TOP 2028 DHA Responses to DRAFT RFP 20251027.pdf

TOP 2028 Draft RFP Questions & DHA Responses

HT9402-25-R-0219

TOP 2028 Draft RFP Questions & DHA Responses HT9402-25-R-0219 Page 1 of 23

No: Solicitation Citation & Paragraph

Question/Comment DHA Response

1 C.1 - C.16 The document references Section J for procedures, examples, amplifying information, and waivers. To ensure a comprehensive understanding of the DHA TOP program and enable competition, we recommend that Section J and all relevant attachments be included with the RFP or shared in advance with offerors through the draft materials.

Additionally, it would be beneficial to clearly specify the purpose and update frequency of these materials, and to provide guidance on how contractors can request additions or clarifications. This approach will promote transparency and enable contractors to fully understand requirements, locations, payment conditions, reporting formats, and support plans.

A second draft RFP, with Section J attachments, will be released by the Government in the coming months.

2 C.1 - C.16 Implementations costs associated with developing and transitioning between vendors can be prohibitively high, often creating structural advantages for the incumbent. To foster a more competitive and innovative procurement environment we recommend eliminating key transition costs from the evaluated price. This adjustment would reduce barriers to entry, mitigate incumbent dominance and encourage broader commercial vendor participation.

Without such measures, the DHA risks diminished innovation and constrained growth potential - outcomes that could adversely affect care delivery and limit the agency’s ability to leverage emerging capabilities.

Thank you for your comments, the Government will take this under advisement.

TOP 2028 Draft RFP Questions & DHA Responses HT9402-25-R-0219 Page 2 of 23

3 C.1.1 Can DHA clarify how the contractor should coordinate with local health care systems in remote locations where host-nation regulations may conflict with TRICARE requirements? We recommend providing additional guidance or examples for handling regulatory conflicts.

Clear direction in this area will help ensure consistent compliance, reduce operational ambiguity, and support effective care delivery in complex international environments.

DHA does not direct how the contractor coordinates with host-nation health care systems make this determination, the contractor would need to identify these cases and inform the Government when such conflicts are noted.

4 C.1.1.1, C.5.1 Statements indicate MTF locations identified in Attachment J-1 TOP Prime Locations, Attachment J-2 TOP Prime Remote Locations, and Attachment J-3 TOP Prime Remote Embassy Locations with an Embassy Health Unit (EHU). Please provide a comprehensive list of all locations expected to be covered by the contractor.

A second draft RFP, with Section J attachments, will be released by the Government in the coming months.

5 C.2. Does the DHA TOP Program have policy regarding innovation reviews and how they should be conducted between the contractor and government? We recommend adding language that encourages ongoing process improvement and innovation throughout the contract period, not just at award. For example, require annual “innovation reviews” or allow optional pilot projects for new technologies and care models. We believe this would push innovation and best practices within the TOP program and develop room for additional competitiveness between vendors. An example of this would be the DHA Competitive Plans Demonstration.

Thank you for your comments, the Government will take this under advisement. Once awarded and throughout the life of a contract, the contractor can submit a proposal to the Government at any time for consideration of a new innovation.

6 C.2.1. Does the DHA have an approved list of telehealth platforms or standards for integration? If so, we recommend providing minimum interoperability requirements to guide contractor integration efforts.

No, DHA does not have an approved list. The technical requirements can be found in the TRICARE Policy Manual, Ch 7, Section 22.1.

TOP 2028 Draft RFP Questions & DHA Responses HT9402-25-R-0219 Page 3 of 23

7 C.3.2. Transition risk is among the highest in healthcare outsourcing. Would DHA consider requiring structured parallel operations and system/data interoperability testing as a condition of transition acceptance?

Thank you for your comments. The Government makes the determination on testing during transition. Please reference Draft TOM, Ch 24, Sec 2 TRICARE Operations Manual 6010.62-M, April 2021, Ch 2 for Transition Requirements.

8 C.3.3, C.8.9 How does DHA currently assess or plan to assess contractor compliance with audit and coding requirements?

Would DHA consider mandating FedRAMP-authorized platforms and NIST 800-53 aligned audit trails at contract start, rather than leaving compliance posture to contractor discretion?

This question is unclear. We are happy to address after clarification. Sorry, we are unclear if the question. The contractor audit requirements are spelled out in Section C and in the TRICARE Operations Manual 6010.62-M, April 2021, Ch 1, Sec 4.

9 C.3.3, C.8.9 Real-time transparency drives trust. Would DHA consider requiring near-real-time dashboards across claims, call centers, and clinical quality—using contractor-hosted but government-accessible tools—to support proactive oversight?

The contractor can propose this approach as part of their proposal for Government consideration during the evaluation phase.

10 C.4, C.8.4 Enrollment discrepancies often create downstream claims errors. Would DHA consider requiring real-time DEERS integration with TED capture to ensure synchronized eligibility and reduce rework?

It is the contractor's responsibility to establish their process to create the TRICARE Encounter Data (TED) record. The DEERS real-time eligibility check is already required at the time the claim is processed.

11 C.5. Does the DHA have environmental, social, or governance (ESG) criteria for private network development and provider selection? If not, we recommend the DHA provide guidance on this requirement or outline a list of already associated partnerships.

