ICC SOW_SSN 220374.docx

June 22, 2004 Sources Sought Notice (SSN) 220374

STATEMENT OF WORK (SOW)

RISK ADJUSTMENT DATA VALIDATION (RADV)

Independent Coding Consultant (ICC)

I. SCOPE

The Centers for Medicare and Medicaid Services (CMS) is seeking a contractor to serve as the Independent Coding Consultant (ICC) contractor responsible for providing expert coding support for the medical record reviews (MRR) for the Contract-Level Risk Adjustment Data Validation (RADV). The Contractor shall also provide training for the Contract-Level RADV Medical Record Review Contractors (MRRCs), and develop written communication, guidance and briefing materials to clarify the RADV and MRR process.

A. Background

CMS conducts RADV audits using MRR to validate the accuracy of risk adjustment data submitted to CMS by Medicare Advantage Organizations (MA organizations) for Medicare Part C payments. The purpose of RADV is to measure the extent to which inaccurate diagnosis codes affect CMS-Hierarchical Condition Categories (CMS-HCC) assignments and the associated payment for MA beneficiaries. The CMS primary RADV objective is to estimate Contract-Level risk-adjustment payment-error for payment adjustment and payment recovery efforts.

CMS conducts two (2) major Medicare RADV projects: the National sample and the Contract-Level sample (the term sample is synonymous in this context with audit). The National sample is used to compute an error estimate for the Medicare Part C Program. The Contract-Level sample is used to estimate payment adjustments at the MA Contract-Level based on MRR findings. The Part C payment error estimate and the MA Contract-level payment adjustments represent CMS’s response to provisions set forth in the Improper Payments Information Act (IPIA) of 2002 as amended by the Improper Payments Elimination and Recovery Act (IPERA) of 2010 and the Improper Payments Elimination and Recovery Improvement Act (IPERIA) of 2012. This project focuses primarily on the Contract-Level RADV sample.

1. Description of Risk Adjustment

The Balanced Budget Act (BBA) of 1997 mandated that payments to MA organizations be based on the health status of their enrollees. By implementing risk adjustment, CMS creates a level playing field and MA organizations are paid more accurately based on the health status of their enrollees. Full risk adjustment payment to MA organizations was phased in over a period of years; since 2007, payment has been made on a 100% risk adjusted basis. Since risk adjustment payment is based on enrollee health status, MA organizations are provided with an incentive to enroll and treat less healthy Medicare beneficiaries.

To receive risk adjustment payments, MA organizations submit diagnostic data to CMS. The data elements collected are Health Insurance Claim (HIC) number, beneficiary ICD-9/10 diagnosis codes, from and through dates of service, and the provider type (hospital inpatient, hospital outpatient, and physician). CMS only requires a one-time submission of all relevant diagnoses (as these diagnoses affect payment) for each enrollee during a data collection period. For example, if an enrollee has been treated 10 times for congestive heart failure during the year, the MA organization is only required to submit the congestive heart failure diagnosis once in the data collection period for payment to occur. MA organizations are required to submit risk adjustment data on a quarterly basis.

Risk Adjusted payment is based on the CMS-HCC model. The CMS-HCC model can be found at: https://www.cms.gov/Medicare/Health-Plans/MedicareAdvtgSpecRateStats/Risk-Adjustors.html . The CMS-HCC model is additive, and includes most body systems (that is, multiple chronic diseases are incorporated into the risk factor for an enrollee). In some cases, however, a diagnosis that is included in the model does not trigger additional payment because a more severe diagnosis supersedes the less serious one; these are considered hierarchy cases.

The CMS-HCC model uses diagnoses from multiple sites of care: physician, hospital inpatient and hospital outpatient. The model is site neutral, which means that the model does not distinguish payment amounts based on the site of care where the diagnosis was generated (i.e., hospital inpatient, hospital outpatient or physician setting).

