations OP FORCES-

NH YOKOSUKA).

DMIS 6341 is missing from J1. ADSMs currently enrolled. Will BSR support be needed onsite at location?

USNH, Yokosuka, Japan is listed in Section J, Attachment…