No, DHA does not have environmental, social, or governance criteria for private network development and provider selection, it is the contractor's responsibility to establish a network.

TOP 2028 Draft RFP Questions & DHA Responses HT9402-25-R-0219 Page 4 of 23

12 C.5.1. The requirement to achieve a full network from scratch may restrict competition to incumbents with pre-established global networks. Recommend that the long-established TOP network of participating providers be transitioned with the contract. This will open up competition and reduce transition risk to the government.

This will also allow more time and capacity for analysis of virtual health augmentation options.

Thank you for your comments. Each contractor owns their network, the Government does not have an agreement with the providers.

13 C.5.1. In order to develop a comprehensive PSCP which fully supports beneficiary needs for J-1, J-2, and J-3 sites will the government provide by site the population at risk/number of enrolled beneficiaries, the annual referral volume by specialty, and the network provider specialties needed?

Additional supporting data will be provided with Draft #2.

14 C.5.1.2.1 Will TOPO establish parameters for when directed additions to the network are appropriate? Ideally, TOPO may direct network additions where access to care standards is inadequate and where the direction is agreed between Contractor and TOPO to address this concern without lowering clinical quality standards.

No, TOPO will not establish parameters. The Government will direct additions dependent on each situation.

15 C.5.1.2.2 Does the DHA have approved language translation materials? We recommend that to ensure consistency, security, and accuracy that the DHA look to an approved translation method (to include training materials).

No, DHA does not have approved materials, that is the contractor's responsibility. (C.5.1.2.2 does not appear to be the proper reference for this question.)

16 C.5.1.5.5 Would TOPO consider revising to “notify applicable MTF, TAO, DHN” rather than requiring confirmation? The current language appears to contradict the core contract objective of responsive and agile network. There are administrative and quality concerns which may necessitate quick action by removing or suspending a provider.

Requiring confirmation rather than providing information could cause problematic delays.

No, the requirement is to collaborate, which could include notification or confirmation and should entail bidirectional discussions.

TOP 2028 Draft RFP Questions & DHA Responses HT9402-25-R-0219 Page 5 of 23

17 C.5.1.5.2., C.5.1.5.4. Will the government consider allowing alternative methods of support such as a telehealth capability to meet the requirement. This could include strategically located portable equipment that could be brought to the MTF, Embassy/Consulate, or USG installation (ex: compact secure and private “doc in a box” type solutions) that can be easily relocated as needs arise. This would provide a faster response and support direct care recapture, by keeping the care inside the Direct Care system.

Appointing can be facilitated by the MTF referral mechanism and/or directly via the beneficiary app.

Delivering the service on the installation, you would mitigate the complexity of host nation telehealth regulations. Telehealth providers supporting the SOFA covered military personnel from an installation would fall outside host nation regulations, while still allowing onward specialty appointing via the contractor to the local PCSP network as required.

The contractor should describe their approach to Network Development in their proposal so that DHA Private Sector Care and Direct Care subject matter experts can evaluate during the evaluation period.

18 C.5.1.5.4. Will the government allow the contractor to provide on-site, MTF-embedded contract clinicians to deliver primary care or large specialty services in-house to enrolled beneficiaries?

If the Government deems it necessary to provide on-site, MTF-embedded contract clinicians, a Clinical Support Agreement will be incorporated to the contract via a modification.

19 C.5.1.5.4. Alternatively, will the government consider a contractor staffed, equipped, and supplied on-installation temporary clinics to deliver care to enrolled beneficiaries?

At this time, no. If the Government does at some time chose to implement such a clinic, it would be done in accordance with 32 CFR 199.17(a)(2), (h)(3), and (l)(4), and TRICARE Operations Manual 6010.62-M, April 2021, Ch 15 Section 2, Resource Sharing. This would require Congressional approval.

20 C.5.1.5.5. Which command, MTF, TAO, or DHN is the approval authority for network changes?

It will depend on the necessary adjustments requested.

TOP 2028 Draft RFP Questions & DHA Responses HT9402-25-R-0219 Page 6 of 23

21 C.5.1.5.6. For locations within Puerto Rico with a high volume of Prime beneficiaries, will the government consider the contractor operating Primary Care clinics to manage the care of this population, or embedding a PCM at the MTF?

At this time, no. This would require Congressional approval. It is the contractor's responsibility to develop a network to meet the requirements. If the Government does at some time chose to implement such a clinic, it would be done in accordance with 32 CFR 199.17(a)(2), (h)(3), and (l)(4), and TRICARE Operations Manual 6010.62-M, April 2021, Ch 15 Section 2, Resource Sharing.

22 C.5.1.6.5. In the event a provider frequently utilized by and EHU refuses to join the network or agrees to become a non-network participating provider, what is the process for communicating and aligning with the government on this refusal?

This is communicated via the Monthly Network Adequacy Report (CDRL M080).

23 C.5.2.2. In lieu of the network provider or non-network participating provider being responsible to provide access to video and tele-interpretation services would it be acceptable for the contractor to support this requirement via a robust beneficiary app?

The provider does not have to be responsible for providing this access, the requirement is simply to support video and tele-interpretation support. The contractor may choose to provide this service for their providers as long as it meets the needs of the requirements.

