JA 3M GPCS post.pdf

3M Grouper Plus Content System Software and Maintenance Support

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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: The proposed sole source action is for a firm-fixed price contract for a brand name enterprise 3M Grouper Plus Content System (GPCS) Claims Software-as-a-Service (SaaS) subscription with 3M Company (3M), 3M Center, Building 220, Saint Paul, Minnesota, 55144.

3. Description of the Supplies or Services: VA Financial Services Center (FSC) and Veterans Health Administration (VHA) have a requirement for an enterprise 3M GPCS SaaS solution in order to automate its healthcare claims pricing methodologies. VA FSC requires the 3M GPCS solution to continue to integrate with the existing medical claims processing system, the electronic Claims Administration and Management System (eCAMS) Health Care Engine (HCE). eCAMS HCE is a centralized and configurable healthcare claims processing platform that supports VA claims processing business functions, including pricing methodologies, and is capable of adjudicating, processing, and preparing payment of claims by healthcare providers. The eCAMS HCE platform supports a minimum of 85 percent of all claims transactions as auto-adjudicated with straight through processing, with no human touch points or human interaction.

The 3M GPCS solution enables automated pricing methodologies within the eCAMS solution. The 3M GPCS consists of various grouper and pricer functionalities which group healthcare claims by reading its diagnosis code, grouping it by code into high level functional areas, and calculating the associated price based on the claim and medical data. This enables eCAMS to adjudicate the claim and send bills to the VHA or non-VHA providers who will then administer as appropriate. These groupers and associated pricer functionalities provide Medicare and non-Medicare procedure grouping, editing, and assignment of reimbursement costs for inpatient and outpatient medical claims data ensuring accurate reimbursements are paid to the VHA and non- VHA health care medical claims in support of the Veterans Access to Care through Choice, Accountability, and Transparency Act of 2014 (H.R.4810; 113th Congress;

Public Law (PL) 113-175). PL 113-175 requires VA to establish and implement a system to process and pay claims for care delivered to Veterans by non-VA providers under the program and other non-VA care authorities. The Veterans Access to Care through Choice, Accountability, and Transparency Act of 2014 has significantly increased the number and types of medical claims received each year from VHA and non-VHA healthcare providers. In order to remain in compliance with the Veterans Access to Care through Choice, Accountability, and Transparency Act of 2014, the VA FCS requires seven (7) additional 3M groupers with associated pricers for eCAMS medical claim automation functionalities: Hospital Outpatient Department (HOPD), VA-23-00044524

Ambulatory Surgical Center (ASC), Center for Medicare and Medicaid Services (CMS), Inpatient Psychiatric (IPF), Long Term Care Hospitals (LTCH), Inpatient Rehab, Medicare Renal Dialysis Editing and Reimbursement (RDF), and Professional Claims Editor and Reimbursement (PCER).

The 3M GPCS software as a service solution shall allow the VA FSC to send specific claim information (non-identifying data) to the service and the service will return a price for eCAMS to adjudicate the claim. In addition, the Contractor shall provide maintenance support services. Specifically, these maintenance support services include software upgrades, updates, enhancements, and corrections within five (5) business days of being released by the contractor. The Contractor shall also provide remote and telephonic technical support 24 hours a day, seven (7) days a week. The period of performance for the software as a service solution shall be 12 months from delivery with two (2) 12-month option periods. Option periods are required to continue to provide healthcare medical claims and reimbursement services eCAMS HCE processing solution.

4. 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) Subpart 6.302-1 entitled, “Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.”

5. Rationale Supporting Use of Authority Cited Above: The proposed source for this action is 3M. Based on market research, as described in Section 8 of this justification, it was determined that only 3M GPCS solution can meet the Government’s requirements.

Only the 3M GPCS solution is interoperable with the eCAMS HCE system. The eCAMS HCE solution is designed to integrate only with the 3M GPCS proprietary source code.

The eCAMS HCE solution was specifically designed and extensively tested to ensure its production rates provide a solution that meets the Government requirements including the requirement to auto-adjudicate 85 percent of claims transactions with straight through processing and no human touch points or human interactions. The use of another brand would require the Government to not only redesign its eCAMS HCE solution, but also require redevelopment of an interface with any alternative software solution. Based on previous acquisition history and historical Government data, VA technical experts estimate that such a redevelopment effort would result in an approximate one-year delay and produce estimated duplicated costs of $6.2M. The redesign of eCAMS would consist of developing new requirements, design and analysis of the redesigned solution, implementation and deployment, developer testing, quality assurance acceptance testing, and evaluation. To redesign or procure a new healthcare claims system would result in a substantial duplication of cost and resources which would not be recouped through competition. If the Government were to redesign this system, all current automated healthcare claims processing functionality would halt and future automated processing would be severely delayed. This would severely impact VA FCS’s ability to process and pay claims for care delivered to Veterans by non-VA providers under the Program and other non-VA care authorities and in direct compliance with the Veterans Access to Care Act of 2014. Additionally, VA would be at

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high risk of outside medical providers stopping their provided care to Veterans being supported under the VA Choice program, which would have serious negative impacts to Veterans health.

Furthermore, 3M GPCS software is a proprietary software product; therefore, no other software maintenance provider has the proprietary code to perform the necessary maintenance and technical support services including software upgrades, updates, enhancements, and corrections. Access to this code is also needed to ensure all services provided are properly configured. The maintenance and technical support of 3M GPCS software is critical for the software to continue to remain operational in support of medical claims processing which is a mandated under the Veterans Access to Care Act of 2014.

6. Efforts to Obtain Competition: Market research was conducted, details of which are in the market research section of this document. 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 Contracting Opportunities Page in accordance with FAR 5.201.

Any proposals that are received shall be evaluated.

7. Actions to Increase Competition: The Government will continue to conduct market research to ascertain if additional solutions are able to integrate with VA eCAMS HCE.

8. Market Research: Market research was conducted by VA technical experts in February 2023 to ascertain the ability of any other source besides 3M to provide healthcare claims pricing methodology software and maintenance that meets the Government’s requirements. The research consisted of web-based research that reviewed similar software products including AMPS software and Optum’s RevCycle Pro software. After reviewing these software products it was determined that no other alternative software can integrate with eCAMS without a redesign of the respective solutions and redevelopment of an interface as detailed in Section 5 of this justification. The Government contacted eCAMS HCE representatives on January 26, 2023 and confirmed that only 3M GPCS can integrate with the eCAMS HCE solution and that any other software would require a significant redesign and redevelopment. The Government contacted 3M representatives and received a confirmation letter on February 8, 2023 that it is the sole provider of brand name 3M software and support and that the firm does not have any authorized resellers. The confirmation letter was placed in the contract file. In addition, additional market research was conducted in February 2023 via a Request for Information (RFI) that was posted on the National Aeronautics and Space Administration Solutions for Enterprise-Wide Procurement V Government-Wide Acquisition Contract. The RFI was posted for the Brand Name 3M requirement. No responses were received.

9. Other Facts: VA FCS awarded competitive procurement contract, 36C10B18C2551, on November 2, 2017 with CNSI eCAMS HCE claims processing solution. The contract had a period of performance of 24 months with three 12-month option periods. VAalso

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awarded a follow-on contract for eCAMS support with CNSI in March 2023 that will extend support of eCAMS through the Period of Performance of this action.