The model is divided into segments with associated coefficients that define the relative mean predicted expenditure based on place of residence for the Medicare Fee-For-Service (FFS) population - community versus long-term institutional. These segments are applied to all enrollees with 12 months of Medicare Part B enrollment during the data collection period (i.e., full risk enrollees). The community model is used to calculate Medicare Part C payment risk scores for enrollees who spent less than 90 days in an institution (i.e., community enrollees). The institutional model is used to calculate payment risk scores for enrollees who spent 90 days or greater in an institution during the payment year (i.e., institutional enrollees). Additionally, a new enrollee segment applies to beneficiaries who are new to Medicare, and beneficiaries with less than 12 months of Medicare Part B enrollment during the data collection period.

The CMS-HCC model is periodically re-calibrated to reflect newer treatment and coding patterns in Medicare FFS; thus, updating the coefficients for all segments (community, long-term institutional and new enrollee). In annual payment notices, CMS provides the disease groupings, draft coefficients, and the disease hierarchies for the model. The final coefficients for each of the segments are provided in the specific calendar year’s Announcement of Medicare Advantage Capitation Rates and Payment Policies.

2. Description of Medicare Advantage Risk Adjustment Data Validation Activities

CMS conducts annual MA RADV activities for ensuring the accuracy and integrity of risk adjustment data and MA risk adjusted payments. The focus of data validation is on reviewing medical record documentation to verify diagnoses submitted by MA organizations for payment under Medicare Part C. One of the major RADV projects CMS conducts is the Contract-Level specific sample. The Contract-Level specific sample is used to calculate an error estimate for a specific MA contract.

The Contract-Level RADV project includes the following processes:

1. Sampling. For the Contract-Level RADV audit, CMS uses defined criteria by which to select statistically valid samples of enrollees for the purpose of estimating payment error. For the contract-specific samples, CMS may target and/or randomly select MA contracts to undergo RADV audits. A random sample of enrollees is selected from each audited contract. The enrollee samples selected for the Contract-Level audits are used for estimating payment error with the intent of conducting payment recovery based on MRR findings for individual contracts.

· Medical Record Request. CMS notifies MA organizations of their selection for RADV and requests primary points of contact that will be responsible for facilitating the RADV process on behalf of the MA organization. CMS then sends each selected MA contract a medical record request for submission of medical records to support the CMS-HCCs for each enrollee in the MA contract’s sample.

· Medical Record Submission and Receipt. MA organizations are required to submit the requested enrollee medical records to CMS’ designated contractor for medical record receipt and intake. The records go through a logging and technical assistance process, where necessary, in preparation for MRR.

· Medical Record Review (MRR). Certified medical record ICD-9/10-CM coders review the medical records submitted by the MA organizations and abstract diagnoses in accordance with the ICD-9/10-CM coding guidelines.

· Medical Record and Payment Error Findings. Corrected enrollee CMS-HCC profiles are developed based on the MRR results. These findings are used to develop corrected payment error results for each sampled enrollee. CMS sends MA organizations in the Contract-Level samples the MRR results for their sampled enrollees. CMS also gives the organizations the opportunity to submit a dispute, which provides an explanation from the plan as to why a discrepant MRR finding is incorrect.

· Medical Record Disputes (MRD). MA organizations who wish to dispute discrepant CMS-HCC results may submit their disputes, following CMS official guidelines for this process. The organization-submitted disputes are then reviewed by medical record reviewers and final determinations to either uphold or overturn a CMS-HCC discrepancy are made.

· Final RADV Medical Record and Payment Error Findings. CMS re-establishes individual CMS-HCC profiles and correct payments based on the results from the MRDs. The revised enrollee-level results are then extrapolated to estimate payment error for the Contract-Level population, and a payment recovery amount is established based on CMS’ policies.

· Appeals:

Medical Record Review Determination (MRRD) Appeal For Contract specific samples, CMS will afford MA organizations an opportunity to appeal MRR findings for diagnoses that are not supported by medical records. MRR will be conducted by a MRRC. Upon completion of the review, the MRR findings and payment error calculations will be reported back to the MA organizations. If a plan disagrees with a MRR finding, it can appeal the MRR findings. A hearings officer will adjudicate all MRR appeal requests. Plans that request MRR appeal will receive an appeal determination from the hearings officer and an appeal report of findings from CMS. This decision by the hearings officer will be final and binding unless the MA organization requests review by the CMS Administrator, who will be granted discretionary review authority.