24 C.5.3. Strict U.S.-style access standards (e.g., 30–60 minute drive times) may be unrealistic in many overseas locations and favors the incumbent with existing country-by-country data. Suggest a milage radius is utilized. Wait times will only be possible if the beneficiary indicates arrival and seen data into their beneficiary app or other self-reported metrics. Perhaps an alternative measure is patient satisfaction surveys or Net Promotor Score. Access to Specialty, routine and urgent appointments can be calculated via the appointment data and associated beneficiary preferences.

Access to Care Standards is defined in 32 Code of Federal Regulations (CFR) 199.17(p)(5)(ii). If compliance with these standards is not feasible, the contractor may submit a waiver request to the Government for consideration per C.5.4.3.

TOP 2028 Draft RFP Questions & DHA Responses HT9402-25-R-0219 Page 7 of 23

25 C.5.3.1 How does the Government envision consistent monitoring of provider office waiting times globally? Enforcement of strict drive times or distance requirements may inhibit access to care depending on the quality of providers proximate to the Prime or Prime Remote location.

The Access to Care Report (M060) will require the Contractor to report the average days to care when a referral is matched to a claim. This CDRL will be released with Draft 2 to provide additional details.

The Contractor is required to monitor and measure ATC performance and inform the TRICARE Overseas Program Office of locations where ATC is impaired and implement corrective actions to improve access in those areas.

26 C.5.3.2 Since provider wait times cannot be consistently monitored worldwide and TRICARE’s volume is insufficient to compel corrective action, would TOPO consider allowing the Contractor to instead notify stakeholders of negative impacts and propose pivot actions?

If unable to implement a corrective action, the contractor shall notify stakeholders and propose alternative actions.

27 C.5.4.1 Network inadequacy can occur due to multiple factors, many of which are not feasible for the contractor to address. A CAP should be able to deliver a corrected state of service delivery. However, if network inadequacy occurs due to cultural, regional, legal, or market forces, the contractor would not be able to address the shortfall with the resources available in region. Recommend adjusting to a requirement to inform the Government of reasons for inadequacy and keep stakeholders informed of developments in the region affecting adequacy.

Thank you for your comments, the Government will take this under advisement. consider your recommendation.

28 C.5.4.3 What is the expected timeline for DHA to review and approve network adequacy waiver requests? Is there a formal appeals process? If so, please provide timelines and requirements for both.

There is no restriction on when a waiver can be requested and it typically takes 30 days for the Government to review and provide a response.

There is not a formal appeals process.

29 C.5.5, C.6.1.8. How does DHA currently measure or plan to measure contractor readiness for contingency events (e.g., medevacs, natural disasters)?

C.5.5 & C.6.1.8, Combat Support

TOP 2028 Draft RFP Questions & DHA Responses HT9402-25-R-0219 Page 8 of 23

30 C.5.5.1. Clarify whether surge staffing may include telehealth augmentation to ensure continuity and access to needed specialty healthcare services during contingencies.

"As outlined in C.5.5.3, the contractor shall respond to contingencies and provide TAO/MTFs with analysis of provider network; expand the provider network (including Primary Care) to support changes in TOP

31 C.5.7.3. The accuracy rate increases annually. Will DHA provide historical data or benchmarks to help contractors assess feasibility? We recommend including a transition period for new accuracy standards. This is critical for regions with high provider turnover.

DHA considers the challenges with transition and accuracy rates are lower at the start of the contract and increase over the life of the contract. This is a new requirement for the TOP Contract, and we do not have historical data for overseas.

32 C.5.7.3., C.5.7.3.4 In order to determine the level of effort and resources required to ensure an accurate, useful provider directory is available, will the government provide the historical volume network and non-network participating by location?

The Government is unclear on what your question is asking. Utilization data will be provided with the Final RFP. It is the contractor's responsibility to build the network and provider directory.

33 C.5.9. For a medical center or large multi-service specialty clinic is the government’s intent that every unique individual provider’s be verified to include primary source verification for every provider treating TRICARE beneficiaries? If so, is the expectation 100% verification?

"Yes, as stated in C.5.9.2. ""The contractor shall verify individual providers working within an institution are appropriately credentialed through primary source verification." This would be 100% of the providers.

34 C.5.9 – C.5.13. How does DHA currently verify or plan to verify credentialing and malpractice compliance globally? Would DHA consider allowing contractors to apply standardized proxy validation in countries lacking formal systems, while mandating on-site verification in higher-risk geographies?

In addition to the contract requirements, please refer to TRICARE Operations Manual 6010.62-M, April 2021, Ch 4 Section 1 for additional Provider Certification and Credentialing requirements, and paragraph 6.0 for Provider File Audits. It is the contractor's responsibility to establish business processes to track and monitor the credentials of all networks and participate in non-network PSCP. The Government has the right to inspect or audit all the requirements per FAR 52.246-4 Inspection of Services-Fixed-Price and 2.246-5 Inspection of Services-Cost-Reimbursement.

