JA Limited Source Justification.pdf

FEDERAL SUPPLY SCHEDULE LIMITED-SOURCES JUSTIFICATION

Acquisition Title: CMS Enterprise Access Management System (CEAMS) Agency: Centers for Medicare and Medicaid Services (CMS), Office of Information Technology (OIT) Acquisition Year: 2025 Author: Wade Zarriello, Heather Brown, Allan Hess, Julie Bebber and Tony Salinas

1. Description of Action:

Nature

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

• GS-35F-595GA 75FCMC20F0048

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:

Current Total Contract Value Inclusive of all Options

$41,284,065.72

Anticipated Value of Action $7,283,854.00 Anticipated Total Contract Value Inclusive of all Options

$48,567,919.70

Funding Source (s): Project Number 000010 Prog Ops - Hosting Operations and End- User Support; funding source 0511: Program Operations Direct: Disc

Name of Proposed Contractor(s): Alcor Technical Solutions LLC Street Address: 5520 Research Park Dr, Suite 100 City, State, Zip: Baltimore, MD 21284-4851

2. Description of Supplies or Services:

CMS is responsible for serving Medicare and Medicaid beneficiaries nationwide. The CMS OIT plays an integral role within CMS by providing enterprise-wide software development, hosting, management, and oversight. OIT is involved in almost every on-line touchpoint that CMS provides, whether to payers, providers, beneficiaries, or staff. Within this context, CMS is seeking to improve the services provided within the CMS Enterprise User Access (EUA) and Identity Credentialing Tool (ICT) system & obtain Operations & Maintenance support for key enterprise shared services. The goal is to provide a consistent user experience by providing a common level of automation, interoperability and standardization that is compliant with CMS standards and procedures. Alcor Technical Solutions has been contracted since 2020 to assist OIT in pursuit of this goal. Specifically, the CEAMS contractor is responsible for providing human centered design-based solutions and implementation support for CMS to improve the end-user experience of all relevant systems, automate business processes, enable real time collection of data, analysis, monitoring, reporting, and to ultimately improve business operations and effectively utilize resources to the EUA & ICT systems.

This Limited Source Justification contemplates extending the contract for a period of six (6) months. This 6-month period will enable the continuity of operations without a lapse or disruption given the respective value, expertise, and technical skill set of services provided while transitioning to the new awardee should the incumbent not win the award. Specifically, the work to be performed will include continuation of Operations and Maintenance of legacy shared services, such as Active Directory & LDAP as well as release of new EUA/ICT features & functionality.

Current Order Period of Performance:

Period Period of Performance Base Period 07/01/2020 - 12/31/2020 Option Period 1 01/01/2021 - 06/30/2021 Option Period 2 07/01/2021 - 06/30/2022 Option Period 3 07/01/2022 - 06/30/2023 Option Period 4 07/01/2023 - 06/30/2024 Option Period 5 07/01/2024 - 06/30/2025

Additional Period: 07/01/2025 - 12/31/2025

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));

The work of the contract includes a significant modernization of the IT infrastructure for EUA by re-deployment from its legacy hosting environment to AWS?MAG? in CMS Cloud. This effort is under way but not anticipated to finish before the end of the contract’s period of performance.

Efforts to complete this project have been delayed due to the need to support other efforts which are outside of the control of the EUA team. The CMS cloud team is engaged in an Office of the Inspector General (OIG) audit that began in early 2024 and will complete in early 2025. The audit has caused diversion of resources on the CMS Cloud infrastructure team and has delayed resourcing for any EUA system go live reviews, security audits, or configurations. The audit has caused long delays from various teams (including the EUA contract team) who were required to support the OIG audit as a main priority.

In addition, CMS is bound by strict policy to minimize all infrastructure and application changes during the CMS Open Enrollment (OE) period (September 2024 through January 2025) for both Medicare and Health Insurance Marketplace. Unless under emergency circumstances, any changes, system enhancements, or new functionality releases must be delayed until after OE ends. EUA is a critical system in support of OE.

Only the incumbent contractor can perform the required work without significant delays, which in turn would undermine on-going efforts to improve the IT supporting personnel Vetting and Credentialing. EUA’s new cloud environment, while run on common infrastructure using common coding languages, is custom developed that requires a significant transition time from contractor to contractor. Without a successful transition period from one contractor to another, it would require approximately 9 to 12 months to reverse engineer the code for understanding and possible re-work (additional cost) to deploy.

A six-month extension would allow the EUA team to support the OIG audit and OE while allowing sufficient time to go live with the system changes prior to award of a new contract and allow a successful transition beginning in July 2025 and ending in December 2025. The extension will allow CMS to avoid significant delays in background check process and to deprecate old and legacy functionality and ensure proper coverage.

☐ Only one source is capable of providing the supplies or services required at the level or quality required becausethe supplies or services are unique or highly specialized (FAR 8.405-6(a)(i)(B)); or

☐ 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

☐ 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:

From a technical perspective, Alcor Technical Solutions Inc. is hosting the new EUA/ICT cloud environments within CMS authorized cloud environment. No market research was completed for this action because there https://www.acquisition.gov/sites/default/files/current/far/html/Subpart%208_4.html https://www.acquisition.gov/sites/default/files/current/far/html/Subpart%208_4.html

Digitally signed by Allan D. Hess -S Date: 2024.12.19 08:24:52 -05'00'

Nichole M. Poist -S Digitally signed by Nichole M. Poist -S Date: 2024.12.19 10:10:45 -05'00' is no information from industry that would change this technical reality (Alcor is hosting the new EUA/ICT cloud infrastructure), which is the primary justification for the sole source acquisition. Any new contractor would need to repeat the work already done to get the program to where it is now.

IUSG has knowledge of the market for these services based on ongoing market research for related acquisitions and interactions with various industry partners. As a result of that expertise and experience, IUSG is confident no information received from market research would change the contracting approach.

5. Actions to Increase Competition:

This work is a modification to an original Federal Supply Schedule order whereby the original order was placed in accordance with the applicable Federal Supply Schedule Fair Opportunity ordering procedures and not as sole source or limited source procedures. Following the end of this contract, inclusive of the additional six months, CMS will compete the operation and maintenance of the identify management system. As a result, there are no anticipated barriers to future competition.

6. Any other facts supporting the justification:

In accordance with 8.405-6(c)(2)(8), the Government intends to solicit this sole source requirement to a pool of vendors on GSA MAS in order to maximize competition potential. No other possible actions could be taken at this time to remove or overcome any barriers that leads to this restricted consideration for the required items.

The Government will continue to evaluate the possibility for competition during each recompete of this requirement as well as ensure best interest for the Government between option periods.

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:

Digitally signed by Donald Knode -S

Per FAR 8.404(d), “GSA has already determined the prices of supplies and fixed-price services, and rates for services offered at hourly rates, under schedule contracts to be fair and reasonable. This effort will be a modification under the GSA MAS order for the Alcor MAS Schedule Contract. The proposed labor mix and level of effort will be evaluated for price reasonableness.

Digitally signed by JULIA A. BEBBER -

Julia A. Bebber

Contracting Officer / Date

S Date: 2024.12.19 08:06:53 -05'00'

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

N/A

6. OGC Legal Review

_N/A

7. HHS Competition Advocate Approval

8. Senior Procurement Executive (SPE) Approval