IPC JA Limited Source Justification.pdf

FEDERAL SUPPLY SCHEDULE LIMITED-SOURCES JUSTIFICATION

Acquisition Title: The Innovation Payment Contractor (IPC) Agency: CMS/CMMI Acquisition Year: FY2021 Author: Alyssa Larson, COR

2. Description of Action:

Nature

• ____ New Requirement

• _X__ Follow-On Order

• ____ Modification of Existing Purchase Order / Contract Number

Contract Type

• _X___ Firm-Fixed Price

• _X__ Time and Materials

• ____ Cost Plus Fixed Fee (CPFF)

• ____ Term

• ____ Completion

• ____ Cost Plus Award Fee (CPAF)

• ____ Other: ___________

Projected Cost / Price: Base Year - $5,521,400 Option Period 1 - $4,944,500 Optional Transition Period - $150,000

Funding Source (s):

CPC+ - Project # 7776 CJR – Project # 7727 NGACO (Provider) – Project #7771 OCM – Project #7764 CEC – Project #7752 DC– Project #7648 KCC – Project#7649 VAPM – Project #7782- QPP/MACRA 101 - Program Analysis (PAC) –Project # 013070 PCF – Project #7776 MDTCOC – Project # 7632 Information Systems & Business Requirements IT –Project #7899 Operation Management Non IT – Project #7750

Name of Proposed Contractor(s): National Government Services Street Address: 8115 Knue Road City, State, Zip: Indianapolis, IN 46250

3. Description of Supplies or Services:

The estimated value of the proposed action, including all options, is $10,615,900

The Centers for Medicare & Medicaid Services (CMS)/Centers for Medicare and Medicaid Innovation (CMMI) require an Innovation Payment Contractor (IPC) to assist CMMI in making payments to eligible participants in multiple model tests and initiatives. For each supported Model, the IPC conducts the following financial services activities:

• Disburse Electronic Funds Transfer (EFT) payments to eligible Medicare, Non-Medicare, and Medicaid providers and beneficiaries.

• Apply Federal Payment Levy Program (FPLP) withholding for each payee in accordance with U.S.

Department of Treasury requirements.

• Issue demand letters, conduct collection activities, and report on receivables.

• Process debt referrals to the Treasury.

• Manage/monitor Extended Repayment Schedule.

• Make adjustments to payments including accounts payable/receivable netting as required.

• Manage a single bank account for all models that make EFT payments.

• Send IRS 1099s annually to all payees.

• Provide proper funds control, oversight, and compliance with all applicable laws, regulations, Federal

Accounting Standards, Generally Accepted Accounting Principles, CMS Office of Financial Management (OFM) guidelines and reporting requirements and CMS Internet Only Manual (IOM)/Medicare Financial Management Manual, Chapters 3-7.

4. Authority:

__X__:ORDER AGAINST FSS: Authority of the Multiple Award Schedule Program, Title III of the Federal Property and Administrative Services Act of 1949 (41 U.S.C. 251, et seq.); Title 40 U.S.C. 501, Services for Executive Agencies; and Section 803 of the National Defense Authorization Act of 2002 (PL 107-107) and implemented by FAR 8.405-6. Mark the applicable exception and for each discuss how the cited authority applies in accordance with FAR 8.405-6(c)(2)(iv).

____: An urgent and compelling need exists, and following the procedures would result in unacceptable delays (FAR 8.405-6(a)(1)(i)(A));

____: Only one source is capable of providing the supplies or services required at the level or quality required because the supplies or services are unique or highly specialized (FAR 8.405-6(a)(i)(B)); or

_X__: In the interest of economy and efficiency, the new work is a logical follow-on to an original Federal Supply Schedule order provided that the original order was placed in accordance with the applicable Federal Supply Schedule ordering procedures. The original order or BPA must not have been previously issued under sole-source or limited sources procedures (FAR 8.405-6(a)(1)(i)(C)); or