Payment Error Calculation (PEC) Appeal MA organizations may also choose to appeal CMS’ RADV payment error calculation. If plans do not believe that CMS calculated payment error according to our stated methodology, they may appeal. An independent appeals entity will recalculate the payment error estimate and submit findings to an independent reconsideration official. The reconsideration official will make a determination, which is binding unless appealed to the CMS hearings office. If appealed, the CMS hearings office will review the determination and any other evidence submitted by the MA organization and issue a determination. The determination by the CMS hearings office will be final and binding unless the MA organization requests review by the CMS Administrator, who will be granted discretionary review authority.

To facilitate the RADV process CMS has developed the Centralized Data Abstraction Tool (CDAT). RADV MRR and some activities related to payment error calculation shall occur via the tool. CDAT will be the system of records used to manage the collection and distribution of medical records, RADV project data, and other project information. The entities involved in using CDAT to facilitate the flow of information will include CMS, RADV contractors, Appeals entities, and MA organizations.

3. Contractors Involved in Risk Adjustment Validation Data

As part of this overall MRR project, the ICC will collaborate and coordinate with, and receive support from the following contracting functions:

Lead Analytic Contractor (LAC): will coordinate the overall analytic approach and process for the medical record activities. This will involve sampling, analysis, developing reports, calculating initial and final payment error estimates, working with the Intake Evaluation and Medical Record Review Contractors (IMRRCs) to conduct requests, and managing project data. The LAC will also train CMS, its contractors and MA organizations CDAT users on the use of CDAT and the RADV process.

Central Data Abstraction Tool (CDAT) Contractor: responsible for implementing the Information Technology (IT) system processes and all applicable environments necessary to support the RADV project’s goals as follows:

· Maintain current CDAT system solutions to assure functionality for the RADV processes;

· Build new CDAT business solutions to meet ongoing RADV requirements for MRD, Contract-Level RADV audits, and ad-hoc RADV activities;

· Build new CDAT IT business solutions, as needed, to meet new or changed RADV requirements;

· Provide comprehensive IT functionality and technical support to all CDAT end users;

· Train RADV CDAT contractors and end users on their CDAT functional roles; and

· Evaluate systems and business solutions to assure optimal operations with regard to the implementation of RADV processes on CDAT.

· Prepare for and manage transition to a new CDAT contractor; and

· Comply with the CMS Office of Information Systems (OIS) requirements.

Medical Record Review Contractor (MRRC): will facilitate the medical record request and intake evaluation process including technical assistance and submission compliance; will conduct MRR, including the ICD-9/10-CM coding of foreign language medical records as needed; and will conduct MRD.

Program Assurance and Data Optimization Support (PADOS): will perform the role of communication and quality assurance and will transmit CMS’ RADV communications to MA organizations and RADV Contractors on behalf of CMS. The PADOS Contractor captures RADV project communications from all communication sources for reporting to CMS and RADV Contractors and tracks communications until closure. The PADOS Contractor writes the RADV Standard Operating Plan (SOP) and also serves as a liaison between CMS, the Contractors, and the other parties to coordinate, prepare and manage documentation.

4. CDAT Modules supporting RADV

The ICC will mainly utilize the following CDAT modules to support the CMS RADV project. These modules are provided within the CDAT system and training will be performed by the CDAT contractor.

CDAT Coding Discussion Journal The coding discussion journal (CDJ) and the reconsideration discussion journal (RDJ) allows for the capture of issues identified during coding and reconsideration as well as decisions made by the Escalation QA Panel to help coders resolve specific issues related to a medical record.

CDAT Research Module The CDAT Research Module provides access to medical records by all authorized users. Accessing medical records is accomplished by using search parameters within CDAT that will return the corresponding medical record image results. The research module shall be maintained to assist in multiple efforts that include coder medical record training, probe sampling, MRD and appeals. The research module serves as a window into CDAT without impacting workflows.

CDAT Plan Portal The plan portal central library is maintained to expedite the dissemination of information to MA contracts. The library allows for administration and display of shared files on the plan portal to all approved MA contract users. The library also includes CMS communications and RADV resources.

