ICC SSN 220374.docx

Centers for Medicare & Medicaid Services (CMS) Independent Coding Consultant (ICC) Sources Sought Notice (SSN) 220374

THIS IS NOT A REQUEST FOR PROPOSAL or SOLICITATION AND DOES NOT COMMIT CMS TO AWARD A CONTRACT NOW OR IN THE FUTURE

Introduction:

The Centers for Medicare & Medicaid Services (CMS) is hereby conducting market research to identify 8(a) small businesses to support informed decisions to procure an Independent Coding Consultant (ICC) for their services to support CMS, and specifically the Center for Program Integrity (CPI), in its Medicare Risk Adjustment Data Validation (RADV) program. This notice is a Sources Sought Notice (SSN) for all interested qualified businesses that meet the requirements for this effort. The information from this market research will help CMS plan their acquisition strategy.

Contractors must be free of conflicts of interest or be able to prepare an Organizational Conflict of Interest (OCI) mitigation plan to address any actual, potential, or apparent organizational conflicts of interest that could arise.

Contractors must be registered in the System for Award Management (SAM) database located at https://www.sam.gov/SAM/ prior to award, during performance, and through final payment of any contract resulting from this Notice. Contractors may obtain information on SAM registration by visiting: https://www.acquisition.gov.

This announcement is a SSN for planning purposes only. This is not an invitation for bid, request for quote or other solicitation and in no way obligates the Government to award a contract. CMS will not entertain questions regarding this market research.

Background:

CMS conducts RADV audits using Medical Record Reviews (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.

Overview of the requirements

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 Medical Record Review Contractors (MRRCs), and develop written communication, guidance and briefing materials to clarify the RADV and MRR process.

The CMS seeks to acquire an ICC Contractor to:

1. Provide expert coding support for medical record reviews for the Medicare RADV program.

2. Provide training for the RADV MRRCs.

3. Develop written communication, guidance, and briefing materials to clarify the RADV and MRR process.

See the attached Draft Statement of Work (SOW) for additional information on all anticipated requirements.

Instructions for Responding:

To respond to this notice, contractors must be able to indicate knowledge, expertise and experience in all of the numbered points below. Reference the Draft SOW for definitions and clarification of terms. Give enough detail so your response clearly indicates knowledge, expertise and experience with SOW requirements, including:

1. Knowledge and application of the International Classification of Diseases, Clinical Modification (i.e., ICD-9/10 coding) for medical record review

2. Knowledge of and experience using AHA Coding Clinic as source of information for accurate ICD-9/10 coding;

3. At least five years of experience as a medical record reviewer with the capacity to resolve escalated coding cases.

Interested 8(a) small businesses having the capabilities necessary to perform the requirements may submit capability statements. Please address each requirement outlined above in order listed under “Capability Statement Information.” CMS will take all information received under consideration when finalizing the strategy for procuring services for the ICC.

Respondents shall also submit the following business information in their response:

1. DUNS Number

2. Company Name

3. Company Address

4. Company Point of Contact, phone number and email address

5. Type of company under NAICS 541219 Medical coding services; Size Standard $22.0 million as validated via the System for Award Management (SAM). Additional information on NAICS codes can be found at www.sba.gov.

6. Corporate structure (e.g. corporation, LLC, sole proprietorship, partnership, limited liability partnership, professional corporation, etc.).

7. Do you have a Government approved accounting system? If so, please identify the Agency that approved the system.

8. Current contracting vehicles appropriate to this Sources Sought the company is part of that is applicable and relevant.

9. Point of Contact, phone number and email addresses of at least two individuals who can verify the demonstrated capabilities identified in the responses.

Teaming Arrangements: All teaming arrangements shall also include the above-cited information and certifications for each entity on the proposed team. Specifically, the capability statement must address how much effort would be performed by any proposed team member. Note that any resulting small business set aside would require that at least 50% of the cost of contract performance for personnel be expended for employees of the concern (see FAR 52.219-14, Limitations on Subcontracting).

Submission Requirements:

All capability statements shall be submitted via email to the point of contact listed below. The title of the email shall read “Response to ICC SSN 220374.” Responses must be submitted no later than 9:00am, local time, Baltimore, MD, XXXXXXXX, 2021. Responses shall be limited to 10 single-sided pages, not including the required business information and cover page. Pages should be single-spaced, minimum 11 point Times New Roman font with a minimum of one inch margins on all sides.

Responses should be sent electronically to Megan Anuszewski, Contract Specialist, at Megan.Anuszewski@cms.hhs.gov with a courtesy copy to David Hochendoner, Contracting Officer, at David.Hochendoner@cms.hhs.gov.

Disclaimer and Important Notes:

This notice does not obligate the Government to award a contract or otherwise pay for the information provided in response. The Government reserves the right to use information provided by respondents for any purpose deemed necessary and legally appropriate. Any organization responding to this notice should ensure that its response is complete and sufficiently detailed to allow the Government to determine the organization’s qualifications to perform the work. Respondents are advised that the Government is under no obligation to acknowledge receipt of the information received or provide feedback to respondents with respect to any information submitted. No reimbursement will be made for any costs associated with providing information in response to this Notice. Respondents will not be notified of the results of this evaluation.

After a review of the responses received, a pre-solicitation synopsis or a solicitation may be published on beta.SAM.gov. However, responses to this notice will not be considered adequate responses to any solicitation CMS may choose to issue.

Confidentiality:

No proprietary, classified, confidential, or sensitive information should be included in your response. The Government reserves the right to use any non-proprietary technical information in any resultant solicitation(s).

Protection of Privileged or Confidential Commercial or Financial Information

The Freedom of Information Act (FOIA), 5 U.S.C. § 552, provides individuals with a right to access certain records in the possession of the Federal government, subject to certain exemptions. Exemption 4 of the FOIA permits information to be withheld that is in the nature of "trade secrets and commercial or financial information obtained from a person and privileged or confidential." The term "person" refers to a wide range of entities, including corporations, banks, state governments, agencies of foreign governments, and Native American tribes or nations, who provide information to the government. Information that does not qualify withholding under the Exemption will be disclosed.

CMS may invoke Executive Order 12600 in accordance with FOIA Regulation 45 C.F.R. § 5.42. Information provided by entities to CMS in response to this notice may be subject to FOIA disclosure requirements unless protected under Exemption 4 of the Freedom of Information Act. Should entities wish to protect any trade secret or confidential information under Exemption 4, they should mark their submission accordingly citing applicable redactions and non-disclosure rationale. Pre-disclosure redactions and non-disclosure rationale shall be sent via e-mail to the requesting contracting officer with a copy to the CMS FOIA Office at 12600@cms.hhs.gov.

If an entity’s submission is not marked and CMS receives a FOIA request related to this notice, the CMS Contracting Officer will notify the entity. The entity will have 10 working days to object to the release of any part of their information submitted to CMS citing relevant case law. Final determination on the applicability of Exemption 4 of the FOIA are made on a case-by-case basis by CMS.

The statutory language of the FOIA is codified at 5 U.S.C. § 552(b). Additional information and resources, including the 9 FOIA Exemptions and HHS FOIA Regulation, and examples, can be found on the HHS FOIA Website.

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