TOP 2028 Draft RFP Questions & DHA Responses HT9402-25-R-0219 Page 9 of 23

35 C.5.9.1. Does “individual provider” include institutional providers?

If so, please confirm that individual providers working within an institutional provider will not require accreditation if the institution validates its internal credentialing process. Performing accreditation of each individual provider working within an institutional provider is not possible for the Contractor given the administrative burden on the providers in relation to the volumes of business that TRICARE provides. Even were it possible, credentialing to that level would greatly increase Contractor administrative burden and costs.

This requirement will be clarified in Draft 2. The Government's expectation is for the contractor to verify the institutional process is valid for individual providers. If the contractor is unable to verify a sound institutional process, then 100% of individual provider credential verification is required for that institution.

36 C.5.9.5, TOM Ch 24, Sec 3, p 2.12"

PWS section C.5.9.5 states, “Contractor shall complete on-site verification during provider certification in the Philippines.” Chapter 24 Section 3 (2.1.2) states, “The TOP contractor shall reimburse claims in the Philippines and Panama following Government established fee schedules.” Please clarify whether reimbursement and certification issues in the Philippines also apply to Panama and ensure consistency in fee schedules and processes.

The Government sets the fee schedules. Provider credentialing is only required in the Philippines.

37 C.5.11., C.6.7.4.3. "To open up the innovation in solution approach, recommend the government provide a list of all network and non-network providers in the TOP network of PCSPs.

This will derisk the transition of an incoming contractor and allow for more competitive proposals for the government.

C.5.11.&C.6.7.4.3. Provider Clinical Site Visits

38 C.5.12. How does DHA currently assess or plan to assess the effectiveness of multilingual provider and beneficiary education programs? Would DHA consider a shared multilingual content library, maintained centrally, to ensure consistent messaging across all regions and beneficiaries?

The contractor is responsible for developing an Education Plan for Government review. No, DHA will not consider a centrally maintained library.

39 C.5.14. Consider whether regional reimbursement models (vs.

country-by-country) may be used to drive cost savings.

Thank you for your comments. Negotiated rates are the responsibility of the contractor.

TOP 2028 Draft RFP Questions & DHA Responses HT9402-25-R-0219 Page 10 of 23

40 C.5.15. Would DHA consider restricting or limiting use of contractor-owned clinics/hospitals to prevent self-referral conflicts of interest? This safeguards objectivity and aligns with OCI standards.

No, the Government does not want to impose any limitations on potential access for our beneficiaries.

The contractor shall work collaboratively with the Government to mitigate any potential conflicts of interests per C.5.15.1.

41 C.6.1.1.2. Recommend clarification of administration of a robust IMM program requires a consistent procedure across all regions. A more complicated service delivery with regional differences is prone to error. In a firm fixed price contract, the Contractor also requires certainty of staffing to deliver the requirement.

Thank you for your comments, the Government will take this under advisement.

42 C.6.1.2.1, C.7.3.1.3. What is the current secure web-based portal that is being utilized within the TOP program? We recommend utilizing or requiring a program that is integrated with MHS Genesis, DEERS, AHLTA/CHCS (legacy systems), TOL Secure messaging, JLV, and overseas contractor portals.

We also recommend that any systems have the ability to integrate with extended COTS and GOTS solutions to ensure the highest level of technology for DHA healthcare.

Each contractor is responsible for developing and maintaining the required secure web-based portals within the established systems requirements.

43 C.6.1.5 - C.6.1.6.1 Would TOPO consider reducing the frequency of required discharge planning updates? Daily discharge planning undermines provider autonomy and inhibits quality of care.

The number of discharge updates should be reduced. Most systems would include the newborn with the mother’s entry until separately enrolled.

No, the Government will not reduce the frequency of updates.

44 C.6.1.7.1. With respect to obtaining, translating, and uploading medical records, would the government define “pertinent” reports?

This will be clarified in DRAFT #2.

TOP 2028 Draft RFP Questions & DHA Responses HT9402-25-R-0219 Page 11 of 23

45 C.6.3. Would TOPO consider extending the response window from 12 hours to 24 hours? Staffing globally for a 12-hour requirement would be prohibitively expensive. Industry best practice is that medical calls go to a call center to evaluate the call for best medical point of contact to address the case. This allows selection of a professional who is both available and able to provide the highest level of clinical quality for the case. The requirements for this section can only be provided by clinical staff, so the option for a non-licensed professional should be removed.

The 12-hr outreach can be handled via a phone call or through the app and is not required to be in-person. The contractor is responsible for determining the skill level of the staff who would attend the visits.

46 C.6.3. Is there a government expectation for one in-person visit for <48 hour admissions, or would it be possible to leverage video tele-communications via the beneficiary app to provide service for short admissions? If a 100% in-person visit is required, would it be possible to receive a list of total admissions/year by network facility and Prime service area/

The requirement is for outreach within 12-hrs of admission and yes, an in-person visit is the Government's expectation regardless of length of admission. Data will be provided with 2nd DRAFT

RFP.

47 C.6.4.4. The scope of applicable beneficiaries is not clearly defined.

The program is best administered to Prime and Prime Remote only, as otherwise this language would entail a case management program made up primarily of the Select population. Inclusion of Select would greatly increase the scope and cost to deliver. Case management under this draft contract’s parameters may also be greater than the scope provided by the Select authorizing law.

The scope is any eligible TRICARE beneficiary who meets the requirements of C.6.4.4.

