JA HICBA VIRR Post_Redacted.pdf

HICBA VIRR Software Control Number VA-25-00039427

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, NJ 07724

2. Description of Action: The proposed action is for a modification to firm-fixed price contract number 36C10B23C0012. This modification will provide a four (4) month extension of software licenses, maintenance, and technical support of the Health Information Coding, Billing, & Auditing (HICBA) Veterans Health Information Systems and Technology Architecture (VistA) Integration, Revenue, and Reporting (VIRR) software solution. The proposed effort will be awarded under contract number 36C10B23C0012 to Document Storage Systems, Incorporated (DSS), 12575 US Highway One Suite 200, Juno Beach, Florida 33408.

3. Description of the Supplies or Services: The Office of Information and Technology (OIT) requires the continued licensing, maintenance and technical support for the HICBA VIRR software solution while a competitive acquisition for a new contract is underway. HICBA business management falls within OIT’s Health Informatics Product line, Health Information Governance sub-product line. HICBA software solutions provide OIT with enterprise capabilities for health record coding and revenue cycle operations such as accounts receivable and billing. HICBA also provides for the management of health information and Revenue Operations business workflows and reporting from various management perspectives and Revenue Operations. HICBA is comprised of two components: an Encoder software solution and the VIRR software solution. This action is for the continuation of the VIRR software solution which provides VistA integration for the Encoder, workflow management for coding and revenue operations, and reporting functionality for these operations. HICBA VIRR requirements are stratified across the functional areas of billing software requirements, compliance requirements, Encoder integration and claims review (scrubbing) requirements, technical and on-call support requirements, training requirements, and reporting capabilities. Facilities, Veterans Integrated Service Networks (VISNs), and the Enterprise require reporting for coding and revenue and integration with VistA and VA’s HICBA Encoder software solution to enable these functionalities. HICBA VIRR is a commercial bill scrubbing software solution which includes enterprise level software access.

The national HICBA VIRR software solution applications (and the national HICBA Encoder solution that the VIRR applications enable) are the standard applications mandated for use throughout OIT by OIT’s Office of the Assistant Deputy Under Secretary for Health Informatics/10A7 and OIT’s Office of the Assistant Under Secretary for Health for Operations (AUSHO)/10N. Handbook 1901.07: Health Information

HICBA VIRR Software Control Number VA-25-00039427

Management (HIM) and Health Records (March 2015) and the OIT Health Information Management Clinical Program Guide V1.7 (December 2019) require use of the national VIRR applications to appropriately manage HIM coding and revenue cycle operations.

This is in support of meeting the mandates of the of AUSHO/10N memorandums to VISN and VA Medical Center (VAMC) Directors in response to Government Accountability Office and the Office of Management and Budget findings and recommendations: ‘Coding Backlog Reduction and Monitoring (VAIQ #7843437)’ (November 2017) and ‘Monitoring Accuracy of Provider Coding and Clinical Coding and Productivity (VAIQ #7688833‘ (May 2016)). The VIRR software solution applications also include billing tools currently used by all Consolidated Patient Account Centers (CPAC) billing and accounts receivable staff and management personnel.

This effort will be a modification to contract number 36C10B23C0012 that was awarded on a sole source basis to DSS on February 7, 2023.

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) 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 DSS, 12575 US Highway One Suite 200, Juno Beach, Florida 33408. The requirement is needed for software licenses, maintenance, and technical support for the HICBA VIRR software solution while a competitive acquisition for a new contract is underway. Based on extensive market research as described in Section 8 of this document, it was determined that there is no competition for this extension as DSS is the sole provider of the required VIRR software solution currently in place and has no resellers of this solution.

DSS is the only vendor that currently provides a suite of applications (Veterans In- Patient (VIP) Workplace, VIP Director, Compliant Coding Module (CCM), Audit Compliance Module (ACM)) that make up a VistA-integrated VIRR framework.