CMS is requesting a one-time exception to fair opportunity. The incumbent contractor, National Government Services (NGS), Contract #GS-35F-0674T /HHSM-500-2016-000116G, was a competitive award made under the GSA schedule. The period of performance was a 12-month base period with four 12-month option periods from September 26, 2016 through September 25, https://www.acquisition.gov/sites/default/files/current/far/html/Subpart%208_4.html

2021. As part of the five year award, CMMI intended the IPC would be integrated with CMS’ general accounting system, HIGLAS, but due to work load capacity issues on the OFM contract, the component responsible for HIGLAS, work was delayed. Because OFM could not begin the work until June 2020, the IPC HIGLAS integration cannot be completed during the original IPC period of performance with NGS. As CMMI expected HIGLAS integration would be completed as part of the original SOW, it is vital the contractor be allowed to complete the work or the government will be at high risk of the integration being delayed and potentially unable to process CMMI payments timely to Model Participants.

IPC Integration with HIGLAS is a 14 month special project between CMMI and OFM. This transition will enable CMMI’s IPC to submit and record all model accounts payable/accounts receivable transactions into HIGLAS. A one-time cutover conversion from the IPC’s current Deltek Costpoint accounting system to HIGLAS is planned after which the IPC will process all model transactions exclusively in HIGLAS. The HIGLAS Integration will provide automated tracking and reporting of cash balances by CMMI model by Fiscal Year by funding category. The Go-Live date for this integration is scheduled for November 2021, which is two months after the IPC’s final option year ends. Onboarding a new contractor at that time would impose unnecessary risk to the government and jeopardize payments to CMMI Model Participants in terms of potential schedule delays, disruption of technical performance and payment failures.

Maintaining the current IPC contractor for an additional year will maximize the probability the HIGLAS integration is successful, is completed on schedule, and without any disruptions to Model Participant payments. It will also allow the government to leverage the subject matter expertise of the existing contractor staff in building model-specific reports to supplement the “MAC-centric” HIGLAS, a task included in the Logical Follow-On award. Attempting to re-compete the contract at this most vulnerable period of HIGLAS integration and deployment will risk the loss of critical programmatic knowledge and efficiencies gained throughout the initial five years of the contract.

NGS has spent the last five years learning the intricacies of CMMI’s business needs and successfully providing technical assistance and program support to CMMI Models. They have developed business and program processes and collaborated with internal stakeholders and other CMS contractors to meet CMMI’s programmatic objectives and address model-specific designs.

Bringing in another contractor will require a transition period of at least three months which would jeopardize the HIGLAS integration timeline agreed on with OFM. The learning curve associated with a new contactor will introduce inefficiencies, expose the government to unnecessary risk, and create avoidable schedule delays. For these reasons, it is critical NGS complete this work.

____: An item peculiar to one manufacturer can be a particular brand name, product, or a feature of a product, peculiar to one manufacturer). A brand name item, whether available on one or more schedule contracts, is an item peculiar to one manufacturer. (FAR 8.405-6(b);

5. Market Research:

Market Research is not needed since this is a logical follow-on.

6. Actions to Increase Competition:

https://www.acquisition.gov/sites/default/files/current/far/html/Subpart%208_4.html

The period of performance for this effort is one 12-month base year, one 12-month option year, and an optional three-month transition period. Any future need to continue services related to IPC support beyond this limited 27-month period will be procured through competitive means.

7. Any other facts supporting the justification:

NGS is also working on several other developmental tasks which will not be completed by the end of the current contract year and will need to be completed during the Logical Follow-On award:

• IPC Portal, Version 3: Build and deployment for 3rd of 3 “stage” application, which eliminates need for Model Teams to collect Medicare 588 Forms (automating collection of bank account information), provides Participants with Payment and Overpayment summary information (with links to Remittance Advice and Demand Letters), and comprehensive self-service reporting for Model Teams.

