JA Limited Source Justification BEDAP.pdf

FEDERAL SUPPLY SCHEDULE LIMITED-SOURCES JUSTIFICATION

Acquisition Title: Beneficiary Experience Data Analytics Platform (BEDAP) Agency: The U.S. Department of Health and Human Services (DHHS), Centers for

Medicare & Medicaid Services (CMS), Office of Acquisition and Grants Management

(OAGM)

Acquisition Year: FY 2022 Author: Donald Bozimski, Contracting Officer (CO)

1. Description of Action:

Nature

• ____ New Requirement

• ____ Follow-On Order

• _X__ Modification of Existing Purchase Order / Contract Number

Contract Type

• _X__ Firm-Fixed Price

• ____ Time and Materials

• ____ Cost Plus Fixed Fee (CPFF)

• ____ Term

• ____ Completion

• ____ Cost Plus Award Fee (CPAF)

• ____ Other: ___________

Projected Cost / Price: The total value of this task order increases by 5,342,046; from $16,698,015.70 to $ 22,040,061.70

Funding Source (s): Annual Appropriations – Program Operations and Exchange

Name of Proposed Contractor(s): Flexion Inc. (Flexion)

Street Address: 1500 West Main Street, Suite 500

City, State, Zip: Sun Prairie, WI, 53590

2. Description of Supplies or Services:

The Centers for Medicare & Medicaid Services (CMS) has developed a Beneficiary Experience Data Analytics Portal (BEDAP) to provide a single source of truth for Medicare Beneficiary data that would equip CMS' communications channels to support an improved omnichannel experience across the Medicare program including Medicare.gov, 1-800-Medicare, publications and outbound outreach such as email and other direct response tactics.

In 2018, the BEDAP architecture was established within the AWS Cloud Hosting environment. BEDAP will provide a data store for Medicare.gov/MyMedicare.gov user data that is currently stored in the Next Generation Desktop (NGD) Siebel Database with the goal of eliminating data dependencies on the NGD system. Additionally, BEDAP will integrate Medicare Beneficiary Demographic (MBD)/ Eligibility Enrollment Medicare Online (ELMO) data as well as Original Medicare Claims data and web analytics data. BEDAP will also integrate Encounter Data. There will be an analytics/Business Intelligence capability as part of BEDAP which will provide business stakeholders insights into the data being integrated into the BEDAP at each phase of the project. The project will also support the agency’s Digital Seniors effort by providing Business Intelligence to improve the omnichannel experience for beneficiaries and their caregivers. This will be accomplished by providing real time transaction support, an analytics platform, and an outreach engine.

CMS has need for IT professional services to support development and operations of BEDAP. The principal support tasks include Continuous Integration/Continuous Delivery (CI/CD), release support, outage support, monitoring, application and development configuration, infrastructure support, and independent testing. The twelve (12) months of performance proposed to be added via the modification contemplated in this document will consist of one eleven (11) month option period and one (1) additional month of transition which will be added to the existing CLIN 0010 two (2) month transition-out period. The total period of performance (in the event that both options are exercised) will be from March 19, 2022 through May 18, 2023.

3. Authority: ORDER AGAINST FSS: Authority of the Multiple Award Schedule 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; and Section 803 of the National Defense Authorization Act of 2002 (PL 107-107) and implemented by FAR 8.405-6. Mark the applicable exception and for each discuss how the cited authority applies in accordance with FAR 8.405-6(c)(2)(iv).

____: An urgent and compelling need exists, and following the procedures would result in unacceptable delays (FAR 8.405-6(a)(1)(i)(A));

_____: Only one awardee is capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized [FAR 16.505(b)(2)(i)(B)];

X___: In the interest of economy and efficiency, the new work is a logical follow-on to an original Federal Supply Schedule order provided that the original order was placed in accordance with the applicable Federal Supply Schedule ordering procedures. The original order or BPA must not have been previously issued under sole-source or limited sources procedures (FAR 8.405-6(a)(1)(i)(C)); or

A series of extenuating circumstances outside the control of the BEDAP program delayed the planned development, implementation, and migration of Medicare.gov data sources to the BEDAP platform.

Additionally, the BEDAP team is working with CMS on defining additional data elements and data sources to support the migration of workflows from dependency on the Next Generation Desktop (NGD) Integration Layer while improving usability in support of the eMedicare initiative.

The requested twelve (12) month extension of the current BEDAP contract is necessary to complete key strategic deliverables including the migration to Redshift, the implementation of Multi-Factor Authentication for Medicare.gov, and the coordination of data elements to support an expanded Beneficiary profile feature on Medicare.gov. The implementation of Multi-Factor Authentication (MFA) on Medicare.gov will require additional data elements to be captured from users as well as new user workflows that will have dependencies on BEDAP Application Program Interfaces (APIs) and data. The extension of this Task Order will allow CMS to complete this implementation during the requested extension period. The implementation of MFA during this timeframe is in response to an Executive Order specifying the requirement for MFA on federal pubic websites.