While this VIRR solution is tightly coupled with VistA on the one end, it includes multiple integration entry and exit points, and standardized application programming interfaces on the other end to allow it to be easily integrated with various commercial Encoder solutions. Over the last 12 years, DSS has customized its commercial software solution to integrate with VistA and be fully compliant with all of VA’s requirements. This VIRR solution is currently in use at all 141 VAMCs and seven CPACs. This customization has been performed under VA’s current and preceding contracts, giving the Government intellectual property rights. However, the customization which was done to integrate the DSS VIRR solution with VA’s current Encoder solution and VistA, for which the Government has intellectual property rights, are specific to the DSS software applications, their specific data types, data fields, and communication types, some of which are proprietary, and would not be reusable for any other solution.

HICBA VIRR Software Control Number VA-25-00039427

Without the HICBA VIRR software applications, there will be agency delinquencies and inaccuracies in entering crucial clinical and administrative data into the above-mentioned VistA packages (which in turn feed the VA Equitable Resource Allocation algorithms which are used to distribute Congress’s funding allocations for VAMCs as well as third-party insurance claims). Also, without the VIRR software, no national Encoder solution would be available for use since VIRR provides the VistA integration required to enable the Encoder functionality. Without this automated encoding capability, HIM coding, management, and revenue operations staff and management will require remedial training on how to manually enter these codes into VistA and will also have to research using outdated methods that are currently not accepted by standard industry practice, such as paper coding books, and costly online resources. Without the VIRR capability, billers will be forced to manually research every claim for any business rules that apply in order to ensure all entries are accurate, complete, and no errors exist on the bill prior to submission to the third-party payer. The loss of this VIRR software solution will require all coding and billing to be completed manually, using a paper process; thus delaying these important processes and having a direct, negative impact on third party revenue generation. Without the VIRR applications, medical providers could end up not providing medical treatment to Veterans in need due to lack of payment and billing information. Veteran patients’ safety will be risked if Veterans are denied treatment.

Every inpatient discharge and billable encounter would have to be manually evaluated to ensure all current business rules are applied. Many facilities no longer have code books, so they would need to obtain access to the updated coding which would entail some time and additional costs. Acquiring paper code books and other required references and business workflow tools to accomplish these operations by the more than 3,000 daily users of these applications would significantly impede critical VA operations in support of clinical care and administrative functions.

Purchasing timeframes would present weeks to months of delays and implementing antiquated paper and manual processes for completing these functions would add additional weeks to months. Additionally, it would become much more labor intensive requiring the need to onboard more FTEs at every location. Funding these changes at the local levels would also require significant shifts in medical center spending, taking resources away from provision of care for Veterans. Veterans would face extreme delays and unacceptable difficulties obtaining any required pre-authorization for care from third-party insurance due to new manual procedures that are not accepted by the industry.

In addition to delinquent timelines, VA would also experience unacceptable risks of inaccurate data capture in HIM coding and inaccurate billing in revenue operations due to the potential for errors inherent in manual data entry and review. The VIRR software enables automated mechanisms that are industry standard to perform “edit checks” in HIM coding and “claim scrubbing” in accounts receivable and billing to prevent erroneous coding of clinical information and billing inaccurate claims to third-party insurance. Failing to provide these industry-standard safeguards would create

HICBA VIRR Software Control Number VA-25-00039427 unnecessary waste. Coding and billing errors that are not caught by time-consuming and resource-intensive manual procedures would result in VA’s depending on erroneous clinical data for provision of care to Veterans, erroneous documentation of physician workload, inaccurate reporting of quality measures, and inaccurate reporting to Congress for allocation of VA’s funding to medical centers.

It is critical that HIM coding and revenue operations personnel have the tools necessary to continue OIT business and keep revenue flowing to OIT. A disruption in continuity of health care services caused by administrative failures, such as a failure to support industry revenue cycles, could compromise or delay Veterans’ access to care. Access to the VIRR applications is necessary for OIT employees to carry out their duties in support of OIT’s mission.

