RFI_Questions_ Gov Response_Medical Claims.pdf

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This document is a Response to RFI (Request for Information) Questions issued by the U.S. Department of Homeland Security (DHS), Office of Acquisition Management, Detention, Compliance & Removals (DCR) division, located at 500 12th Street SW, Washington, D.C. 20024.

The RFI addresses requirements for a Third-Party Administrator (TPA) to manage medical and dental claims processing for illegal aliens (detainees) in ICE and CBP custody. Key requirements include: claims adjudication systems compliant with HIPAA, NIST SP 800-53 controls, and FIPS 140-3 validated cryptographic modules; system integration capabilities with EHR/EMR systems, clearinghouses (such as Availity or PNT), and government custody systems via SFTP; provider credentialing, enrollment, and network management; and support for EDI standards 835 and 837, HL7, FHIR, X12, and NCPDP data exchange protocols. The government does not require FedRAMP authorization but prefers it. ICE will require contractor systems to meet FISMA Moderate baseline aligned to NIST SP 800-53 Rev. 5 and will conduct internal assessment for Authority to Operate (ATO) determination. The TPA must maintain current SOC 1 and SOC 2 reports and perform full data migration of approximately 500GB from the incumbent vendor, including claims, payments, authorizations, member profiles, provider records, reference data sets, fee schedules, and configurations.

The contract scope covers approximately 266 ICE authorized facilities and 328 CBP ports of entry, with detainee average length of stay ranging from 7 to 30 days depending on facility type. Payment is limited to Medicare reimbursement rates with a 2% reduction per the Budget Control Act of 2011; dental procedures reimburse at 90% of usual and customary rates. Top claim categories include X-rays, emergency department visits, mental health, ambulance/transport, and respiratory infections, with dental claims representing approximately 1.85% of total paid claims. The government will provide daily custody and authorization files in Microsoft Excel and text formats, along with preauthorization business rules. Currently, 100% of claims are submitted electronically. Subcontractors are acceptable, and the government may consider combining medical administrative services and pharmacy benefit management (PBM) administration if demonstrated to be in the government's best interest.

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U.S. Department of Homeland Security (DHS) Office of the Acquisition Management (OAQ) Detention, Compliance & Removals (DCR)

500 12th St. SW, Washington, D.C. 20024

RESPONSE TO RFI QUESTIONS

Reference Question Government Response 1 N/A Our leadership is wondering if there will be an opportunity for an Industry Day or One-on-One type engagement to better understand the requirements and current challenges.

The government may schedule an industry day or one-on-one engagements in the future.

2 “Describe your claims processing technology that can adjudicate medical and dental claims submitted from community providers (emerging technologies) including the system’s functionality, compliance with federal standards”

Can you list these “federal standards”?

The system would need to be compliant with HIPAA, Implementation and documentation of NIST SP 800‑53 controls, following NIST SP 800‑37 and related guidance, and use of FIPS 140‑3 validated cryptographic modules.

3 “Do you have a contract with a specific clearing house for clean claim clearance or rejects prior to submission and processing in your claims adjudication system?”

When referring to a "clearing house” are you suggesting a third party EDI clearinghouse (such as Availity)?

The government does not have a contract with any clearinghouse. The third-party administrator would need to contract with a third-party clearinghouse such as Availity, PNT, etc.

4 Can your system integrate with other government systems, such as electronic health record (EHR or

EMR)?

Can you clarify “integrate”? Is this a direct, seamless connection with the EHR/EMR system or is it the ability to exchange data bidirectionally (like through scheduled, secure file transfers)?

The term is general. Describe any capability for data connectivity, interoperability, application programming interface, HL7, etc. with push, pull or bidirectional function.

5 What interoperability standards (e.g. HL7, FEDRAMP) does your system support?

Do you anticipate the FedRAMP authorization being a non-negotiable requirement?

FedRAMP authorization is not a non-negotiable requirement but it is preferred.

Do you have the current ability to manage a full-scale provider network to include credentialing, enrollment, and maintenance?

Is bidding with a network partner who performs credentialing sufficient for this requirement or will the TPA be required to coordinate and manage the provider credentialing process?

It is the government’s expectation that the TPA will have a mechanism to perform credentialing services, whether through bidding with a network partner or independently coordinating and managing the provider credentialing process.