48 C.6.5. The ratio of MTF providers to beneficiary population would create a major burden on the MTF as right of first refusal requests would overwhelm the facility and create delays in care that would inhibit access to care. Given the dispersed nature of the PR beneficiary population, there are also issues with the travel distance to the MTF if it did exercise right of first refusal. Would TOPO consider modifying this requirement to prevent excessive burden on MTFs and PR beneficiaries?

The contractor shall develop a plan within the SOR per C.6.7.1.3.1 for Puerto Rico.

TOP 2028 Draft RFP Questions & DHA Responses HT9402-25-R-0219 Page 12 of 23

49 C.6.7.2.1. Would the government clarify “phone number for the specific provider”? For example, in a large multi-specialty clinic, would it be acceptable to provide the location and phone number to the specific specialty/sub-specialty clinic?

Yes, the beneficiary must have direct access to the provider's specialty clinic phone number.

50 C.6.7.3.2. Setting appointment on first contact is not possible due to lack of system integration capability (see note for C.9.4.1 and C.9.4.3). This also circumvents the benefit review process and contradicts the authorization timeline. How does TOPO envision first-contact appointment scheduling, given lack of system integration and existing benefit review/authorization timelines?

Appointment setting shall occur once an authorization has been issued, which is after the benefit review. Further, the requirement is only for appointment setting completed by the contractor.

The Government will clarify this in the requirements.

51 C.6.7.4.2. Encourage the government to consider the allowance of appointment services for non-Prime beneficiaries via virtual first methodologies, meaning their access for service is via an app, virtual (voice) or online services first.

This would provide a more cost-effective solution for the government.

Thank you for your comments. The Government will not change this requirement and limit the beneficiaries options.

52 C.6.7.4.2. Additionally, will the government provide the associated numbers of non-prime beneficiaries that would be utilizing this service.

We can provide an estimate of the volume of non-prime beneficiaries.

53 C.6.7.4.2. Will there be a separate CLIN associate for these services or expected to be included in the FFP modeling?

No, appointment setting is part of the FFP modeling.

54 C.6.7.6. Recommend TRICARE Select should be removed as it is not part of their legal entitlement for cashless/claimless authorizations.

TRICARE Select will not be removed for cashless/claimless authorizations.

TOP 2028 Draft RFP Questions & DHA Responses HT9402-25-R-0219 Page 13 of 23

55 C.6.8. "How does DHA currently measure or plan to measure clinical quality outcomes for overseas providers?

Would DHA consider requiring contractors to align quality measures with WHO/JCI standards where host-nation metrics do not exist, ensuring parity of care outcomes across regions?

Measuring quality in an overseas environment and across multiple cultures is challenging. PREMS scratch the surface on quality by measuring patient experience; however, it is a very limited and subjective lens. RFP DRAFT #2 will include CDRLs and M020 is Monthly Clinical Quality Report requirements, including Potential Quality and Quality Incidents, Patient Safety Indicators, Corrective Action Plan reporting, PREMs, Enhanced Recovery After Surgery, Care Area Grades.

No, DHA will not require contractors to align quality measures with WHO/JCI standards where host-nation metrics do not exist, the administrative burden a facility would need to meet to join the TRICARE Network would increase and be challenging to sustain, which would negatively impact the ability to recruit providers.

56 C.6.8.2.4. How does DHA currently measure or plan to measure beneficiary experience (e.g., PREMs, cultural/language barriers)? Would DHA consider standardizing PREM collection and reporting across contractors so overseas beneficiaries achieve parity with CONUS service levels?

The contractor is responsible for measuring the requirement of C.6.8.2.4 and reporting to the Government. The Government strives to align measures whenever possible to ensure consistent reporting between contractors, as we; as between private sector care and direct care whenever possible parity, please refer to TRICARE Operations Manual 6010.62-M, April 2021, Ch 7, Sec 6, para 3.2.3. for further clarification.

57 C.7. Translation timelines vary widely across host nations.

Would DHA consider establishing a standardized certification framework for medical translators to ensure quality and consistency across contractors?

The requirement currently outlines specified timelines, however the Government anticipates adding additional clarification in Draft #2.

58 C.7.3.2.1., C.7.3.3.1. What host nations would be potentially involved? Any and all countries where medical records are being collected.

TOP 2028 Draft RFP Questions & DHA Responses HT9402-25-R-0219 Page 14 of 23

59 C.7.4. Host-nation privacy laws may conflict with U.S. security requirements. Would DHA issue guidance on encryption, data residency, and harmonization of HIPAA/DFARS/NIST controls to avoid inconsistent contractor practices overseas?

The contractor shall apply the privacy and security laws, regulations, and guidance of the host nations (not the US)adhere to the host nation privacy laws and it is the contractor's responsibility to understand and comply with these.

60 C.7.2.3. A complete medical record containing all medically relevant documents of a patient’s care is required for the adjudication of benefits when separating from the service.

Daily nursing notes and charts may prove relevant for such adjudication, especially if the inpatient stay is short. To ensure accurate benefit adjudication, would TOPO consider requiring daily nursing notes/charts only for inpatient stays under 8 days? Other documents can only be excluded if clearly labeled, otherwise Contractor will be forced to translate the document and incur cost in order to determine it is excluded.