• Migrating IPC code and applications to CMS AWS-environment (planned for March 2022.)

• Ensuring linkage to OC-funded, NGS-designed Next Generation Desktop application (an innovation developed by NGS to access bank account information for Model Participants and other Medicare Shared Systems data mining, CMMI’s need for such data will continue after the Logical Follow-On award ends.)

Additionally, CMMI will use the Logical Follow-On period to ensure the transfer of knowledge and complete documentation of the best practices and efficiencies developed by the IPC in working with CMMI Model Teams and Participants since inception of the IPC program. This will improve the CMMI’s IPC Program’s ability to facilitate a smooth transition and uninterrupted support of CMMI’s operational needs regarding non-claims based payments.

Onboarding a new contractor to simply complete the final pieces of the current work being performed by NGS would impose unnecessary and burdensome schedule delays and unnecessary costs stemming from a transition period between contractors.

NGS has spent the past five years learning the IPC business workflows and developing business relationships with the key CMS entities. NGS is the only contractor currently equipped to seamlessly continue the work under this contract without a disruption to schedule or performance.

Approvals:

1. Program Office Certification: This is to certify that portions of this justification have been developed by the undersigned program office personnel, including supporting information and/or data verifying the Government’s minimum needs, schedule requirements and other rationale, which form the basis for this Limited Source Justification.

Contracting Officer Representative (COR) / Date

Program/Project Manager (P/PM) / Date

Best Value Determination. By my signature below, after review of the relevant documents, I have determined that the order subject to this Limited-Sources Justification represents the best value for the Government as set forth in FAR 8.404(d), and constitutes a fair and reasonable price. The basis for my determination is as follows:

Based upon our knowledge of the vendor community capable of meeting this requirement and the existing capabilities of the incumbent contractor currently performing this work, a determination has been made to request a sole source contract with the previous contractor, National Government Services.

Additionally, the complexity of this effort, the critical nature of the IPC work, and the time constraints existing to accomplish this procurement were all taken into consideration prior to making this determination. As a result, the services described above will be procured through a FAR Part 8.4 procurement under NGS’ GSA Schedule task order.

The previous NGS GSA Schedule task order was awarded using fair opportunity competition. NGS was awarded the original GSA Schedule based on competition among all GSA vendors selected. All offers were evaluated and a determination was made that NGS offered the best value to the Government at a price that was both fair and reasonable. The estimated value of this task order is based upon the existing pricing and in line with the labor mix and hours currently required to complete the requirements of the existing body of work.

The Government will request NGS submit a proposal based upon the scope of work of the follow on GSA Schedule and the COR along with the CO and CS will review and confirm that the costs are fair and reasonable.

This sole source contract will be awarded to NGS as a GSA Schedule task order.

2. Contracting Officer Certification: This is to certify that the justification for the proposed acquisition has been reviewed and that to the best of my knowledge and belief, the information and/or data provided to support the rationale and recommendation for approval, is accurate and complete.

Contracting Officer / Date

OAGM Approvals I hereby confirm the circumstances described above apply and approve the Limited Source Justification.

OAGM Division Director / Date

OAGM Group Director / Date

3. Head of Contracting Authority (HCA) Approval

I hereby confirm the circumstances described above apply and approve the Limited Source Justification.

HCA Name / Date

4. CMS Competition Advocate (CA) Approval I hereby confirm the circumstances described above apply and approve the Limited Source Justification.

N/A

Name / Date

5. Senior Procurement Executive (SPE) Approval Based on the foregoing justification, I hereby approve the procurement of (state supplies/services being procured) on an other than full and open competition basis pursuant to the authority of (state the full statutory authority and FAR cite and title, consistent with paragraph 4, e.g. 41 U.S.C. 253(c)(1)), as implemented by FAR 6.302-1), subject to the availability of funds, and provided that the services herein described have otherwise been authorized for acquisition.

N/A

Name / Date