JA Limited Source Justification.pdf

FEDERAL SUPPLY SCHEDULE LIMITED-SOURCES JUSTIFICATION

Acquisition Title: Implementation of the Medicare PDP and MA Plan Disenrollment Reasons Survey Agency: Centers for Medicare and Medicaid Services (CMS) Acquisition Year: 2025 Author: Mark Smolenski, Contracting Officer

1. Description of Action:

Nature

☐ New Requirement ☐ Follow-On Order ☒ Modification of Existing Purchase Order / Contract Number: GS-10F-0275P/75FCMC20F0033

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: $0 Funding Source (s): N/A

Name of Proposed Contractor(s): The RAND Corporation Street Address: 1776 Main Street City, State, Zip: Santa Monica, CA 90407

2. Description of Supplies or Services:

The purpose of this contract is the continued implementation and analysis of a survey that captures the reasons beneficiaries choose to voluntarily disenroll from Medicare Advantage (MA) Plans and stand-alone Prescription Drug Plans (PDPs). The disenrollment survey was designed to capture the reasons for disenrollment at a time that is as close as possible to the actual date of disenrollment. Through this survey, CMS seeks to: (1) obtain information about beneficiaries’ expectations relative to provided benefits and services (for both MA Plans, and PDPs); and (2) determine the reasons that prompt beneficiaries to disenroll.

FAR 52.217-8, Option to Extend Services, provides the Government the option to extend contract performance for up to an additional six months at the rates specified in the contract. The option provision may be exercised more than once, but the total extension of performance hereunder shall not exceed 6 months. Because the option price was not evaluated at the time of award, a limited-sources justification is required to exercise the option, along with the determination required by FAR 17.207(c). This approach is consistent with the decision and direction in Government Accountability Office (GAO) case B-410472.

This proposed action requires no additional funding. The period of performance end date for Option Period 4 of the task order is being extended for one month from 6/30/2025 to 7/31/2025 to allow the contractor to submit data files, produce and disseminate individual plan reports and implement procedures for public reporting of results of the surveys as a result of CMS Technical Direction. The work under this task order is non-severable and CMS won’t receive full value of the work completed under it until all the deliverables are finalized.

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 on this task order needs to be completed by July 31, 2025. It would not be feasible at this point in time to have another contractor finalize the work started by RAND, which is in the final stages, and have meaningful results compiled in such a short time frame and complete this non-severable work.

4. Market Research:

Market research was not conducted in this instance as the period of performance extension of one month is just to allow the contractor to finalize a couple deliverables that will be completed after the current end date of the task order, which is June 30, 2025.

CMS will post this LSJ on SAM.gov with 14 days of completion of this extension in accordance with FAR 8.405- 6(a)(2).

5. Actions to Increase Competition:

N/A. This is only to extend the task order by one month to finalize a couple of deliverables that won’t be finished by 6/30/25 as a result of CMS Technical Direction.

6. Any other facts supporting the justification:

N/A https://sam.gov/content/home https://www.acquisition.gov/far/8.405-6 https://www.acquisition.gov/far/8.405-6

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:

RAND will continue billing at the current rates of the task order which are in accordance with their GSA MAS contract.

Based on the language contained in FAR 52.217-8, which says within the limits and at the rates specified in the contract, CMS anticipates receiving this same discount during the extension. As such, the pricing is still determined to be reasonable as it is in accordance with RAND’s GSA schedule rates.

Contracting Officer / Date

OAGM Approvals

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

__N/A________________________________________________ OAGM Division Director

3. CMS Competition Advocate Approval I hereby confirm the circumstances described above apply and approve the Limited Source Justification.

__N/A________________________________________________ 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

___N/A________________________________________________

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______________________________________________

___N/A______________________________________________