Amendment 4 Govt Responses to Industry Questions.xlsx
XLSX spreadsheet 26 KB Posted
- Solicitation number
- HT9402-26-RFI-0001
- Issued by
-
Defense Health Agency
About this file
This file is an amendment containing government responses to industry questions submitted on the TRICARE Overseas Program (TOP) 2028 Second Draft Request for Proposal. The Defense Health Agency (DHA) addresses 25 questions and comments from potential offerors regarding the draft RFP requirements for managing overseas healthcare services for TRICARE beneficiaries.
Key topics addressed include: historical data availability, with DHA confirming it will provide summary enrollment data, claims data for calendar years 2023-2025, aeromedical evacuation data, authorization requests, customer service data, historical translation data, medical capability reports, and TRICARE Service Center walk-in data (excluding specific CDRL deliverables and detailed provider information due to proprietary constraints); claims administration and financial operations clarifications to be included in the final RFP Section G; systems and interfaces specifications using X12 EDI standards with details in CDRL R180 B2B Questionnaire; transition support including TRICARE Service Center locations and workspace allocations detailed in Attachment J-4; population scope, data exchange standards, security accreditation requirements (NIST SP 800-171 baseline, CMMC status, FedRAMP Moderate equivalency for cloud computing), and KPI definitions sourced from various CDRLs and Section H of the Final RFP. The government also considers industry recommendations on network adequacy language, contingency support requirements, case management definitions, translation methodologies using AI and machine translation technologies, medical record collection timelines by region, and interpretation service delivery flexibility, noting that certain timeliness standards for medical records and translation will not be adjusted and that CONUS care workload may receive separate treatment in the final RFP.
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Other files
| File | Type | Posted |
|---|---|---|
| Amendment 4 Historical Data Ordering Instructions.docx | DOCX document | |
| Amendment 0003 TOP 2028 DRAFT J Attachments.zip | ZIP file | |
| TOP28 DRAFT RFP Questions.docx | DOCX document | |
| Historical Data Attachment 1 Non-Disclosure Agreement FINAL.docx | DOCX document | |
| TOP2028_SECTION C_DRAFT.docx | DOCX document | |
| Historical Data Ordering Instructions Final.docx | DOCX document | |
| TOP 2028 DRAFT TOM Chapter 24.docx | DOCX document | |
| TOP 2028 DRAFT CDRLs.zip | ZIP file | |
| TOP28 DRAFT RFP Questions for Industry.docx | DOCX document | |
| TOP 2028 DRAFT J Attachments.zip | ZIP file | |
| TOP 2028 DRAFT Section J.docx | DOCX document |
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Sheet1
| Question # | Subject | Solicitation Citation & Paragraph | Question/Comment | Response |
| 1 | Historical Data | DRAFT 2 | In reviewing the draft RFP, the most challenging aspect is developing a complete, supportable solution design and price without access to baseline operational data. In accordance with “TRICARE Overseas Program (TOP) 2028 Second DRAFT Request for Proposal (RFP)” issued 9 FEB 26, historical data is requested. Depending on the volume, specificity, and granularity of the data, it may not be possible to determine historical utilization/claims patterns and contact center demand by geography, language, and channel to size staffing, network build requirements, and service levels with confidence. If the data does not adequately provide necessary information, it would be challenging to determine the resources required to deliver the TOP28 contract. |
In addition, the overseas environment introduces complexity that is difficult to estimate without clearer parameters, including the volume and locations of certain required activities (interpreter needs, NOCs, encounters by location, types of care, MTF capabilities, medical records translations etc.) and any established waivers to policy/network/contract requirements. These aspects can materially change cost assumptions and calculations of transition and PMPM fee. Without this information, the incumbent is at an advantage to the rest of industry.
