JA Limited Source Justification 01.22.26.pdf

FEDERAL SUPPLY SCHEDULE LIMITED-SOURCES JUSTIFICATION

Acquisition Title: Bonnie and Measure Authoring Tool (MAT) Agency: Centers for Medicare and Medicaid Acquisition Year: 2026 Author: Julie Bebber, Contracting Officer

1. Description of Action:

Nature

☐ New Requirement ☐ Follow-On Order ☒ Modification of Existing Purchase Order / Contract Number

Contract Type ☒ Firm-Fixed Price ☐ Time and Materials ☐ Cost Plus Fixed Fee (CPFF)

☐ Term ☐ Completion

☐ Cost Plus Award Fee (CPAF) ☐ Other:

Total Projected Cost / Price:

Contract Periods / Anticipated Contract Periods Anticipated Total Amount

Current Total Contract Value Inclusive of all Option Years $9,716,861.63 Anticipated Value of Extension 14 Week (7 Sprints - 4 Full/3 Reduced)

$1,374,674.38

Funding Source (s): QIO Project # 005301 Funding Source 0519: Support Contracts_Direct

Name of Proposed Contractor(s): SEMANTICBITS LLC Street Address: 1902 Reston Metro Plaza City, State, Zip: Reston, VA 20190-231

2. Description of Supplies or Services:

The Bonnie and Measure Authoring Tool (MAT) task order supports the centralization, maintenance, operations, and continuous improvement of the Measure Authoring and Development Integrated Environment (MADiE) for electronic Clinical Quality Measures (eCQMs) used in programs including the Quality Payment Program (QPP), Merit-based Incentive Payment System (MIPS), Advanced Alternative Payment Models (APMs), Hospital Inpatient Quality Reporting (IQR) Program, and Promoting Interoperability (PI) Programs. The contractor provides comprehensive services including requirements gathering, technical documentation, design, development, quality assurance testing, help desk support, and system operations and maintenance for MADiE, which transitioned from the legacy MAT and Bonnie applications. Services also include coordination with infrastructure support contractors, interdependent contractors, and internal and external stakeholders in accordance with project planning and management protocols.

The current contract is a GSA Multiple Award Schedule order (GS-35F-192BA/75FCMC24F0179) awarded to SemanticBits as a sole source logical follow-on under FAR 8.405-6(a)(1)(i)(C), authorized by a J&A signed in March 2024. The period of performance runs from August 26, 2024, through February 24, 2026, with financial obligations totaling $9,716,861.63 to date. CMS competed a replacement contract on GSA MAS using fair opportunity procedures and awarded it to Red Tail Digital LLC (47QTCA25D00E7/75FCMC26F0023) on December 3, 2025. However, a protest was filed on December 15, 2025, resulting in a stop work order on the new award.

The current Bonnie MAT II contract was scheduled to ramp down during the final three sprints (six weeks) from January 14, 2026, through February 24, 2026, to transition to the new MADIE contract, which had a planned start date of December 10, 2025. Due to the protest and work stoppage, CMS requires an extension to the current contract to ensure continuity of critical services during the protest resolution and transition period. This justification seeks approval for a contract modification extending the period of performance from February 25, 2026, through June 2, 2026 (approximately 14 weeks), with an estimated value of $1,374,674.38.

3. Authority and Justification for Limited Sources:

This acquisition is being conducted under the authority of the FSS 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, as implemented at RFO - FAR 8.401 and GSAM/R 538.7104-3(b)(1). Mark the applicable exception and for each, discuss how the cited authority applies in accordance with GSAM/R 538.7104-3(b)(1).

☒ Only one source is capable of providing the products, services or solution required at the level of quality required because the products, services or solutions are unique or highly specialized GSAM/R (538.7104-3(b)(ii))

To meet the immediate 14-week operational need, the government will issue a modification to the current Bonnie MAT II Task Order 75FCMC24F0179, encompassing four full sprints and three reduced sprints (each sprint is two weeks). Due to the critical nature of uninterrupted service delivery and the specialized requirements of the MADiE system, SemanticBits is the only source capable of providing the required services at the necessary quality level.