CDAT Central Coder Queue The CDAT central coder queue is maintained to support the functionality for intake, abstraction, and MRD modules in CDAT. The central coder queue allows up to multiple IMRRCs/MRRCs to access the intake, abstraction and MRD modules. For intake, users must have the ability to request a record within a queue that is ready to be processed and not currently being reviewed by any other user. For abstraction, the central queue must allow the ability for a MRRC user from any MRRC with permissions to request a record that is ready to be processed for abstraction.

CDAT Multiple Medical Record Process/Workflow The Multiple Medical Record Process/Workflow supports the processing of single and multiple medical records during the submission phase of RADV. Once the medical record(s) are submitted, CDAT will provide a mechanism for RADV contractors, as defined by CMS, to review each medical record.

The existing medical record workflow incorporates functionality including Intake (Submission), Abstraction and MRD. Several reviews are performed on each medical record submitted to CDAT. Intake includes user access and medical record submission to CDAT. Abstraction in CDAT is performed by RADV contractors, as designated by CMS. Medical records submitted must be available to multiple contractors for abstraction. MRD is described further below.

CDAT Repository The Repository module will allow CMS and RADV contractors to access a repository from within the CDAT application. The CDAT repository must allow users to organize documents within a folder structure, relating to all phases of a RADV audit, including appeals.

Reconsideration The reconsideration module allows for the capture and evaluation of MA contracts’ requests for MRDs and findings related to the disputes. The reconsideration write-ups are submitted by MA Organizations in response to the Audit Reports (AR’s). The CMS RADV contractors and CMS evaluate the disputes in CDAT and document findings.

CDAT Encoder The encoder tool is maintained in CDAT to provide uniformity in MRR process with encoder tool utilization across the MRRCs.

RADV Ad-Hoc Sample Module CMS, on occasion, may conduct ad-hoc RADV audit samples to satisfy program and/or CMS requirements. The ad-hoc sample module shall be used to perform any combination of intake (submission), abstraction, and reporting of findings using logic as defined by CMS. Activities to support the ad-hoc sample(s) may include converting files for compatibility in CDAT, creating coversheet files, converting data sets in CDAT format, creating scripts to set up the ad-hoc sample(s), and modifying the other existing CDAT modules to allow for full processing of the ad-hoc sample.

CDAT RADV Team Library The RADV team library is maintained to facilitate the dissemination of RADV sample and project related information to CMS and RADV contractors. The library must allow for the administration and display of shared files to all approved non-MA Contract CDAT users.

B. Purpose

The purpose of the ICC is to provide expert coding support for the MRR for the Contract-Level RADV. The ICC will manage and help to resolve discrepant medical reviews and escalated cases that require an objective knowledgeable opinion. The Contractor shall also provide training for the Contract-Level RADV MRRCs, and develop written communication, guidance and briefing materials to clarify the RADV and MRR process.

C. Assumptions and Constraints

CMS recognizes the following assumptions and constraints:

· All information required to accomplish the tasks under this Statement of Work (SOW) shall be provided to the Contract Officer Representative (COR), by this Contractor, in hard copy and/or via a mutually acceptable electronic format as requested during the process and upon completion of this project. The information shall be provided in the manner that clearly identifies the purpose of the information and could be easily replicated and implemented by a separate independent entity.

· The Contractor shall conform to all requirements (paper and electronic) for protecting beneficiary and MA organization level confidential data. For all tasks relating to coding support for the MRR, and to conduct coder training, CMS shall provide guidance in the form of standards, policies, procedures and oversight of this contract.

· The Contractor shall establish connectivity to CMS, in order to perform required tasks.

· There may be times when the Contractor shall be required to have staff at CMS to attend meetings per this SOW or as requested by the COR.

· The Contractor shall use the current CMS standard desktop suite versions for all deliverables.

· Where timeframes are stated, CMS may choose to give consideration to unforeseen circumstances. Therefore, deliverable due dates are as stated unless otherwise authorized by the COR.

· The Contractor shall provide software and licenses for software as required by CMS.

· The Contractor shall not design, implement, or maintain any customized or proprietary utilities without prior approval in writing from the COR.

· The Contractor shall update and maintain all documentation and deliverables in this contract.

· The Contractor shall supply necessary computer equipment to access CMS systems to conduct work.