These challenges could be reduced significantly by providing industry with de-identified historical data and CDRLs sufficient to model demand and network needs (utilization/claims and contact center volumes by region, provider, language, and service type). It would also be helpful to define translation/interpreter volumes, as well as to clarify required systems, interfaces, and Government-furnished information/equipment and what specific transition artifacts and cooperation will be available. Collectively, these adjustments would improve proposal accuracy, reduce transition risk, and allow DHA to receive more accurate and comparable proposals. In short, anything is achievable with enough information, resource planning, and execution time. To support and encourage competition for TOP 2028,TRICARE Overseas Program Office is collating the following data sets for Industry:
Summary Enrollment Data CY25 Claims data for CY23, CY24 and CY25 Aeromedical Evacuation Data for CY25 Authorization Requests for CY25 Customer Service Data CY24 and CY25 Historical Translation Data 1SEPT24-31AUG25 Medical Capability Reports 1SEPT23-31AUG25 Notification of Case Data FEB25-JAN26 TRICARE Service Center Walk-in Data CY25
Due to proprietary constraints, we are unable to provide the specific deliverables under the CDRLs, and detailed provider information. MTF capability information is available online.
| 2 | Claims Administration and Financial Operations | DRAFT 2 | On claims administration and financial operations, the draft includes specific foreign payment mechanics and timelines that would benefit from confirmation of the intended operating model, including the approval workflow with DHA Contract Resource Management prior to check/draft issuance, the required approach for local-currency drafts (including country-specific requirements such as German drafts and use of a German address), the exchange-rate source and handling rules, and how DHA expects the contractor to calculate and report monthly currency gains/losses and manage reconciliation. Additional clarification on the expected bank account structure and recoupment processes (including when the contractor is financially responsible for errors) would also reduce ambiguity. | Claims administration and financial operation information and requirements will be included in Section G of the Final Draft. | |
| 3 | Systems and Interfaces | DRAFT 2 | On systems and interfaces, the draft references required automated eligibility/deductible/claims history capabilities, HIPAA-compliant claim formats and EDI acceptance/rejection behavior, TED creation/submission and downstream access via PEPR/PCDIS, and defined processing timeliness standards; DHA clarification on required interfaces (what is government-furnished versus contractor-furnished), data exchange specifications, and the scope of any data migration would materially improve pricing accuracy. Acuity reviewed DHA’s published responses to industry questions and recommends focusing any remaining clarifications on items not already addressed—particularly baseline volumes (utilization/claims, contact center, | ||
| translation/interpreter demand), and clear identification of government-furnished versus contractor-furnished interfaces, data exchanges, and CDRL artifacts. | Interfaces: Contractor furnished IT systems or covered contractor information systems (defined in DFARS 252.204-7012) are non-DoD IT systems owned, operated, and maintained by the contractor used in performance of the contract. |
Data Exchange Specifications and EDI/API standards: X12 EDI standards (E.g., HIPAA ASC X12). System interface specifications are prescribed in the Contract Data Requirements List (CDRL) (R180) B2B Questionnaire.
| 4 | Transition | DRAFT 2 | For transition execution, the draft indicates the incoming contractor will utilize existing TRICARE Service Centers and that the Government will set access/occupancy schedules at the TRANSPEC meeting, with specific readiness timelines for trained representatives and online interfaces. Clarifying the exact TSC locations, associated volumes of activity, and the number of personnel permitted at each location, and the incumbent artifact handover expectations would reduce transition risk and support an achievable 12-month schedule. | Attachment J-4- Government Furnished Equipment lists the locations, number of phone lines, equipment, and allotted workspace for the Beneficiary Service Representative at each location. The number of walk-in visits for CY25 at each TRICARE Service Center location is a component of the data being released to Industry. |
| 5 | Request for Clarifications | DRAFT 2 | Acuity reviewed DHA’s responses to industry questions and recommends that any future clarification package continue to include (1) claims data, program volumes by region and language for contact center and interpreter demand and medical record translation collection by site, (2) clear identification of TRICARE Service Center volume data (walk in queries, empanelment and briefings), and historical CDRL data. Providing this baseline information will reduce pricing uncertainty, improve comparability across offerors, and lower transition risk without changing DHA’s intended performance outcomes. | To support and encourage competition for TOP 2028, TRICARE Overseas Program Office is collating the following data sets for Industry: |
Summary Enrollment Data CY25 Claims data for CY23, CY24 and CY25 Aeromedical Evacuation Data for CY25 Authorization Requests for CY25 Customer Service Data CY24 and CY25 Historical Translation Data 1SEPT24-31AUG25 Medical Capability Reports 1SEPT23-31AUG25 Notification of Case Data FEB25-JAN26 TRICARE Service Center Walk-in Data CY25
Due to proprietary constraints, we are unable to provide the specific deliverables under the CDRLs and detailed provider information.