6. Efforts to Obtain Competition: Market research was conducted, details of which are in the market research section of this document. In October of 2024 an additional RFI resulted in the discovery of a new potential solution that appears to meet technical requirements. There is a need for additional time to adjust the requirement to accommodate this potential alternative. Focus is newly found and we are adjusting to accommodate this to promote competition. Additionally, the proposed action will be synopsized on the Contracting Opportunities Page in accordance with FAR 5.201 and this Justification will be made publicly available.

7. Actions to Increase Competition: No barriers to future competition are anticipated.

The follow-on contract is anticipated to be awarded in the second quarter of Fiscal Year 2025 under competitive procedures. This extension will provide continued support until the new long-term contract is competitively awarded. Due to changing market conditions that were not anticipated, the acquisition strategy for the forthcoming source selection was changed from sole source to competitive. As a result, additional time is needed to update the requirements and to evaluate new vendors to ensure the Government requirements are met.

8. Market Research: Market research was conducted from October to December 2024 via a RFI on the Contract Opportunities website which included a draft HICBA VIRR performance work statement and a list of technical requirements and questions for the vendors to respond to. The RFI closed and the four (4) responses that were received were sent to the technical team for review. The response received from was reviewed and it was determined that they are not capable of meeting VA’s requirements for a commercial-Off-The-Shelf (COTS) bill scrubbing software suite solution with enterprise level software access. Their response did not include specific details regarding this requirement and their capabilities to meet it. The response received from was also deemed not capable as their capabilities only described limited healthcare experience 14 years ago and did not include any experience with VistA. The response from was reviewed and their solution was determined to potentially be technically capable as they described the COTS solution they would provide to meet VA’s requirements as well as their experience with healthcare claims and VistA. DSS as the

HICBA VIRR Software Control Number VA-25-00039427 incumbent contractor was also determined to have a capable solution. Each of VA’s requirements are currently being met with the VIRR solution DSS provides. Until we can thoroughly evaluate other vendors capabilities, the only vendor capable is the current vendor, which justifies the need for the four (4) month extension. An RFI was also posted on the National Aeronautics and Space Administration’s (NASA) Solutions for Enterprise-Wide Procurements (SEWP) V Governmentwide Acquisition Contract (GWAC) and no responses were received.

Based on all market research efforts, the Government’s technical experts have determined that a four (4) month extension to the current contract is required to ensure no break in service for the HICBA VIRR solution while a new competitive contract is awarded and only DSS’s currently fielded software solution can meet VA’s existing needs. Based on the above, it has been determined that only the HICBA VIRR software solution provided by DSS meets all of VA’s requirements and DSS is currently the only source that can accomplish the ongoing work for this four (4) month contract extension request. Although another potential vendor was identified during the RFI phase, none could be thoroughly evaluated to the extent needed to determine if they can actually meet a requirement of this magnitude. Furthermore, any other potential source, even if capable, would need to be transitioned and cannot start on day 1 without creating an intolerable lapse. Recent market research has permitted us to compete the follow on but that has caused us to adjust our requirements for the imminent source selection.

9. Other Facts. None.

HICBA VIRR Software Control Number VA-25-00039427

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.

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 current contact pricing and in comparison to the Government’s Independent Cost Estimate.

Contracting Officer Certification

I certify that this justification is accurate and complete to the best of my knowledge and belief.

HICBA VIRR Software Control Number VA-25-00039427

Office of General Counsel (OGC) Review

I have reviewed this document and find it legally sufficient, based on the representations set forth in the documents and, if any, attachments. The Competition Advocate’s approval is an independently supported decision not wholly reliant on the legal sufficiency determination.

HICBA VIRR Software Control Number VA-25-00039427

Approval

In my role as Advocate for Competition, based on the foregoing justification, I hereby approve the four (4) month extension of software licenses, maintenance and technical support for the HICBA VIRR software solution 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.