Thank you for your comments. The Government will consider this request for Draft #2.

61 C.7.3.1.2. Recommend the KPI clock should begin when the medical record is complete, rather than immediately following the appointment. Medical records are typically not available immediately following the appointment, which is consistent with provider practice for most providers overseas. In addition, recommend shifting from calendar days to business days as staffing for calendar days would be substantially greater.

Thank you for your comments, the Government will take this under advisement.

62 C.7.3.1.4. Is there risk that the beneficiary experience will be potentially compromised and inconsistent across regions if MTFs can opt out of a service delivery? This may lead to alternative and unnecessary additional operational processes that may result in potential increased cost and impact service delivery within a region.

Yes, it will be inconsistent, however the MTF is part of the customer base and it is at their discretion to provide this service or not. This should be included as part of the SOR development.

TOP 2028 Draft RFP Questions & DHA Responses HT9402-25-R-0219 Page 15 of 23

63 C.8. How does DHA currently measure or plan to measure contractor performance in dual-payer scenarios (Medicare, OHI)? Would DHA consider modular claims platforms that integrate directly with TPA networks to improve auto-adjudication and reduce improper payments?

Measure of performance is determined on the contractor's approach to dual-payer scenarios. The government will inspect and audit the contractor's performance for this requirement through routine inspections and address any concerns with non-performance, if discovered. It is the contractor's responsibility to determine which modular claims platforms they will utilize as best practice.

64 C.8. Beyond cost savings, how does DHA currently evaluate or plan to evaluate contractor innovation in claims management? Would DHA consider scoring models that reward denial prevention, provider satisfaction, and accelerated adjudication timelines?

The contractor is evaluated on their ability to meet the claims processing standards outlined in TRICARE Operations Manual 6010.62-M, April 2021, Ch 1, Sec 3, para. 6.0; there are not evaluation criteria specific to innovation. Thank you for your comment regarding scoring models, DHA will take that under advisement.

65 C.8. The draft calls for “modern” software. Would DHA clarify whether COTS SaaS platforms that already meet FedRAMP and TRICARE transaction standards are acceptable, or whether custom development is expected?

As long as the software meets all of the platform requirements, it is acceptable. The term "modern" is to ensure platforms evolve with technological advancements and software is up to date within the scope of the requirements throughout the life of the contract.

66 C.8.1. Request DHA allow deployment of AI/ML for fraud, waste, and abuse detection in claims adjudication.

It is the contractor's responsibility to determine technology best utilized to meet the requirements.

67 C.8.8.1. This is in conflict with the LOD that requires proof of payment on all submitted claims and not just beneficiary submitted claims.

Thank you for your comments, the Government will review and edit for Draft #2, as appropriate.

68 C.8.8.2. We recommend that the DHA clearly outline any special payment conditions or administrative charges associated with the delivery of healthcare, to ensure transparency and facilitate contractor compliance.

A second draft RFP, with Section J attachments, will be released by the Government in the coming months.

TOP 2028 Draft RFP Questions & DHA Responses HT9402-25-R-0219 Page 16 of 23

69 C.8.8.2.1. We recommend that the DHA provide the attachment outlining any variations in provider processes for issuing receipts to beneficiaries. This will enhance transparency and help ensure consistency across all regions.

A second draft RFP, with Section J attachments, will be released by the Government in the coming months.

70 C.8.8.2, C.8.8.3. How frequently does the DHA update its list of countries?

What procedures are in place for submitting requests to add or review countries on the list? We suggest implementing regular reviews and clearly defined processes for maintaining and updating the country listing.

"The list of countries is updated as needed and is outlined in Attachment J-8 as follows:

71 C.8.9.2.1. Confirm this requirement only applies to the third-party subcontractor auditors.

Yes, C.8.9.2.1 is specific to the third-party auditors.

72 C.9. Recommend mobile-first beneficiary engagement (apps, secure chat, translation assistance, population health initiatives, claims tracking, appointment tracking). This approach is supportive of “meeting the patients where they are” and reducing call wait times, surge risks and costs to government for call centers and providing a consistent experience globally.

The contractor is required by C.9.4. to implement a mobile app to facilitate an integrated healthcare system for beneficiaries, however it is only one method of beneficiary engagement. The current requirements allow beneficiaries to select their preferred method of customer service engagement and DHA will not restrict access or options by requiring mobile-first beneficiary engagement.

73 C.9. Providing a contemporary one-stop shop appropriate for most of the demographic served, allows for easier evolution of services offerings and wider reach capability that can be proactive as opposed to reactive.

Thank you for your comment, the Government will take this under advisement.

74 C.9.2. How does DHA currently measure or plan to measure call center performance beyond ASA/AHT? Would DHA consider including broader CX indicators—CSAT, FCR, digital self-service adoption, and intent-based routing effectiveness—to reflect modern call center performance?

Refer to TRICARE Operations Manual 6010.62-M, April 2021, Ch 1, Sec 3, para 3.2.1 for call center standards. The contractor can propose reporting additional indicators to demonstrate their performance as part of their proposal for Government consideration during the evaluation phase.