N/A Does this RFI apply to the claims for detainees, agents, or both?

RFI is only applicable to illegal aliens (detainees) in ICE/CBP custody.

N/A

Will the Department of Homeland Security provide eligibility information for the patients who’s claims are being processed?

By law, eligibility is determined by being in custody. Custody files are provided by the government.

N/A Will there be any type of accumulators expected for a cap adjustment or otherwise?

Authorized payments and issued reimbursement for health care services rendered while in custody, is in accordance with Title 18, Part III, Chapter 301, Section 4006 of the U.S. code, which must not exceed Medicare reimbursement rates.

All payments will incorporate a two percent reduction in accordance with the Budget Control Act of 2011.

Approved Dental procedure(s) standard reimbursement rate is 90% of usual and customary rate (URC). Dental Codes that are not covered by UCR, must be approved prior to services rendered.

The Medicare Fee Schedule Rate (MFSR) is used to reimburse physician services, ambulance services, clinical laboratory services, and durable medical equipment.

N/A Will preauthorization lists be provided?

The government will provide business rules that specify whether processing requires preauthorization or auto approved process.

N/A Will the Department of Homeland Security enable the TPA to verify pre-authorizations in real-time (when needed)?

This is the goal with use of modern technology Application Programming Interface, interoperability, etc.

12 N/A How is eligibility information provided?

Who is responsible for providing the information (e.g., ICE national office, regional offices, and/or separate facilities)?

What is the frequency of eligibility updates?

What format will the eligibility information be provided?

Daily custody and authorization files are provided by the government. Custody eligibility and authorization of a referral or per preauthorization/auto-approved business rules collectively with provider enrollment drive financial reimbursement requirements.

The authorization files are provided in Microsoft Excel format. Each file contains detainee identifiers and demographic information, facility details, unique authorization numbers, and other relevant data, including referral dates, diagnoses, and CPT codes. Custody chain and facility information files are provided in text format.

These files confirm the custody dates and facility information for detainees. Facility files provide an up-to-date list of ICE facilities and their associated information.

13 N/A What is the estimated number of facilities that house detainees being serviced through this contract?

Number of facilities and average daily population can and does fluctuate according to the current administration mission. As of June 18, 2026, ICE had 266 authorized facilities. Additionally, CBP’s Office of Field Operations manages 328 ports of entry in total — including the 167 land ports plus other entry points such as seaports, airports, and certain inland facilities where illegal aliens may be apprehended and need specialty medical care.

14 N/A What is the average length of stay or duration of detainment?

The average length of stay for detainees varies by facility. Some facilities average approximately 7 days, while others may average between 14 and up to 30 days. Actual duration depends on facility type and operational factors.

15 N/A Is ICE planning to require URAC accreditation to ensure high-quality operations and compliance?

IHSC has no plans at this time for URAC accreditation but may change in the future

16 N/A Does ICE anticipate requiring the contractor to maintain current SOC 1 and SOC 2 reports to ensure adequate controls over claims processing, financial reporting, and information security?

Yes. SOC 1 focuses on financial controls (e.g., claims accuracy, payment processing) and SOC 2 focuses on data protection and operational controls (e.g., data security, privacy).

17 N/A Does ICE anticipate requiring contractor systems to meet a FISMA Moderate baseline aligned to NIST SP 800-53 Rev. 5, including obtaining and maintaining an Authority to Operate (ATO) or equivalent authorization? Will ICE sponsor the ATO, or can the contractor bring an existing ATO?

Will a different security baseline be required (e.g., FedRAMP Moderate)?

ICE will require the contractor systems to meet a FISMA Moderate baseline aligned to NIST SP 800-53 Rev. 5. ICE will process an internal assessment to determine if the system can obtain an Authority to Operate (ATO) or equivalent authorization.

18 N/A Will ICE want incumbent data (e.g., claims, provider, or member data) to be fully migrated, partially migrated, or archived? If so, are there defined data formats, volumes, or transition constraints?

ICE requires a full data import and migration from the incumbent vendor (roughly 500gb). The migration must include all relevant data sets, specifically:

Claims: All historical and current claims records, including supporting documentation and metadata.

Payments: Complete payment records associated with claims, providers, and members.