This need exists because, as explained above, the migration effort will only be partially complete by the current end date of March 2022 and cannot be handed off to a new contractor midway through without significant risks, delays, and costs. Transitioning this requirement to a new contractor during this migration and getting the new contractor up to speed would cause CMS to incur both increased cost and schedule impacts which would result in unacceptable delays to the data source migration. Extending time necessary to bring the new awardee up to speed and pick up where the incumbent contractor leaves off would result in redundancies introducing risk to key deliverables to include the migration to RedShift, the implementation of Multi- Factor Authentication, and the coordination of data elements to support personalization objectives.

The original GSA FSS order (HHSM-500-2016-00010B-75FCMC18F0002) was competed in 2018 amongst Agile Delivery to Execute Legislative Endeavors for Quality Related Initiatives (ADELE-QRI) Blanket Purchase Agreement (BPA) holders established under GSA IT Schedule 70 and awarded to Flexion. It is necessary to continue this requirement through a sole-source action as it is not in the agency’s best interests to transition to a new contractor at this time. Flexion’s performance has been better than satisfactory and it is the only source available to ensure that there is no disruption to the mission critical Medicare.gov data source migration.

Through the current BEDAP task order, Flexion has supported WETG by working with the data teams to identify and integrate with alternative data sources to the legacy Next Generation Desktop (NGD) Integration Layer and Data Repository. Several of these integrations rely on the implementation of AWS capabilities such as the migration to Redshift and Kinesis which is in process. It is not reasonable to expect any other source would be determined a better value than the incumbent contractor were this effort the subject of a competitive (fair opportunity) acquisition, because any cost or performance benefits of a competitor would be outweighed by the drawbacks of transition described above.

____: An item peculiar to one manufacturer can be a particular brand name, product, or a feature of a product, peculiar to one manufacturer). A brand name item, whether available on one or more schedule contracts, is an item peculiar to one manufacturer. (FAR 8.405-6(b);

4. Market Research:

The acquisition team conducted an environmental scan consisting of a review of the available Government wide and agency contract (GWAC) vehicles, their specific technical scopes alignment with requirements appropriate for competition of the authenticated experience development and user portal integration services and assessed the availability of contractors that can meet the stated objectives of the BEDAP contract. Although there are other Contractors that have the technical expertise to provide these types of services, it would require a transition period which incurs risk to complete the key strategic deliverables during a critical time in the personalization strategy whereas an eleven (11) month extension period and one (1) three (3) month transition period (inclusive of existing two (2)month Transition Out Period) to the current task order would be more cost and time efficient for the Government. The requested extension of the current BEDAP contract is necessary to complete key strategic deliverables as required to comply with the Executive Order with regard to the implementation of Multi-Factor Authentication for Medicare.gov, and the coordination of data elements to support an expanded Beneficiary profile feature on Medicare.gov which is also a dependency for the MFA initiative. The current BEDAP contractor possesses the requisite institutional knowledge and expertise to accomplish the completion of these key required deliverables.

5. Actions to Increase Competition:

CMS is working on a longer-term acquisition strategy in parallel with this contract extension aimed at fostering increased competition for future opportunities. The OC/WETG and OAGM integrated acquisition team is currently conducting market research, and is planning to conduct a competitive procurement, for a five (5) year-MAX 2.0 contract, which will also encompass the work currently provided under the existing BEDAP contract. The work currently provided under the BEDAP contract will be focused on the Medicare Authenticated Experience going forward and will be included in the next MAX contract to increase efficiency as the needs of the MAX strategy as it develops will drive the data elements and services implemented. These efficiencies include the consolidation of Application Programming Interface (API) work that is currently duplicated on contracts, as well as the consolidation of the coordination of requirement development and implementation in support of these activities into a single contract. Additional efficiencies will be realized by the consolidation of user profile information storage and updates that are also duplicated across both contracts.

6. Any other facts supporting the justification:

None

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

Best Value Determination. 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:

The contractor proposed pricing will be compared to an Independent Government Cost Estimate, market research, and historical data to include a comparison with the rates established on their current BPA contract and the previous task orders. Based on this analysis, the Contracting Officer will negotiate a fair and reasonable price. A further determination will be made by the Contracting Officer that the action represents a fair and reasonable cost to the Government by conducting both a technical and price evaluation as part of a fair and reasonable price determination.

2. Contracting Officer Certification: 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.

Contracting Officer / Date

OAGM Approvals

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

OAGM Division Director / Date

OAGM Group Director / Date

3. Head of Contracting Activity (HCA) Approval

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

HCA Name / Date

4. CMS Competition Advocate (CA) Approval

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

__N/A_________________________________________________ Name / Date

5. OGC Legal Review

_____N/A____________________________________________ Name / Date

6. Office of Small and Disadvantaged Business Utilization s77c Typewritten Text 02/22/2022

__N/A_______________________________________________ Name / Date

7. Senior Procurement Executive (SPE) Approval

Based on the foregoing justification, I hereby approve the procurement of (state supplies/services being procured) on an other than full and open competition basis pursuant to the authority of (state the full statutory authority and FAR cite and title, consistent with paragraph 4, e.g. 41 U.S.C. 253(c)(1)), as implemented by FAR 6.302-1), subject to the availability of funds, and provided that the services herein described have otherwise been authorized for acquisition.

__N/A_______________________________________________ Name / Date