| 6 | Population | DRAFT 2 | Please confirm scope of TRICARE populations covered under TOP28 (e.g., active-duty family members, retirees, specific categories). | This information is included in RFP DRAFT 2, Section C and Attachment J-22 is the DRAFT of the TRICARE Operations Manual, Ch 24 for the TOP. Section 5 provides details of TOP Eligibility and Enrollment. The summary enrollment data also provides the size of each beneficiary population. |
| 7 | Data Exchange | DRAFT 2 | Please confirm accepted data exchange standards (EDI X12, FHIR APIs) and any gateway constraints. | Data Exchange Specifications and EDI/API standards: X12 EDI standards (E.g., HIPAA ASC X12). System interface specifications are prescribed in the CDRL (R180) B2B Questionnaire. |
| 8 | Security Accreditation | DRAFT 2 | Please confirm security accreditation expectations (e.g., NIST SP 800‑53 baseline, FedRAMP Moderate/High alignment) and Authority ATO process steps. | Baseline requirements: NIST SP 800-171. See DFARS clause 252.204-7012. While NIST SP 800-53 is not the primary control set for performance-based contracts (i.e., non-IT service-based contracts), the NIST SP 800-171 controls are derived from it. |
Cyber compliance: Contractors are required to have a current CMMC status at the level specified in the contract (DFARS 252.204-7021). The specific CMMC level required will be stated in the solicitation (DFARS 252.204-7025).
Cloud Computing (FedRAMP): Minimum requirement FedRAMP Moderate equivalency (see DFARS 252.204-7012) It should be noted, if the contractor intends to directly interface their CSP to the B2B Gateway to interconnect to a DoW system, then FedRAMP authorized or equivalent at High environment is recommended.
ATO process: ATO process is not applicable for performance-based/non-IT service-based contracts.
| 9 | KPI definitions | DRAFT 2 | Please provide required KPI definitions and any legacy baseline reports to ensure continuity of performance trending. | The KPIs can be identified in several of the Contract Data Requirements Lists and throughout the contract and manuals. Baseline reports are proprietary and will not be shared, it is the contractor's responsibility to build a program that will meet the expected targets. Section H of the Final RFP will also include details of Performance Incentives and how they will be calculated. |
| 10 | Records tats | C.8.3.1 | Records turn‑around times across multiple alphabets/languages. Recommend outcome‑based SLAs with tiering by document type/urgency. | Thank you for your comment. The identified records and timeliness standards for MRC and Translation are essential in supporting medical readiness and will not be adjusted. |
| 11 | Credentialing | C.6.7 | OCONUS credentialing in medically limited regions. Recommend alternative credential standards + enhanced supervision and explicit escalation paths. | Thank you for your comment. When drafting a proposal, Offerors can submit their plan to credential providers in medically limited regions, as long as they remain in compliance with TRICARE statues. |
| 12 | Data Residency | DRAFT 2 | Data residency and cross‑border transfer of PHI. Recommend clarifying permissible storage/processing locations and encryption key ownership. | Cloud computing services. US or US outlying areas or DoD on premises. |
Furthermore, a successful records management program is detailed in the TRICARE Operations Manual (TOM) Chapter 9, Section 1, Para 1.0. The below TRICARE manual requirements might have references to this topic:
1. Compliance with DoD Security Rules: TOM, Chapter 19, Section 3.
2. Compliance with Host Nation Laws: TRICARE Policy Manual (TPM), Chapter 7, Section 22.1.
| 13 | Data Exchange | DRAFT 2 | Integration formats. Recommend confirming accepted EDI/API standards to streamline claims and MI exchange. | Data Exchange Specifications and EDI/API standards: X12 EDI standards (E.g., HIPAA ASC X12). System interface specifications are prescribed in the CDRL (R180) B2B Questionnaire. | |
| 14 | High Level Objective: Quality Overseas Healthcare System | C.2.1 | To ensure DHA receives a comprehensive overseas healthcare system, contract language should explicitly require both in-person clinical capacity and virtual health solutions. Digital health tools should supplement and enable a strong local network. Recommend revising the language to: “Integrates the overseas private sector healthcare system with the direct care system and utilizes digital health solutions where appropriate, to supplement a robust local network that ensures reliable access to quality care.” | Thank you for your input. The Government will take this under consideration. | |
| 15 | High Level Objective: Optimal Beneficary Experience | C.2.2 | To ensure TRICARE beneficiaries receive a system that is custom tailored to provide them with the best possible experience, suggest altering the last sentences from “Modernize the care experience using best-in-class approaches and state-of-the-art technology. Continuously improve patient care experience through data-driven initiatives and cutting-edge technology” to “Support the beneficiary care experience using best-in-class approaches and state-of-the-art technology where appropriate. Continuously improve patient care experience through data-driven initiatives, operational enhancements and technology.” | Thank you for your input. The Government will take this under consideration. | |
| 16 | High Level Objective 4: Combat Support Agency Role | C.2.3 | To allow the contractor to provide a broad range of support in contingency operations, suggest rewording to “Objective 4: Combat Support Agency Role. Support Combatant Commands (CCMDs) and Combat Support Activities. Provide private sector healthcare solutions that support CCMD medical operations and contingency requirements.” | Thank you for your input. The Government will take this under consideration. | |
| 17 | Network Adequacy CAP | C.6.3.1 and C.6.3.2 | Recommend replacing CAP language with: “The Contractor shall assess network adequacy on an ongoing basis, report any instances of network inadequacy to the Government per CDRL requirements, and submit a white paper detailing medical capabilities and suggested alternatives when there is an inadequacy persisting more than 30 calendar days.” | ||
| A CAP requires an achievable outcome that can be evaluated and measured to confirm corrective actions are in place. 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 the region. | Thank you for your input. The Government will take this under consideration. | ||||
| 18 | Network Contingency Support | C.6.4 | To ensure the TRICARE Overseas Program is prepared for rapidly evolving global events, we recommend broadening the contingency support requirements to emphasize existing capability, agility, and boots-on-the-ground operational readiness. The current PWS places limitations which do not fully capture the range of contingency services DHA may require in complex overseas environments. To create a more flexible, outcomes-based framework aligned with DHA’s mission, we recommend the following expanded language: |
1. Require capability to respond to immediate contingency activation:
“The Contractor shall maintain validated contingency support capabilities, including operational coordination resources, and clinical and non clinical response elements able to activate globally with limited notice.”
2. Broaden the definition of contingency support: “Contingency support includes, but is not limited to, medical stabilization, patient tracking and movement coordination, logistics facilitation, provider and facility assessment, translation and communication support, and operational liaison functions necessary to ensure care continuity. The Government may direct the Contractor to provide contingency support activities in addition to those explicitly identified above, consistent with the Contractor’s demonstrated capabilities.”
3. Ensure capability across permissive, semi permissive, and non permissive environments: “The Contractor shall possess and document its ability to deliver services in permissive, semi permissive, and non permissive environments, including clear processes for risk assessment, personnel deployment, and operational execution in each environment.”
4. Establish a comprehensive planning support “The Contractor shall maintain a standing Contingency Support Framework outlining surge support assets, operational capabilities, and communication channels and participate as directed in planning exercises”
| Thank you for your input. The Government will take this under consideration. | ||||
| 19 | Case Management | C.7.5.4 | In the final RFP, the Government should define “complex, sensitive, rare, high-profile, or high visibility.” | Thank you for your input. The Government will take this under consideration. |
| 20 | Document Translation | C.8.2.7 | The wording of this sentence still implies two humans in the loop, which eliminates the advantages of utilizing AI or other programmatic translation capabilities Recommend revising the language to: |
“The Contractor shall ensure all translated documents are complete, accurate, and certified. When the initial translation is produced using machine or AI based tools, a single qualified medically trained certifying linguist may validate and certify the final product to confirm accuracy.”
