RFI_Pharmacy Benefit Manager (PBM)_A00003_Questions_ Gov Response.pdf
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Immigration and Customs Enforcement
About this file
This is a Response to RFI Questions document issued by the U.S. Department of Homeland Security (DHS) Office of the Acquisition Management regarding Detention, Compliance & Removals (DCR) pharmacy benefit management (PBM) services for ICE detainees.
The RFI is market research for an upcoming re-compete of contract 70CDCR26C00000003, which was previously awarded to Ardent in 2025. The contract will cover approximately 200 to 230 ICE detention facilities housing detainees with average lengths of stay ranging from 7 days to 30 days depending on facility type. IHSC (Immigrations and Customs Enforcement Health Services Coordinator) serves as the central point of contact and will provide daily updates of eligibility information including name, date of birth, ID number, and facility Group IDs. The anticipated contract volume is 50,000 to 80,000 claims per month with less than 30-day supply prescriptions predominating, including some mail order prescriptions. Contractors must build a pharmacy network using the current network as a baseline for development and expansion, with the use of subcontractors acceptable for some PBM services. Eligibility information will be provided daily in a specified format with current and prior year data fully migrated and all pre-FY 25 data archived.
Contractors must obtain and maintain a new Authority to Operate (ATO) issued by ICE aligned to FISMA Moderate baseline per NIST SP 800-53 Rev. 5; existing ATOs will not be accepted, though FedRAMP Moderate authorization is not required but viewed as an additional benefit. Contractors must maintain current SOC 1 and SOC 2 reports for financial controls and data security. EDI standards are required for claims processing. IHSC's Deputy Assistant Director of Clinical Services Division and pharmacy program leadership make formulary decisions. Current pharmaceutical pricing methodology is proprietary; interested parties must outline their customary pricing methods for consideration. Transfer medications are ordered for 7 to 30 days depending on medication type, with overrides available for early refill requests. Medical administrative services and PBM administration services will not be combined in the solicitation at this time.
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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 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?
IHSC serves as the central point of contact and is solely responsible for providing eligibility information. The file will include, at a minimum: Name, Date of Birth (DOB), and ID Number for each eligible individual.
Frequency of update preference: Daily
IHSC will also provide specific Group IDs corresponding to particular groups of facilities, as required.
N/A What is the estimated number of facilities that house detainees being serviced through this contract?
~230.
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.
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.
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).
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)?
Contractors must obtain and maintain a new Authority to Operate (ATO) issued by ICE; existing ATOs will not be accepted.
While a FedRAMP Moderate authorization is not required, it will be viewed as an additional benefit.
N/A Will ICE want incumbent data to be fully migrated, partially migrated, or archived?
Current year and prior year should be fully migrated. All data prior to FY 25 should be archived.
N/A What EDI standards will be required (e.g., 837/835/270/271, NCPDP for PBM)? Yes. EDI Standard will be required.
N/A
Does ICE want the contractor to build a pharmacy network or just process claims against an existing network?
Yes, contractor to build a pharmacy network, using the current network as a baseline for development and expansion.
N/A Is the use of subcontractors acceptable for some PBM services? Yes
N/A What is the anticipated volume of claims? 50,000 to 80,000 claims per month.
12 N/A What is the average days supplied? Do you anticipate that many prescriptions will be for less than a 30-day supply? Will ICE be interested in mail order prescriptions to facilities?
Less than 30 days’ supply. Some mail order prescriptions are needed.
13 N/A How has IHSC historically priced pharmaceuticals (e.g., based on AWP, WAC, or other pricing benchmarks), and does ICE intend to maintain the current pricing method?
Current pricing method is proprietary.
Interested parties should outline their customary pricing methods for ICE’s consideration.
14 N/A When a detainee is transferred to a different facility, how are medications managed and transported, if at all, during the transfer process?
Transfer medication are ordered for a minimum of 7 days up to 30 days, depending on the medication type. If a refill is requested before the standard interval, an override may be required to process the prescription.
15 N/A Does ICE have its own Medical Director/team that is responsible for formulary decisions? Is this team separate from the Medical Director/team that makes medical decisions?
IHSC has a Deputy Assistant Director Clinical Services Division. Pharmacy falls under this Division, and the pharmacy program leadership make formulary decisions.
16 N/A Would ICE consider combining the solicitation for medical administrative services and PBM administration services to optimize efficiency?
Not at this time.
17 Is this RFI for services to ICE detainees or employees of ICE and DHS?
ICE detainees
18 Would this contract if issued replace the current vendors like Clinical Solutions and the services we provide via our clients and ScriptCare?
This is market research for an upcoming re-compete of 70CDCR26C00000003.
19 Does this RFI relate to the contract issued last year, in 2025 to Ardent? Contract Award Number 70CDCR2600000003.
Yes.
20 Is there an estimate of the number of individuals this contract would cover, the number of prescriptions and locations?
The number of individuals covered under this contract varies and cannot be precisely estimated. However, the contract is expected to cover 200 to 230 locations, with an anticipated volume of 50,000 to 80,000 claims per month.
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