JA Limited Source Justification_NCQA_PMMAP 081926.pdf

FEDERAL SUPPLY SCHEDULE LIMITED-SOURCES JUSTIFICATION

Acquisition Title: PERFORMANCE MEASUREMENT FOR THE MEDICARE ADVANTAGE PROGRAM Agency: Centers for Medicare and Medicaid Services Acquisition Year: FY 2026 Author: Daniel G. Lehman

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: $9,777,718.00 Funding Source (s): 8393: Medicare Program Integrity_Direct:Disc

Name of Proposed Contractor(s): National Committee for Quality Assurance (NCQA) Street Address: 1100 13th Street, NW, Third Floor City, State, Zip: Washington, DC 20005

2. Description of Supplies or Services:

The estimated value of the proposed action, including all options, is $9,777,718.00 (base year + 4 option years), delineated as follows:

Contract Period Period of Performance IGCE Base Period 09/29/2026-09/28/2027 $2,025,000.00

Option Period 1 09/29/2027-09/28/2028 $2,025,000.00 Option Period 2 09/29/2028-09/28/2029 $2,025,000.00 Option Period 3 09/29/2029-09/28/2030 $1,851,359.00

Option Period 4 09/29/2030-09/28/2031 $1,851,359.00 Total $9,777,718.00

The purpose of this contract is to support CMS in the evaluation and approval of each SNP’s model of care (MOC). Section 1859(f)(7) of the Act and 42 CFR §§422.4(a)(1)(iv), 422.101(f), and 422.152(g) require that each Medicare Advantage (MA) organization (MAO) offering a SNP must submit a MOC to be approved by NCQA. In addition, 42 CFR §422.101(f) requires that MAOs offering SNPs develop and implement a MOC that provides structure for care management processes and systems that enable the SNP to provide a high level of care coordination to address the specialized needs of the target population.

NCQA shall also provide program management support (Task 1), including a kickoff meeting, work plan, monthly progress reports, annual reports, and an AI MOC Enhancement Plan.

Under Task 2 of this contract, NCQA reviews, scores, and approves each SNP MOC using CMS-established standards for the approval process. Under Task 2, beginning in Option Year 1, NCQA shall implement a technology strategy leveraging Commercially Available Off-The-Shelf (COTS) AI large language models (LLMs) to streamline MOC review, identify missing information, and assess compliance with CMS regulations and scoring guidelines.

NCQA shall also support improvements to the MOC Matrix (Task 2.5).

CMS has also developed policies and procedures for an MA organization to amend its MOCs after NCQA approval (see 42 CFR 422.101(f)(3)(iv). CMS has labeled this the “off-cycle MOC submission process” (Task 2.4). CMS has acknowledged in the past that in order to address the specific needs of its enrollees more effectively, a SNP may need to modify its processes and strategies for providing care during its approved MOC timeframe. NCQA will also review and approve updated MOCs through the off-cycle submission process to ensure these revisions are consistent with the quality standards as indicated in the approved MOC.

This contract also supports the collection of NCQA’s MA HEDIS® (Healthcare Effectiveness Data and Information Set) measures for SNPs at the plan benefit level (PBP). Under Task 3, the contractor will assist in the collection of PBP-level quality improvement data, in this case HEDIS®, as required of SNPs at 422.152(g)(1).

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 Revolutionary Federal Acquisition Regulation (FAR) Overhaul (RFO) Subpart 8.4 and General Services Acquisition Manual / Regulation (GSAM/R) Subpart 538.71. Mark the applicable exception and for each discuss how the cited authority applies in accordance with GSAM/R 538.7104-3 or GSAM/R 538.7104-4.

The need is of such unusual urgency that following the procedures would result in unacceptable delays in fulfilling that need (GSAM/R 538.7104-3(b)(1)(i)); or

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)(1)(ii)); or

The order should be issued on a sole source basis in the interest of economy and efficiency because it is a logical follow-on to an FSS order already issued on a competitive basis (GSAM/R 538.7104- 3(b)(1)(iii)); or

It is necessary to place the order with a particular FSS contractor to satisfy a minimum guarantee established in the FSS BPA (GSAM/R 538.7104-3(b)(1)(iv)); or

A law expressly authorizes or requires that the purchase be made from a specified source (GSAM/R 538.7104-3(b)(1)(v)); or