| This removes the requirement from a two human workflow and simplifies the operational processes while encouraging the use of advanced translation technologies and preserving quality and compliance at a reduced cost model. | Thank you for your input. The Government will take this under consideration. | ||||
| 21 | Medical Record Translation | C.8.2.1 | To ensure DHA benefits from rapid advancements in translation and medical documentation technologies, the requirement should emphasize the outcome required (accurate, complete English language medical records) rather than specifying the method used to produce them. We recommend broadening the requirement to allow the contractor to employ the best tools and technologies available at any point during contract performance. Suggest the following language: | ||
| “The Contractor shall ensure all translated medical records are accurate, complete, and written in grammatically correct English. The Contractor may use any combination of industry leading tools, including machine translation, algorithmic methods, and large language model (LLM) systems, with a qualified medically trained translation expert to certify the final product to achieve this outcome. The Contractor shall select and apply the most effective available technologies that conform to federal software requirements to deliver high quality translations in a timely and cost-efficient manner.” | Thank you for your input. The Government will take this under consideration. | ||||
| 22 | Medical Record Translation | C.8.2.9 and C.8.2.10 | Requiring exclusions reduces the ability to streamline the operational process, requiring more human intervention and manual QC checks. DHA should require an outcome focused approach that ensures complete full record, timely, and cost-efficient delivery of these records. To achieve this, the contract should incentivize innovative, technology-enabled methods rather than prescriptive processes. Recommend adding language such as: | ||
| “The Contractor shall provide a complete medical record collection and translation using innovative, cost-effective methodologies, ensuring full and accurate records are delivered within required timelines. The Contractor may propose firm fixed price models or other cost stabilizing approaches that guarantee complete record delivery while maintaining predictable costs for the Government.” | Thank you for your input. The Government will take this under consideration. | ||||
| 23 | MRC and Translation Delivery | C.8.3.1 | Different countries or markets have different medical record production timelines defined by statue, regulation, or market. Recommend instead that contractor submit a CDRL providing a matrix of timelines depending on region. Collecting the inpatient medical record is constrained by Medical Governance within Health Systems. Specific examples of inpatient constraints include: | ||
| • | Joint Commission: Medical summary completed no later than 30 days | ||||
| • | Center for Medicare and Medicaid Services (CMMS): 42 CFR 482.24 (viii) Final diagnosis with completion of medical records within 30 days following discharge. Literature, best practice is 7 days, but the standard is 30 | ||||
| • | Germany: median waiting time for patients in the inpatient discharge letter to German PCMs was 4 weeks (2024 Article) | The timeliness standards for MRC and Translation are essential in supporting medical readiness and continuation of care and will not be adjusted. If the contractor is unable to meet the required timeliness standards, they will be expected to submit a waiver request to the CO with the proper justifications as to why they are unable to meet the standards. | |||
| 24 | Tele/video interpretation | C.11.3 | Recommend that the requirement clearly identifies the objective to provide real-time access to interpretation services across diverse overseas environments rather than prescribing a uniform technical method. We recommend broadening the requirement to allow the Contractor to determine the most effective solution based on local infrastructure, regulatory and legal constraints, and beneficiary needs. Suggested language: | ||
| “The Contractor shall ensure that providers and beneficiaries have real-time no cost access to interpretation services. The Contractor may determine the most effective delivery method based on local conditions. The platform used should consider the best experience for the beneficiary in the environment.” | Thank you for your input. The Government will take this under consideration. | ||||
| 25 | CONUS Care | C.7.3.1; C.7.4.2; C.7.4.3; C.7.8.3 | Each of these sections' references care in CONUS. CONUS care is not, as stated in C.7.8.3, a sometimes event. There are in any given month between 20-40 Inpatient Mental Health/SUDRUF admissions. Additionally, there are Stork nesting cases, outpatient OCMRs, and other inpatient admissions. This situation is unique to the other MCSCs. Recommend that CONUS Care be a separate section in Section C. This would be of benefit to the Government to capture the true workload performed within CONUS and for standardization of KPIs for this population. | Thank you for your input. The Government will take this under consideration. |
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