SemanticBits possesses unique and highly specialized capabilities that cannot be replicated by another contractor within the required timeframe:

System-Specific Expertise: SemanticBits has comprehensive knowledge of the MADiE system architecture, proprietary codebase, operational workflows, and technical dependencies developed over the current contract period. This institutional knowledge is essential to maintaining system integrity and cannot be transferred without significant risk to operations.

Immediate Operational Continuity: SemanticBits can continue work without interruption, onboarding delays, or knowledge transfer requirements. Any alternative source would require an estimated 3-6 months for procurement and an additional 3-6 months for transition and knowledge transfer, creating an unacceptable service gap during a critical protest period.

Proven Performance and Stakeholder Integration: SemanticBits has demonstrated successful performance supporting CMS quality measurement programs and has established essential working relationships with measure developers, measure stewards, ONC, VSAC, and interdependent contractors.

These relationships are critical to coordinating complex, time-sensitive deliverables across multiple CMS programs including QPP, MIPS, Advanced APMs, Hospital IQR, and Promoting Interoperability Programs.

Specialized Technical Knowledge: SemanticBits possesses specialized expertise in eCQM development standards, CMS program-specific requirements, and the technical integration points between MADiE and dependent systems. This expertise is highly specialized and not readily available in the marketplace at the level of proficiency required for uninterrupted operations.

The combination of system-specific institutional knowledge, immediate availability without transition risk, established stakeholder relationships, and specialized technical expertise makes SemanticBits uniquely qualified to provide the required services. No other source can perform the work within the required timeframe while maintaining the quality and continuity of service essential to CMS quality measurement programs. Awarding to any other contractor would necessitate months of procurement followed by extensive transition activities, resulting in operational disruptions, increased costs, and unacceptable risks to mission-critical programs serving healthcare providers and beneficiaries nationwide.

4. Market Research:

CCSQ and the Information Systems Group (ISG), in coordination with OAGM, conducted market research through two approaches: (1) analysis of existing ISG contracts to identify capable vendors, and (2) competitive procurement of the replacement contract (awarded December 3, 2025, currently under protest).

While the competitive procurement demonstrated that other firms possess general technical capabilities for agile development services, the analysis confirmed that SemanticBits is the only source capable of providing the required services during this extension period. SemanticBits possesses unique, specialized knowledge of the MADiE codebase, system architecture, and the complex legacy Bonnie MAT tools that are critical to supporting ongoing operations during the post-decommissioning transition period. This institutional knowledge, combined with established staff and program expertise already in place, enables SemanticBits to provide uninterrupted service delivery without the months-long onboarding, knowledge transfer, and transition activities that would be required for any alternative source.

The government requires SemanticBits to perform the work under this extension to ensure continuity of critical services while the protest is resolved and to facilitate an effective transition to the new contractor once the protest is concluded.

5. Actions to Increase Competition:

CMS has already taken action to acquire the needed services through competitive fair opportunity procedures.

The necessity to extend the current contract through a modification is solely due to the GAO protest, which is beyond CMS’s control. The extension is a temporary measure to maintain service continuity while the protest is resolved, after which the completely awarded contract will proceed.

6. Any other facts supporting the justification:

N/A

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

2. Contracting Officer Certification and Best Value Determination:

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.

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:

Contracting Officer / Date

3. CMS Competition Advocate Approval

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

Name / Date

4. Head of Contracting Activity (HCA) Approval I hereby confirm the circumstances described above apply and approve the Limited Source Justification.

N/A

5. Office of Small and Disadvantaged Business Utilization

6. OGC Legal Review

7. HHS Competition Advocate Approval

8. Senior Procurement Executive (SPE) Approval

Based on the foregoing justification, I hereby confirm the circumstances described above apply and approve the Limited Source Justification.

N/A