II. REQUIREMENTS

A. General Requirements

CMS will be using CDAT for its Contract-Level RADV audits. The tool will be used for 1) storage and review of all medical records, and audit documentation, and 2) management and analysis of all RADV and MRR data for the RADV audits. The tool will be hosted by the CDAT Contractor and access to the tool will be granted to RADV Contractors at the discretion of CMS.

The Contractor shall be able to access the tool to:

· View medical records, intake data, and coder abstraction data;

· Provide MRR consultation to Contract-Level RADV audit coders regarding specific medical record documentation and coding guidelines;

· Assist in evaluations of MRD/ reconsideration justifications;

· Upload draft and final audit documentation as directed by the COR; and

· Provide training to new project participants on the tool.

The Contractor shall collaborate with other project contractors to prepare training and instructional materials relating to the CDAT tool for all project participants. The contractor shall provide technical input and evaluation regarding development, updates, and on-going performance of the tool from the medical record intake and coding, and overall RADV operational policy perspectives.

· Data Use Agreement

The Contractor shall establish a standard DUA with CMS to attain access and protect data related to the Medicare program and RADV. The Contractor shall comply with all parts of the DUA.

The Contractor shall document how they will protect and manage data in a Data Management Plan. The Contractor shall deliver the Data Management Plan to the COR as referenced in the Schedule of Deliverables. If updates are made during the year, the Contractor shall provide the updates to the COR at the time the updates are made.

B. Key Personnel

This project will involve three key personnel who play a significant role in the development and execution of the contract.

Independent Coding Consultant

The Independent Coding Consultant is responsible for coordinating the management of all work performed under the contract.

Experience Requirements:

The ICC must have keen medical record reviewer skills and considered an expert in the field to be able to assign and evaluate all work performed under this contract, and thus must have an in-depth knowledge of MRR and the International Classification of Diseases, Clinical Modification. This includes being an expert coder, and having a full range understanding about the relationships between coding, medical record documentation guidelines, and CMS payment and risk adjustment policies. Must have at least five years of relevant experience in a similar role.

Education and Certification Requirements:

A Medical Coders certification from an accredited entity is required.

Independent Coding Consultant Assistant

The Independent Coding Consultant Assistant will act as the back-up personnel for the ICC. The ICC Assistant shall be able to perform medical reviews and clerical duties as needed. Must have at least two years of relevant experience in a similar role.

Experience Requirements:

In-depth knowledge of MRR and the International Classification of Diseases, Clinical Modification.

Education/Certification Requirements:

A Medical Coders certification from an accredited entity is required.

Project Manager

The Project Manager is responsible for coordinating the management of all work performed under the contract. The Project Manager must have the skill level to be able to assign and evaluate all work performed under this contract.

Experience Requirements:

· Serving as a liaison to the government on all contract issues and policy matters

· Managing project staff (and Subcontractors if applicable)

· Ensuring contract requirements are met including quality, cost control, timeliness and business relations

· Ensuring timely delivery of high-quality deliverables

Education/Certification Requirements:

Bachelor’s degree or four years of Project Management experience in the medical record coding field.

C. Specific Requirements

Task 1. Coding Consultant

The purpose of this task is to provide expert Part C RADV consulting for the Contract-Level RADV audits, and develop and maintain key RADV documents and develop other written materials specific to RADV. The contractor will provide monthly updates to this task in the monthly status report. Some of the regular activities include, but are not limited to:

QA Panel: The contractor will serve as the Medical Records Review Quality Assurance (QA) Panel Editor, function as the panel leader, set the panel agenda and invite members according to the topics of cases. As part of the QA protocol, will research coding issues for resolving cases escalated to QA panel.

PHI/PII: The contractor, being the QA Panel Editor, will be responsible for confirming whether records in CDAT contain inappropriate PHI/PII, or not, and if inappropriate PHI/PII is confirmed the contractor will request approval from CMS to have the PHI/PII information deleted based on protocols in place.

Plans Communication: Facilitate providing responses as may be requested to Contract-Level RADV questions related to Plans communications on medical records intake and review.

a. RADV Support and Consultation for Contract-Level RADV audits.

