JA_AMCMS Extension-Final-Redacted.pdf

VA-24-00111485

JUSTIFICATION

FOR AN EXCEPTION TO FAIR OPPORTUNITY

1. Contracting Activity: Department of Veterans Affairs (VA) Office of Procurement, Acquisition, and Logistics Technology Acquisition Center 23 Christopher Way Eatontown, NJ 07724

2. Description of Action: The proposed sole source action is for a Firm Fixed Price modification for a three (3) month extension to task order (TO) 36C10B19N10150046 issued under Transformation Twenty-One Total Technology Next Generation (T4NG) Contract VA118-16-D-1015 for Advanced Medical Cost Management Solutions (AMCMS) and Healthcare Financial Management Services with Liberty IT Solutions LLC (Liberty), 2303 Dulles Station Blvd STE 210, Herndon, VA 20171.

3. Description of the Supplies or Services: The Veteran Health Administration (VHA) Office of Integrated Veteran Care (IVC) requires a three-month extension of the AMCMS and Healthcare Financial Management Services TO to ensure the current system remains operational while VA revises its requirements to better define its new Cost, Utilization and Performance Platform (CUPP) solution that will replace AMCMS and re-issues the cancelled solicitation to meet IVC’s requirements. VA is the largest clinically integrated health system in the Nation, providing access to medical care for approximately nine million enrolled Veterans. To ensure that all patients have adequate access to timely, high-quality, specialized care, VA continues to deploy modernization efforts and clinical care innovations to maximize care efficiency without jeopardizing quality or access. VHA IVC is committed to optimizing the delivery of the soonest and best care to Veterans and beneficiaries. This includes supporting operational functions and developing tools and products to ensure care provided to Veterans by community providers is scheduled, accessed and paid for in a timely manner. The passing of the VA Maintaining Systems and Strengthening Integrated Outside Networks (MISSION) Act and the recent passing of the Promise to Address Comprehensive Toxics Act of 2022, further solidifies the importance of IVC’s role in maintaining responsible Veteran care through efficient allocation of resources. In order to manage, forecast and monitor health care purchased outside of VA Medical Centers (VAMC), IVC utilizes the AMCMS and Healthcare Financial Management Services TO to accomplish its goals. This TO implemented an AMCMS system based on a Software as a Service (SaaS) solution, the WellHive Platform, which integrates financial management, medical management and data analytics to accurately forecast, monitor and control IVC’s medical services costs.

AMCMS enables VA to define, document, and manage Community Care activities across healthcare networks and organizations external to VA within one system and supporting user interface. Additionally, this TO provides healthcare financial management services to support the identification, measurement and management associated with services provided and managed by IVC. Financial healthcare management services include asset management, liability management, valuation support, healthcare planning, organizational structure evaluation, development of

AMCMS Task Order Extension VA-24-00111485

CCN contracts have been built during performance of the current TO to ensure VA has access to the necessary data to calculate Quality Assurance Surveillance Plan Performance Objectives and subsequently accurately and efficiently calculate the incentive and disincentive factors (IDFs) of these contracts. Calculations for these elements are based on monthly data refreshes of electronic data interchange (EDI) and claims data which feed into the system to ensure accurate processing and calculation of performance. As the CCN contracts constitute multiple billions of dollars being spent by VA annually, to lose the ability of oversight of performance and, more importantly, a way to calculate IDFs is a critical risk to VA. VHA IVC will lose the ability to monitor access for community care, access contract performance for all CCN contracts, and the resolution of at least 15 current Government Accountability Office and Office of Inspector General recommendations should the AMCMS system shut down. As the current contractor supporting the system, Liberty is the only source capable of renewing the underlying SaaS agreement for this specific timeframe as well as providing the required maintenance, data refreshes, and financial management services that have been specifically tailored to make the necessary calculations for VA’s CCN contracts.

AMCMS, as currently functioning, has gone through years of development and ongoing refinement to ensure VHA IVC has accurate calculations of performance and IDF precisely aligned with the language of the CCN contracts. These calculations have undergone multiple iterations of vetting with contract and CCN vendor staff to ensure agreement and transparent understanding of these critical elements in contract support.