TOP 2028 Draft RFP Questions & DHA Responses HT9402-25-R-0219 Page 17 of 23

75 C.9.4. What is the current beneficiary smartphone or mobile application? Is this application approved for use globally or is it regionally aligned? We recommend selecting a product that is fully compatible with existing MHS Genesis programs, globally accessible, and meets all TRICARE security requirements.

The mobile application development is the contractor's responsibility.

76 C.9.4.1 Integration with global provider systems is not technically or legally feasible. Contractor systems can track appointments internally and potentially be enhanced, but bi-directional system integration is not achievable.

We are only asking for the appointments that the contractor assists with setting. The Government will clarify this in the requirements Draft #2.

77 C.9.4.3 Per comment to C.9.4.1, direct integration with provider systems will not be possible. Medical record access/uploads through the app would only be possible if the Contractor maintained medical records and provided access, or if Contractor integrated the app to HAIMS.

Either situation would implicate high costs due to liability (direct contractor storage of the files) or technical difficulty (HAIMS integration). TOP beneficiaries are also present in GDPR jurisdictions, which do not allow immediate access of medical records. The technology to capture medical records via photograph would create clinical quality concerns due to the quality of the individual photographs and documents. Would TOPO consider alternatives to direct provider system integration, such as HAIMS integration, acknowledging high costs/liability, or limiting scope to Government-approved solutions?

The requirement is speaking of bidirectional communication between the contractor and the beneficiary, not between the beneficiary and the provider. This requirement speaks to medical records within the contractor's system, not the private sector care provider's system. The contractor is responsible for validating legiblity of the records.

78 C.9.4.4. Historically, providers and beneficiaries do not provide the correct authorization information for the specific claim.

Requiring this information to auto-populate for claims processing could lead to payment errors causing provider and beneficiary dissatisfaction.

The contractor is responsible for ensuring proper claims processing and authorization matching.

TOP 2028 Draft RFP Questions & DHA Responses HT9402-25-R-0219 Page 18 of 23

79 C.9.7. Is there a specific section or guidance that addresses interpretation services aligned with telehealth care? Please provide the intent for integration and operations.

Additionally, are there approved service providers that the DHA has vetted or is currently using? We suggest providing a list to ensure continuity and care for the beneficiaries and aligning the vendors with approved practices.

No, there is not a specific section that addresses interpretation services aligned with telehealth care, the Government will consider providing this at a later time. DHA will not provide an approved list of providers, it is the contractor's responsibility to build this network.

80 C.9.7.1. The current language implies a need for large numbers of globally stationed interpreters, which would be prohibitively expensive and impractical. Would TOPO consider refining this requirement to focus on regions of greatest need?

The Government will define the locations in Attachment J-21, which will be released with Draft 2.

81 C.9.7.2. Please clarify that Tele-interpretation Services capabilities are only required when requested by the beneficiary. Tele-interpretation Services is only available in core languages within 30 seconds, suggest only for 5 core languages within expected timeframe and a longer timeframe for other languages where available.

No, it shall be accessible by both beneficiaries and providers. The Government will take your recommendation for 5 core languages under advisement and make any edits for Draft #2.

82 C.9.7.3. Video interpretation services are not practical due to privacy concerns and regulations. Most international providers would not allow a device that is broadcasting and potentially recording within their facility.

Thank you for your comments. The contractor is expected to notify the Government in situations where this is an issue.

83 C.10., C.8.5. How does DHA currently measure or plan to measure compliance with interoperability requirements (DEERS, TED, HIPAA)? Would DHA consider requiring HL7® FHIR® APIs or enterprise BI tools to improve oversight and reduce data latency across claims and clinical operations?

Interoperability is measured during the contract transition period with connectively testing between systems. DHA already has established technical specifications which are provided upon request.

The Government will take your comments under advisement.

TOP 2028 Draft RFP Questions & DHA Responses HT9402-25-R-0219 Page 19 of 23

84 C.10.1, C.10.4.2 We suggest the DHA clearly define acceptable AI processes for data synthesis and establish or communicate an approved list of AI systems that comply with DHA standards. With the integration of AI, it is critical that standardized rigor be applied to services that include security and interoperability. We recommend the DHA utilizes standards such as aligned with other key programs of record. We believe that this will enhance commercial technology integration. Further, this will allow a more cohesive approach to DHA healthcare.

Thank you for your suggestion, it is the contractor's responsibility to understand the DHA security requirements and should propose how they plan to incorporate proven AI technology as part of their approach to data synthesis and communication.

85 C.12.3.1 Is there a preferred format for in-flight medical record documentation, or should the contractor propose its own system? Establishing a standard that aligns with industry norms and can be broadly applied, would ensure consistency.

There is not a specific format, the contractor should propose its own process for providing the information required by C.12.3.1. While there is not a specific format, the preferred format should be similar to TRANSCOM Critical Care Air Transportation's documentation.

86 C.13 Are there individual personnel security clearance requirements for providers and networks that support CCMD line of effort? We recommend a standardized vetting process be implemented that aligns facilities within the DHA and leverages existing human resources and investigative processes. For those directly supporting the DHA and the CCMD mission, it is necessary to have this standardization to ensure consistency in access, care expectations and mission risk.