The Contractor shall provide expert risk adjustment and MRR support for the RADV audits. The Contractor shall also keep RADV core audit participants (i.e., CMS and RADV Contractors) informed about the latest official coding and documentation guideline updates. Specifically, the Contractor shall submit brief write-ups that discuss coding and documentation guideline updates and their impact for risk adjustment and data validation and facilitate. The contractor shall participate in routine coding panel discussions with Senior Coders from RADV Contractors and other participants designated by CMS to provide CMS with coding and documentation issues that may impact RADV. The Contractor shall assist in completing evaluations of reconsideration justifications for the RADV audit. The Contractor shall provide support for appeals to CMS and other contractors or Agencies on CMS’ behalf by providing relevant information upon request by the COR. The contractor will provide monthly updates to this task in the monthly status report.

b. Key Contract-Level RADV Audit Documents

The Contractor shall develop and maintain key RADV audit documents such as Coder Guidance (including technical assistance), Intake Guidance, MRR Process Plan, Medical Record Reviewer Guidance, any documentation related to Inter Rater Reliability (IRR) or coder agreement processes, and Training Plans to be included in the overall MRRC training guides. The contractor will provide monthly updates to this task in the monthly status report.

c. Other Written Materials

The Contractor shall develop and maintain written guidance such as briefing materials and Question & Answers (Q&A’s), in response to inquiries relating to coding and documentation for the Contract-Level RADV audits. The recipients of these correspondence materials will include, but are not limited to MA organizations, internal CMS experts for coding and documentation guidelines, CMS Leadership, and other CMS RADV Contractors. The contractor will provide monthly updates to this task in the monthly status report.

Task 2. Training for the contract level RADV MRRCs

The Contractor shall conduct routine and ad hoc training for the MRRCs. In particular, the Contractor shall:

· Provide training to each MRRC in preparation for its Contractor and Coder Trainings;

· Assist the MRRCs with development of their coding and other related training materials;

· Assist with the development of Contractor training materials for all RADV audit Contractors;

· Provide evaluation and feedback regarding development and improvement of CDAT;

· Train coding teams at any MRRC on an as needed basis;

· Facilitate ad-hoc coding discussions and respond to on-going coding and documentation guideline inquiries from MRRCs;

· Facilitate and participate in coding panel discussions;

· Apply lessons learned in future trainings from prior training sessions; and

· Provide monthly updates to this task in the monthly status report.

Task 3. Technical Assistance Protocols

The Contractor shall develop and maintain technical assistance protocols for medical records request and review processes. This information shall be incorporated into MRR Process Plans, Training Plans, Intake Guidance, and Guidance to Coders documents. The contractor will provide monthly updates to this task in the monthly status report.

Task 4. Administrative Requirements

a. Kick-Off Meeting

The Contractor shall schedule a ‘kick off’ meeting, with OAGM and the COR no later than five (5) business days after contract award. Key personnel and other Contractor team members shall attend the meeting. CMS and the Contractor, collectively shall determine an agenda for the meeting and shall provide the agenda to the COR at least 48 hours in advance of the meeting.

b. Financial Status Reports

A detailed Financial and Contract report shall be submitted each month. Each report shall:

· Review accomplishments to date, remaining activities to be completed and the status of the project compared with its schedule;

· Discuss significant problems encountered or that are anticipated and their impact on the schedule of the project, or if severe enough, on the overall ability to accomplish the project goals;

· Include the contractor’s plans to deal with any identified significant problem and if appropriate, new delivery or completion dates shall be proposed and revised resource estimates included;

· Include data on planned versus actual expenditures by major task area (discrepancies greater than 10 percent shall be noted);

· Include a brief discussion of substantive findings to date; and include the monthly financial management report.

· Include a financial graph and narrative depicting budgeted costs, actual costs, and projected costs to completion shall also be included.

c. CMS Conferences for ICC Results

The Contractor shall participate on virtual routine or ad hoc conference calls as directed by the COR. Participants may include, but are not limited to, other RADV Contractors and CMS staff. The Contractor shall facilitate and coordinate these discussions, applying expert knowledge. The Contractor shall also participate in CMS internal discussions relating to RADV and general coding.

