JA 2.23.24 final redacted.pdf

Control Number VA-23-00011367

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

1. Contracting Activity: Department of Veterans Affairs (VA) Office of Procurement, Acquisition and Logistics

Technology Acquisition Center 23 Christopher Way Eatontown, New Jersey 07724

2. Description of Action: This proposed sole source action is for a Hybrid Firm- Fixed-Price (FFP) Time and Materials (T&M) contract to be awarded to Client Network Services, Inc. (CNSI) for the operations and maintenance (O&M) support of the healthcare claims processing software, Electronic Claims Adjudication Management System (eCAMS), utilized by the Veterans Health Administration’s (VHA) Office of Community Care Non-Network Claims (CCNNC) and Financial Services Center’s (FSC) Other Government Agency (OGA) customer. The O&M will also include additional change requests to configure the software for new business lines and workflows.

3. Description of Supplies or Services: The purpose of this action is to provide O&M support for eCAMS and support to implement change requests within the eCAMS system. eCAMS is a software that adjudicates medical claims for FSC customers, including VHA and OGAs. eCAMS has been VA FSC’s medical claims software for the past three years utilized in conjunction with VA legacy systems Veterans Integrated Service Technology Architecture (VISTA) and Community Care Reimbursement System (CCRS). VA owns an unlimited enterprise perpetual license for VA use of the eCAMS software, and only requires software maintenance support, and support to customize and further enhance the current functionality. Software maintenance support includes defect resolution, technical support and installing software patches/upgrades from CNSI. VA also requires support to implement change requests to the CNSI eCAMS software. These change requests include business rule changes, code changes, integration with new VA interfaces and implementing new healthcare program offerings. VA consistently needs to apply change requests as business rules for claims processing will change as a result of changes to healthcare, legislation and VA’s workflow. Finally, this action will include an optional task for the addition of new business lines to the claims processing system such as family claims for VHA. The total estimated value for the contract is $50,000,000, which will include a 12-month base period, two 12-month option periods with both FFP and T&M line items for sustainment and one T&M optional task for adding additional business lines to the system. The FFP portion is estimated at $15,000,000 throughout the life of the contract and the T&M is estimated at $35,000,000.00.

4. Statutory Authority: The statutory authority permitting other than full and open competition is 41 U.S.C. 3304(a)(1) as implemented by the Federal Acquisition Regulation (FAR) 6.302-1 entitled, “Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.”

eCAMS Software Support Control Number VA-23-00011367

5. Rationale Supporting Use of Authority Cited Above: VA, FSC is authorized by the Government Management Reform Act of 1994 (P.L. 103-356) to provide common administrative support services on a reimbursable basis to VA and OGAs as a Franchise Fund.

VA, a constantly changing and growing agency, required a system that could implement the same innovative and progressive software development system for its stakeholders. As a result of a competitive action in 2017, CNSI licenced and implemented VA’s original eCAMS system to process community care and other healthcare claims from various business lines. Since the implementation of eCAMS, VA has added and will continue to add, business lines to this system to automate and better manage the payment and tracking of the claims that run across other business lines. VA currently has an existing software system which was originally completed to processes community care claims to include adjudication for various business lines. This software was established by CNSI as a result of the original competition and CNSI is the only vendor that can access or modify the currently fielded software for the business lines running through that software. Access to modify the software is required to add additional business lines or to complete change requests as these changes must be made directly in the proprietary CNSI eCAMS software. These configurations and changes cannot be completed by an outside source as CNSI must make any modificatins directly within its software and its software source code.

No other vendor has access to the CNSI proprietary software source code and therefore cannot implement the configurations and changes VA requires to properly manage and pay community care claims, nor could any other provider access the souce code required to modify the system to add additional business lines which would require significant custom coding support. This system is currently in use within VA, and when this software was initially established it required 25 months to fully implement 18 interfaces to VA systems. Over the course of five years, VA has also configured its system for over 400 VA specific business rules, which even if completed in parallel, would have taken an estimated 24 months. This estimate is based on historical data of approximately 17 business rule implementations completed per month. The interfaces that the eCAMS systems was initially configured with include VA Identity and Access Management (IAM), the Corporate Data Warehouse for VA medical information and data analysis purposes, and interfaces with VA’s Financial Management System (FMS) and the Integrated Financial and Acquisition Management System (iFAMS) system for payment processing purposes. Without these interfaces, the system would not be able to process VA claims or would force VA to process claims in a manner that runs afoul of fiscal laws and regulations. Due to these proprietary constraints, the use of any alternative vendor would require replacement of the entire system. Specifically, VA would need to acquire new enterprise licenses for an alternative software. The duplicative cost associated with procurement of alternative licensing is estimated to be approximately $5,000,000. This estimated cost is based on previous acquisition history. Further, eCAMS Software Support Control Number VA-23-00011367 the use of any alternative software would also require a massive redevelopment effort for VA to rebuild the interfaces with 18 other VA systems and require a reconfiguration effort to restablish the required business tools such as Microsoft Power BI for reporting purposes. CNSI has customized its commercial software solution to integrate with VA systems and to be fully compliant with all of VA’s requirements. CNSI supported and consulted on these interface builds; however, these interfaces were built utilizing VA resources external to the original contract, giving the Government intellectual property (IP) rights. Further, the customization which was done to integrate the CNSI eCAMS solution with 18 other systems, is specific to the CNSI software applications, their specific data types, data fields and communication types, which are proprietary and would not be reusable for any other solution. The underlying CNSI software framework the Government licenses was developed at CNSI’s private expense, is proprietary and the Government does not own IP rights to that commercial product. Additionally, as the interfaces were specifically designed for CNSI code and database structures, they would not be useable for any alternative system as the current interface maps data from the system to the eCAMS database. The majority of the technical work for the eCAMS interfaces is the mapping of VA system data to the CNSI database. If VA were to use another software, VA would have to completely remap all data for each interface because the the field names in the eCAMS database would not align to the field names in the alternative software.