Please reference TRICARE Systems Manual 7550.4-M, April 2021, Chapter 1, Section 1.1 for General Automated Data Processing Requirements;

paragraph 1.12 lists the requirements that contractors, subcontractors and other individuals with access to information systems containing PII protected by the Privacy Act of 1974 and under the Health Insurance Portability and Accountability Act (HIPAA) shall meet. Additionally, TRICARE Operations Manual 6010.62-M, April 2021, Chapter 1, Section 5 provides requirements for Compliance with Federal Statutes regarding Information Security and HIPAA.

TOP 2028 Draft RFP Questions & DHA Responses HT9402-25-R-0219 Page 20 of 23

87 C.13.2.4 What are the integration and security requirements for the EFP portal (e.g., MHS Genesis)? These requirements will ensure a secure and seamless data exchange between contractor and government systems, which is vital for protecting sensitive information and maintaining operational efficiency.

This is a contractor developed portal and shall apply all security requirements.

88 C.13.3.2.3 Which secure web-based system is used to update Host Nation Facility Availability information, and what security measures are required for access? Ensuring strict security protocols for this system is essential to protect sensitive facility data and support operational integrity between contractor and government teams.

Each contractor is responsible for developing and maintaining the required secure web-based portals within the established systems requirements.

89 C.13.4. What is the expected level of participation for the contractor (table top, boots on the ground participation, remote coordination, data reporting, etc.)?

The level of participation will be dependent on what the exercise requires and will be defined upon notification from TOPO.

90 Section H, Incentives How does DHA currently structure or plan to structure performance-based incentives under TOP? Does DHA currently or would they consider tying award fees directly to claims accuracy, network adequacy, and beneficiary satisfaction, rather than process compliance alone?

Thank you for your comments, DHA will take this under consideration. TOP 2028 will include Performance Incentives, Performance Guarantees, as well as an Award Fee, and will be detailed in the Final RFP.

91 H.3.2. The draft references “adequate security” but leaves ambiguity. Would DHA consider explicitly requiring FedRAMP Moderate/High or CMMC Level 2+ for cloud platforms, and mandate flow-down to subcontractors, to ensure consistent protection of covered defense information?

Security requirements are outlined in the TRICARE Systems Manual 7950.4-M, April 2021, Chapter 1, Section 1.1, please reference paragraph 2.3.3 for CMMC requirements and paragraph 2.5 for Cloud Computing requirements.

92 TOM Ch 24 Section 2, Claims 2.2.5

“On-site BSR in all designated Military Medical Treatment Facility managed TSC locations” - How many locations?

These will be released with Draft 2 of the RFP in the J-attachments, in support of C.9.3.1.

93 TOM Ch 24 Section 2, Claims 2.2.5

“On-site BSR in all designated Military Medical Treatment Facility managed TSC locations” – Where are the locations?

These will be released with Draft 2 of the RFP in the J-attachments, in support of C.9.3.1.

94 TOM Ch 24 Section 3, 2.2.2

Can DHA please clarify the purpose for performing these reviews?

The purpose of these reviews is to validate the care being received continues to be medically necessary.

TOP 2028 Draft RFP Questions & DHA Responses HT9402-25-R-0219 Page 21 of 23

95 TOM Ch 24 Section 3 – Financial Administration, 3.2

Are the gain/losses reported related to currency exchange rates?

Yes, reported gains/losses are related to currency exchange rates.

96 TOM Ch 24 Section 4, 2.1

“Monitor provider quality” – Is the expectation for a full Utilization Review department and their processes?

The contractor is required to develop and implement a Clinical Quality Management Program Plan that meets the contract requirements.

97 TOM Ch 24 Section 5, 11.1.3

How will the contractor be notified of changes in eligibility?

Every contractor is responsible for verifying eligibility using the DEERS Interface. The contractor's also receive a notification when there are enrollment changes due to eligibility adjustments.

98 TOM Ch 24, Section 6, Paragraph 3

Disease Management Program: Same comment as above regarding medical data collection and administration. This is not feasible when working in multiple jurisdictions and under multiple privacy laws.

The Government will review and update this requirement for DRAFT #2.

99 TOM Ch 7, Section 1 Can TOPO confirm that this reporting system will capture only administrative data related to program delivery, rather than clinical/medical data?

The Government will review and update Ch 24 as appropriate DRAFT #2.

100 TOM Ch 24, Section 8, Paragraph 5.1.2

Currently, the contractor shall process and pay ADSM claims without an authorization as if there were an authorization on file so as not to burden the beneficiary.

Recommend this be rewritten to align with the current process.

The TOM language is correct, as it is speaking of care that is not authorized or covered.

101 TOM Ch 24, Section 8, Paragraph 5.1.2.2

Currently, the contractor shall process and pay ADSM claims without an authorization as if there were an authorization on file and the claim would not be denied.

Recommend this be rewritten to align with the current process.

The TOM language is correct, as it is speaking of care that is not authorized or covered.

102 TOM Ch 24, Section 8, 5.1.5

How will referral communications between the TOP Contractor and the MCSC contractors take place? What type of interface? How will eligibility be communicated from the MCSC contractors?

"The transmission between the TOP Contractor and the MCSCs is determined as part of the MOU development, as long as it is a secure transmission it is at the descretion…