The Contractor shall be available onsite at CMS or virtually to provide up to four presentations to be made to CMS, the public and/or another interested party. The Contractor shall provide a draft of findings and presentation materials to the COR for approval two weeks prior to a presentation. The Contractor shall also be available for consultation with CMS, other Contractors and selected MA organizations on an as needed basis. The contractor will provide monthly updates to this task in the monthly status report.

d. Status Meetings

The Contractor shall schedule bi-weekly meetings as status updates with the COR. Up to four meetings may take place at CMS or virtually; the rest will be via conference calls. These calls and meetings will be used as a mechanism for discussing and managing administrative and COR issues as they arise. The Contractor shall, in conjunction with the COR, set the agenda, schedule the calls and provide a toll-free number for all conference calls. Draft agendas for meetings must be furnished to the COR at least 1 business day (24 hours) in advance of the meeting. Drafts of meeting minutes must be furnished within 3 business days of the meeting to the COR.

The Contractor shall provide the Government with all software, computer tapes, interim and final files, and file documentation upon request by the COR. Final copies of all software, computer tapes, files, and adequate documentation for all files are required upon completion of this project.

The Contractor shall take minutes at all meetings unless directed otherwise. Minutes from the meeting shall contain at a minimum:

· List of participants;

· Purpose of the meeting;

· Decisions reached during the meeting;

· Action items identified (include the person responsible for addressing the action and the date the action is to be completed); and, Date, time and location of next meeting

e. Monthly Status Report

A monthly status report shall be submitted each month. Each report shall include:

· Status updates regarding expert Part C RADV consulting for the Contract-Level RADV audits (Task 1.a.), development and maintenance of key RADV documents (Task 1.b.) and development of other written materials (Task 1.c.)

· Status updates regarding Training for the Contract-Level RADV MRRs (Task 2)

· Status updates regarding Technical Assistance Protocol (Task 3)

· Status updates regarding CMS Conferences for ICC Results (Task 4.c.)

Task 5. Optional Transition Period (Phase-Out and Transition)

The contractor shall develop and deliver a FINAL Transition Out Plan due 30 days prior to the end of the period of performance.

The transition out period occurs at the end of this contract. The transition out period will coincide with the transition in period for the next contract. During this transition out period, the contractor remains responsible for meeting all requirements under this task order. The contractor shall work with CMS and the subsequent contractor to avoid the disruption or degradation of services. This includes, but is not limited to, such activities as:

a) Planning for the transition activities;

b) Turnover of items such as system and testing documentation and guides/manuals developed in support of the task order;

c) Providing records, logs, and documentation of activities;

d) Attending meetings;

e) Providing training;

f) Interfacing with the new contractor at all levels from management to the lowest working levels; and

g) Planning and implementing the logistics of phasing-out contractor personnel and assets.

Schedule of Deliverables

The contractor shall submit all identified deliverables in accordance with the following schedule for each period of performance as applicable. Deliverables submitted shall be in accordance with the SOW. Deliverable dates that fall on a weekend or government holiday are due on the following business day.

ALL DELIVERABLES MUST BE 508 COMPLIANT

Section 508 - Accessibility of Electronic and Information Technology

(a) This contract is subject to Section 508 of the Rehabilitation Act of 1973 (29 U.S.C. 794d) as amended by the workforce Investment Act of 1998 (P.L. 105-220). Specifically, subsection 508(a)(1) requires that when the Federal Government procures Electronic and Information Technology (EIT), the EIT must allow Federal employees and individuals of the public with disabilities comparable access to and use of information and data that is provided to Federal employees and individuals of the public without disabilities.

(b) The EIT accessibility standards at 36 CFR Part 1194 were developed by the Architectural and Transportation Barriers Compliance Board ("Access Board") and apply to contracts and task/delivery orders, awarded under indefinite quantity contracts on or after June 25, 2001.

(c) Each Electronic and Information Technology (EIT) product or service furnished under this contract shall comply with the Electronic and Information Technology Accessibility Standards (36 CFR 1194), as specified in the contract, as a minimum. If the Contracting Officer determines any furnished product or service is not in compliance with the contract, the Contracting Officer will promptly inform the Contractor in writing. The Contractor shall, without charge to the Government, repair or replace the non-compliant products or services within the period of time to be specified by the Government in writing. If such repair or replacement is not completed within the time specified, the Government shall have the following recourses:

1. Cancellation of the contract, delivery or task order, purchase or line item without termination liabilities; or

2. In the case of custom Electronic and Information Technology (EIT) being developed by a contractor for the Government, the Government shall have the right to have any necessary changes made or repairs performed by itself or by another firm for the noncompliant EIT, with the contractor liable for reimbursement to the Government for any expenses incurred thereby.