Section 1859(f)(7) of the Social Security Act and 42 CFR §§422.4(a)(1)(iv), 422.101(f), and 422.152(g) require that each MAO offering a SNP must submit a MOC to be approved by NCQA. NCQA is required by law to provide SNP approval. No other organization is authorized by statute or regulation to perform this function. Accordingly, no other FSS contractor is capable of satisfying the Government's minimum need for this requirement. This contract also supports the collection of NCQA’s proprietary product MA HEDIS® measures for SNPs at the plan benefit level (PBP). Under Task 3, the contractor will assist in the collection of PBP-level quality improvement data, in this case HEDIS®, as required of SNPs at 422.152(g)(1). NCQA owns the HEDIS® measurement methodology and holds exclusive intellectual property rights to the HEDIS® measures. No other organization is licensed or authorized to administer HEDIS® measures or provide HEDIS® data extracts on behalf of CMS for this purpose. In addition, NCQA's AI enhancement work is inseparable from the MOC review function because it requires access to NCQA's proprietary scoring methodology and HEDIS® data.

The program management and reporting tasks are integral to and inseparable from the MOC review and HEDIS® data collection functions. Separating these tasks would create inefficiencies, introduce coordination risks, and undermine the integrity of the MOC review process, which requires a single accountable entity with direct access to NCQA's proprietary scoring methodology and CMS-established standards. Therefore, no other FSS contractor could perform even a portion of the work.

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. (GSAM/R 538.7104-4).

4. Market Research:

Market research was not conducted because NCQA’s involvement in the contract is established by statute and regulation. Section 1859(f)(7) of the Social Security Act and 42 CFR §§422.4(a)(1)(iv), 422.101(f), and

422.152(g) require that each MAO offering a SNP must submit a MOC to be approved by NCQA. Therefore, NCQA is specifically designated as the entity responsible for reviewing and approving SNP MOCs. No other organization is authorized by law to perform this function. This contract also supports the collection of NCQA’s proprietary product MA HEDIS® measures for SNPs at the plan benefit level (PBP). Under Task 3, the contractor will assist in the collection of PBP-level quality improvement data, in this case HEDIS®, as required of SNPs at 422.152(g)(1). CMS reviewed the applicable Federal Supply Schedule and confirmed that no other schedule holder is authorized or capable of performing the statutorily-designated MOC approval function or providing NCQA's proprietary HEDIS® measures. The program management and AI enhancement tasks are integral to and inseparable from the core statutory functions and therefore do not require separate market research.

5. Actions to Increase Competition:

CMS cannot take any actions to increase competition without congressional actions to revise section 1859(f)(7) of the Social Security Act, followed by rulemaking by CMS to amend 42 CFR §§422.4(a)(1)(iv), 422.101(f), and 422.152(g). CMS will continue to monitor whether legislative or regulatory changes occur that would enable competition, and, if such changes occur, CMS will pursue competitive acquisition of these requirements at the earliest practicable opportunity.

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:

The Independent Government Cost Estimate (IGCE) was created by the procurement team using both current and historical data regarding the types and numbers of labor hour and Other Direct Costs (ODCs) required to perform the requirements described in the Statement of Work (SOW). The Technical Evaluation Panel (TEP) will evaluate the quote from NCQA using the team’s knowledge of the current contract and labor mix required to perform the work, as well as knowledge of any changes affecting the requirements.

The evaluation methodology to be used will be described in the solicitation.

Ordering activities are not required to make a fair and reasonable price determination for FSS products, services, or solutions at the order level or BPA level as FSS contract pricing has been determined fair and reasonable. However, as certified cost or pricing data will not be required for this acquisition since it is for commercial services, the CO will use price analysis to verify that the overall price quoted is fair and reasonable and may require data other than certified cost or pricing data provided by the offeror if needed to make that determination.

Contracting Officer / Date ontracting OfOfOfOffOfOfOfOfOfOfOfOfffOOfOfOOfffOfffOffOfOfOfffffffffffifffffffff cer Representati

7/20/2026

Taylor S Kasky 7/23/2026

Dawn R. Wilkins -S Digitally signed by Dawn R. Wilkins -S Date: 2026.08.04 14:54:50 -04'00'

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

Lyandra Emmanuel / Date

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

_____N/A______________________________________________ Name / Date

5. Office of Small and Disadvantaged Business Utilization

_____N/A____________________________________________

Name / Date

6. OGC Legal Review

____N/A_____________________________________________

Name / Date

7. HHS Competition Advocate Approval

__________N/A_________________________________________ Name / Date

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______________________________________________ Name / Date

Lyandra Emmanuel -S Digitally signed by Lyandra Emmanuel -S Date: 2026.08.19 12:15:23 -04'00'