Liberty is the only source with the necessary technical expertise and understanding to complete the performance and IDF calculations needed for CCN contract monitoring while VA continues its efforts to compete for a new CUPP solution to replace AMCMS, as detailed in Section 6 below. As such, this TO extension is essential to avoid a gap in the AMCMS system availability and VA’s oversight of the CCN contracts which support VA’s mission to provide Veterans access to care in the community as required under MISSION Act.

6. Efforts to Obtain Competition: Market research was conducted, details of which are in the market research section of this document. On August 15, 2024, VA released a competitive solicitation for the procurement of a CUPP solution. While offers were received in response to the solicitation, during the evaluation process, it became apparent that the requirements specified in the solicitation did not sufficiently capture VA’s needs. Two amendments were issued, on August 29, 2024 and September 13, 2024, in an attempt to clarify and provide additional specificity for the CUPP requirements. However, after careful consideration and re-examination of the requirements, VA decided to cancel the CUPP solicitation on September 19, 2024. VA is currently in the process of revising its CUPP requirements and considering a change in the acquisition strategy with the intention to re-release the solicitation and execute a competitive award during the first quarter of Fiscal Year 2025. In order to ensure the current AMCMS system remains available to provide continued oversight of VA’s CCN contracts, a three-month extension to the current TO is necessary, for which there is no competition anticipated. In accordance with FAR 5.301 and 16.505(b)(2)(ii)(D), the award notice for this action will be synopsized on the Contracting Opportunities website, SAM.gov and the justification will be made publicly available within 14 days of award.

7. Actions to Increase Competition: As detailed in Section 6, VA released a competitive solicitation for a CUPP SaaS tool, which is the follow-on effort for the current AMCMS TO. Although the solicitation has been canceled, VA intends to revise the requirements, potentially change the acquisition strategy to utilize a different contract vehicle to promote additional competition for the requirement, and execute a competitive award for the CUPP procurement.

8. Market Research: Market research for the CUPP procurement was performed by utilizing NASA SEWP V GWAC to advertise a Request for Information (RFI) on May 3, 2024. Two responses were received from I3 Federal, LLC and V3Gate, LLC. TAC confirmed that both respondents were capable of providing SaaS tools and professional services that would meet the requirements. However, as detailed above, VA has made the determination that the CUPP requirements specified in the solicitation are not sufficient to meets IVC’s needs. Furthermore, neither of the vendors that responded to the solicitation would be able to meet VA’s current requirement for the next three months, which is to sustain the AMCMS system in its current configuration and continue to provide the necessary financial management services to provide oversight of the CCN contracts while the CUPP requirements are revised and re-solicited for the competitive procurement. Specifically, I3 Federal, LLC is not a reseller for the WellHive Platform SaaS, and therefore, would be unable to provide the necessary software subscription for VA users. V3 Gate, LLC is a WellHive Platform SaaS reseller, but would be unable to provide the shorter-term (i.e. three months) subscription for the licensing and does not have the necessary technical knowledge and understanding of the current configuration of the system to provide the required financial management services beginning on September 25, 2024. Only the current contract, Liberty, has both the ability to renew the current SaaS subscriptions for a three-month term as well as the necessary familiarity with the current configuration of the system to meet IVC’s requirements during this three-month performance extension.

9. Other Facts: None.

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.

Date: ________________________________

Signature:

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 historical prices paid for SaaS solution and financial management services in accordance with FAR 15.404-1(b)(2)(ii).

Date: ________________________________

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.

Date: ____

Procuring Contracting Officer Signature:

09/24/2024

09/24/2024

09/24/2024

Approval

In my role as procuring activity Advocate for Competition, based on the foregoing justification, I hereby approve the acquisition of a three (3) month extension to task order 36C10B19N10150046 for AMCMS and Healthcare Financial Management Services on an other than fair opportunity basis pursuant to the authority cited in Section 4 above, subject to availability of funds, and provided that the services herein described have otherwise been authorized for acquisition.

Date: ____________ Signature:

Advocate for Competition Technology Acquisition Center Office of Procurement, Acquisition, and Logistics

9/24/2024