(d) The contractor must ensure that all EIT products that are less than fully compliant with the accessibility standards are provided pursuant to extensive market research and are the most current compliant products or services available to satisfy the contract requirements.

(e) For every EIT product or service accepted under this contact by the Government that does not comply with 36 CFR 1194, the contractor shall, at the discretion of the Government, make every effort to replace or upgrade it with a compliant equivalent product or service, if commercially available and cost neutral, on either a contract specified refresh cycle for the product or service, or on a contract effective option/renewal date; whichever shall occur first.

Section 508 Compliance for Communications The Contractor shall comply with the standards, policies, and procedures below. In the event of conflicts between the referenced documents and this SOW, PWS, or TO, the SOW, PWS, or TO shall take precedence.

Rehabilitation Act, Section 508, Accessibility Standards

1. 29 U.S.C. 794d (Rehabilitation Act as amended)

2. 36 CFR 1194 (508 Standards)

3. http://www.access-board.gov/guidelines-and-standards/communications-and-it/about-the-section-508-standards/section-508-standards (508 Standards)

4. FAR 39.2 (Section 508)

5. CMS/HHS Standards, policies and procedures (Section 508)

In addition, all contract deliverables are subject to these 508 standards as applicable.

Regardless of format, all Web content or communications materials produced, including text, audio or video - must conform to applicable Section 508 standards to allow federal employees and members of the public with disabilities to access information that is comparable to information provided to persons without disabilities. All contractors (including subcontractors) or consultants responsible for preparing or posting content must comply with applicable Section 508 accessibility standards, and where applicable, those set forth in the referenced policy or standards documents above. Remediation of any materials that do not comply with the applicable provisions of 36 CFR Part 1194 as set forth in the SOW, PWS, or TO, shall be the responsibility of the contractor or consultant.

The following Section 508 provisions apply to the content or communications material identified in this SOW, PWS, or TO:

36 CFR Part 1194.21 a - l 36 CFR Part 1194.22 a - p 36 CFR Part 1194.31 a - f 36 CFR Part 1194.41 a – c

The contractor shall provide a completed Section 508 Product Assessment Template and the contractor shall state exactly how proposed EIT deliverable(s) meet or does not meet the applicable standards.

The following Section 508 provisions apply for software development material identified in this SOW, PWS, or TO:

For software development, the Contractor/Developer/Vendor shall comply with the standards, policies, and procedures below:

1. Rehabilitation Act, Section 508, Accessibility Standards

2. 29 U.S.C. 794d (Rehabilitation Act as amended

3. 36 CFR 1194 (508 Standards) 36 CFR Part 1194.21 (a – l) 36 CFR Part 1194.31 (a - f) 36 CFR Part 1194.41 (a – c)

4. http://www.access-board.gov/guidelines-and-standards/communications-and-it/about-the-section-508-standards/section-508-standards (508 Standards)

5. FAR 39.2 (Section 508)

6. CMS/HHS Standards, policies and procedures (Section 508)

a. Information Technology – General Information http://www.cms.gov/Research-Statistics-Data-and-Systems/CMS-Information-Technology/Section508/index.html?redirect=/Section-508/

For web-based applications, the Contractor shall comply with the standards, policies, and procedures below:

Rehabilitation Act, Section 508, Accessibility Standards

1. 29 U.S.C. 794d (Rehabilitation Act as amended

2. 36 CFR 1194 (508 Standards) 36 CFR Part 1194.22 (a – p) 36 CFR Part 1194.41 (a – c)

3. http://www.access-board.gov/guidelines-and-standards/communications-and-it/about-the-section-508-standards/section-508-standards (508 Standards)

4. FAR 39.2 (Section 508)

5. CMS/HHS Standards, policies and procedures (Section 508)

a. Information Technology – General Information http://www.cms.gov/Research-Statistics-Data-and-Systems/CMS-Information-Technology/Section508/index.html?redirect=/Section-508/

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