These new interfaces would have to be rebuilt, retested and redeployed if a new software were adopted. Outside of the interfaces built for this system, CNSI also had to configure its software for the application of VA specific business rules.

There were over 400 VA specific business rules that had to be configured to the CNSI system to support the business lines processed under this system. These business rule configurations would also have to be applied to any alternative software implemented in VA’s system and would not be available “out of the box” for any other provider. This reintegration and reconfiguration effort would cost an additional estimated $50,000,000, not including the cost to acquire new perpetual licenses, and require a schedule of at least 25 months to implement based on VA’s historical experience with the previous claims software implementation as detailed above. This estimate is based on the competive action taken to establish this effort in 2017 and subsequent contract performance. Without these services, VA will not be able to successfully receive software updates and implement business lines with the CNSI claims system. This will result in less efficient and less managed payments to community care providers. Loss of this system or any loss of this critical functionality during potential transition would negatively affect VA and Veterans as payment for community would be completely compromised.

This would result in a loss of Veteran care or at minimum would result in the loss of proper reimbursement for Veteran care.

6. Efforts to Obtain Competition: Market research was conducted, details of which are in Section 8 of this justification. This effort did not yield any additional sources that can meet the Government’s requirements. There is no competition anticipated for this acquisition. Additionally, the proposed action will be synopsized on the eCAMS Software Support Control Number VA-23-00011367

Contract Opportunities Page in accordance with FAR 5.201. Any proposals that are received shall be evaluated.

7. Actions to Increase Competition: The Government continues to conduct market research to ascertain if there are changes in the marketplace that would enable future actions to be competed.

8. Market Research: In August 2022, Market Research was conducted via a sources-sought Request For Information (RFI) and CNSI was the only vendor to respond. In their response, CNSI provided a letter that stated they do not have any authorized resellers or service providers as they do not authorize anyone outside of CNSI to work on their software.

Additionally, in August 2022, VA technical experts conducted additional web-based market research to review alternative similar software solutions. Specifically, VA technical experts reviewed the websites of Plexis Healthcare Systems, Inc. and Cognizant. After review, VA technical experts concluded that although these vendors could provide similar claims processing software, they do not have access to CNSI proprietary code required to maintain or change CNSI software, nor do they have the ability to replace the CNSI system without a total rebuild of VA’s current interfaces.

Additionally, these offerors could not support additional business lines and could not support changes to business rules as these services are required to be changed within the CNSI proprietary system as no other system has interfaces with VA required systems such as the IAM, FMS or VA Single Sign-On. Research found that there are vendors that provide similar services, yet no alternative vendor has access to CNSI proprietary source code and therefore could not complete the required software changes and configurations required under this effort or avoid the duplicative cost and time as outlined in Section 5 of this justification. Additionally, review of the websites for the alternative software suites did not indicate that configuring, or integrating the reviewed software would be any more streamlined or efficient than the current system. Therefore, it is confirmed that there is no expectation of competition with the awarenenss that the only provider of the proprietary source code is CNSI and their confirmation that they do not resell their services.

9. Other Facts: None.

eCAMS Software Support Control Number VA-23-00011367

10. Technical and Requirements Certification: I certify that the supporting data under my cognizance, which are included in this justification, are accurate and complete to the best of my knowledge and belief.

cccccccccccccccccc Stephen L. Spurlin Date: ________________________________ cccccccccccccccccccccccccc Supervisory Financial Signature: ____________________________ Management Specialist

11. Fair and Reasonable Cost Determination: I hereby determine that the anticipated price to the Government for this contract action will be fair and reasonable based on comparison with prices previously found fair and reasonable.

cccccccccccccccccc Matthew Newell Date: ________________________________ CCCCCCCCCCCCcccccccc Procuring Contracting Officer Signature: ____________________________

12. Procuring Contracting Officer Certification: I certify that this justification is accurate and complete to the best of my knowledge and belief.

CCCCCCCCCCCCCCCCCCCCCCCCc

Matthew Newell Date: ________________________________ CCCCCCCCCCCCCCCCCCCcc Procuring Contracting Officer Signature: _CCCCCCCCCCCCCCCCCCCcc eCAMS Software Support Control Number VA-23-00011367

Approval

In my role as Head of the Contracting Activity, based on the foregoing justification, I hereby approve the acquisition of the Hybrid FFP/T+M contract to be awarded to CNSI on an other than full and open competition basis pursuant to the statutory authority cited in Section 4 above, subject to availability of funds and provided that the property and services herein described have otherwise been authorized for acquisition.

3/14/2023 Michelle Digital Signture Date: __________ Signature: Foster ______3/14/2023_____ Michele R. Foster

Head of the Contracting Activity Technology Acquisition Center Office of Procurement, Acquisition and Logistics