Authorization: All authorization records, including approvals, denials, and supporting documentation.

Member: Comprehensive member profiles and related enrollment, eligibility, and transactional history.

Provider: Complete provider profiles, credentialing information, and associated records.

Reference Data Sets: All supporting reference tables and datasets, inclusive of the subscribed referential data necessary to maintain data integrity and relationships.

Fee Schedule: All fee schedules, rate tables, and associated pricing information.

Configuration: All system configuration settings, parameters, and customizations relevant to the operation and integration of the data.

The migration should ensure data accuracy, completeness, and preservation of all relationships between datasets. ICE expects full cooperation from the incumbent vendor to facilitate a seamless and secure transition.

19 N/A Does ICE anticipate establishing requirements or restrictions governing the use of AI/ML within contractor systems, particularly with respect to handling sensitive data (e.g., PHI/PII), data retention, model training, or use of external AI services?

ICE has no plans to use AI in the system at this time.

20 N/A What EDI standards will be required (e.g., 837/835/270/271, NCPDP for PBM)? Will the current EDI identifier be transferred or would a new EDI identifier be required?

EDI standards 835, 837.

21 N/A What external systems (e.g., EHR/EMR, financial systems, custody systems) will the contractor be required to integrate with?

Vendor’s clearinghouse, pricing software or licenses required for industry claim adjudication, financial reconciliation/banking systems, vendor’s provider portal/provider enrollment system, and an SFTP for government custody and authorization data and to share claims/provider data owned by the government.

22 N/A Are specific interoperability standards (e.g., HL7, FHIR) required or will integration approaches be determined collaboratively?

Yes, support for the interoperability standards such as HL7, FHIR, X12, NCPDP, and other industry-standard data exchange protocols

23 N/A Does ICE want the contractor to contract with providers to build a provider network or just process claims against an existing network?

In the short term, the vendor will process claims for the government’s existing provider network.

However, the government is also interested in exploring the possibility of the contractor developing the provider network.

24 N/A Is the use of subcontractors acceptable for some of the services?

Yes.

25 N/A How are authorization referrals and custody data shared currently? What is the desired process for the future contract?

Currently the information is placed by the government on an SFTP server for transmission to vendor.

26 N/A In terms of ‘auto approval for emergency department claims’, is the intent simply that ED services do not require prior authorization, or are there additional adjudication requirements or exceptions ICE expects to be applied?

Emergency services do not require preauthorization for care but do require an authorization number from a generated referral that is generated retrospectively not to delay care.

27 N/A What is the average monthly spend on services to be included in this contract?

How are claims currently invoiced and paid? What are the current invoicing and payment timelines? How would ICE prefer the contractor to pay claims and be paid for the future contract?

The average monthly expenditure fluctuates based on the volume of claims submitted, adjudicated, processed, and reimbursed. Claims are currently electronically submitted to the Veteran’s Affairs Financing Services portal, will continue to be submitted by the selected vendors system. Invoicing will adhere to Invoice instructions provided by the government. The contractor will comply with the payment parameters established by the Government’s Business Rules.

28 N/A What are the top five categories of claims by place of service?

Paid claims for ICE from Date of Service (DOS) FY21-25, the top 5 categories of claims are related to: X-Rays, Emergency Department Visits, Mental Health, Ambulance/Transport, Covid/Respiratory Infection.

29 N/A What percentage of current claims are dental services?

Paid claims data for ICE across Date of Service (DOS) FY21-25, Dental Claims are approximately 1.85% of Total Paid Claims.

30 N/A Will behavioral health services be included in the scope of the services required in the future contract? Will telehealth be desired to be included?

Inpatient behavioral health providers are expected to be in the IHSC provider network.

Specific behavioral health telehealth is not a current requirement.

31 N/A Will phone interpreter services be included in the scope of services required in the future contract?

Not in the scope or expectation of this contract though community providers should have access to provide interpretive services accordingly.

32 N/A What percentage of total claims volume are submitted on paper?

None currently.

33 N/A Would ICE consider combining the solicitation for medical administrative services and PBM administration services to optimize efficiency?

ICE may consider combining if it is determined to be in the best interest of the government.

Respondents are encouraged to outline efficiencies and benefits of combining this support.

File details come from the government source that posted it. Updated .