JA_LSJ_Final_.pdf

FEDERAL SUPPLY SCHEDULE LIMITED-SOURCES JUSTIFICATION

Acquisition Title: Performance Metrics Database & Analytics (PMDA) Extension Agency: Center for Medicare and Medicaid Services Acquisition Year: 2024 Author: Aaron Nadeau, COR

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: $659,487 Funding Source (s): 1072 – Performance Metrics and Database Analytics (PMDA)

Name of Proposed Contractor(s):

Customer Value Partners (CVP) 3701 Pender Drive, Suite 200 Fairfax, VA 22030

2. Description of Supplies or Services:

The estimated value of the proposed action, including all options is $597,631. This is based on an IGCE to negotiate, incorporate and fund an of two (2) months, and the required optional transition period remaining priced as is on current contract. In addition, The program office requests the negotiation of an additional two (2) week extension of the current PMDA contract (to be named CLIN 00008, SLIN 0008AA and 0008AB) of the subject contract, to allow the contractor, CVP to provide O&M and Development support from September 1, 2024 through September 14, 2024, .The program office also requests the creation of an optional two (2) week extension of period of performance for additional development and operations & maintenance. This would be from September 15, 2024 through September 29, 2024 and would be CLIN 0009/SLIN 0009AA and 0009AB. As a result of the requested extension of the Option Period 4 period of performance, the period of performance for the optional Transition Out Period (CLIN 0006AA) from will be revised from 6/30/2024-9/29/2024 (currently) to either September 15, 2024- November 15, 2024 or September 30, 2024 through November 30, 2024.

The estimated cost breakdown across the CLINS is as follows:

CLIN/SLIN Description Period of Performance Dollars 0007AA Extension Period I O&M 6/30/24-8/29/24 $244,184 0007AB Extension Period I

Development 6/30/24-8/29/24 $167,760

CLIN 0007AA Extension Period II O&M 08/30/24 – 09/14/24 $61,939 CLIN 0007AB Extension Period II

Development 08/30/24 – 09/14/24 $30,904

CLIN 0008AA Extension Period III O&M

- Optional

09/15/24 – 09/29/24 $61,939

CLIN 0008AB Extension Period III Development - Optional

09/15/24 – 09/29/24 $30,904

The requested extension period of two (2) additional months is needed to complete the PMDA scope of work.

The requested additional extension periods will be incorporated to cover the eventuality of CMS requiring additional time to complete a competition among small businesses for a new vendor/contractor for the PMDA work, and to provide additional time for development services for changes that are currently under development between CVP and CMS. -- The CVP contract has been funded to support maintenance and operations of the only IT system that supports Medicaid Section 1115 demonstration operations. The system is called Program Metrics Database and Analytics (PMDA) system. These items include the development of a tool, including the capture of new data elements, to allow for SDG to address a growing backlog of demonstration applications.

Addressing this backlog is a commitment made by the Group director of SDG to the CMS Administrator, the Office of Management and Budget, and the Domestic Policy Council. Additionally, SDG is updating their budget neutrality policy and subsequently adjust the budget neutrality workbook and process within PMDA. States must begin the migration to an updated workbook by the 3rd quarter of calendar year 2024. Given this timeframe, SDG needs CVP with their expertise on the budget neutrality process to train and support the states as they undertake this transition. The contract provides among other things two releases per year to update PMDA functionality. The next and last planned IT release under this contract is June 24, 2024. Two tasks that need to be completed before the end of this contract include:

1) Work planning tool & related data – This task requires adaptation of PMDA to collect data and populate a flexible work planning tool that adequately supports CMCS ability to manage priorities and workflow across the entire Medicaid section 1115 demonstration application portfolio. This is a new requirement as of late March, 2024. It involves collecting business requirements from CMS team, defining and developing new data elements, building these elements into PMDA, building the workplan management tool and the capacity to auto-populate it from PMDA data, and supporting user adoption through training and other technical assistance. This capability is critical to a commitment made by the newly hired CMCS, State Demonstrations Group (SDG) Director to the CMS Administrator, OMB and the Domestic Policy Council to help address the growing backlog of demonstration applications which include state innovation efforts to address several of the Administration’s immediate Medicaid policy priorities.

SDG needs a plan to address the backlog of demonstration applications to satisfy CMS leadership, the Office of Management and Budget, and the Domestic Policy Council by 1st quarter of calendar year 2025.. It is important that the current PMDA vendor provides the work planning tool and additional data elements because of their knowledge of the demonstration process and SDG work procedures. A new vendor would not have time to learn the processes and then develop and implement a solution that will allow SDG to meet this deadline.

2) Budget neutrality monitoring workbook template and state technical assistance—This task, which is not a new task but has been delayed due to conditions not under the control of the contractor or the CMS SDG, requires completing the necessary operational steps for obtaining OMB approval of the revised Medicaid section 1115 budget neutrality monitoring workbook template. This template is needed for state reporting of financial parameters and performance against those parameters to demonstrate on a regular basis that the state’s demonstration is remaining budget neutral. The updated parameters concern demonstration types such as addressing services needed for incarcerated individuals who otherwise do not have Medicaid coverage, and addressing health related social needs (HRSN) which are otherwise not coverable under Medicaid. This task also includes providing expert technical assistance to individual states on the financial reporting requirements associated with state adoption of this revised workbook.

Every state with a section 1115 demonstration (there are 49 states), most migrate from quarterly to annual reporting, and most states must begin this migration to this updated workbook by Quarter 3 in calendar year 2024.

The current PMDA vendor implemented the original budget neutrality workbook and provided training on its use to all states with a demonstration. The current vendor also has several years of help desk support to states as they access and upload the budget neutrality workbook. The institutional knowledge that the current vendor possesses as it relates to rolling out the budget neutrality workbook and will provide increased efficiency for CMS, as well as making the process as smooth as possible for our partners with the State Medicaid Agencies.

Full three month IT transition in optional task is required/needed -- The last planned IT release under this contract is three months before the last option year under this contract ends. CMS is conducting a competitive small business procurement to meet future IT business needs of the Medicaid Section 1115 demonstration program.

The CVP contract includes an optional task that CMS intends to exercise for a full three-month IT transition from CVP (not a small business) to the small business awardee. This full three months of transition is needed to successfully support significant knowledge transfer.

Total contract extension required/needed is two months -- In total, rather than this contract ending on September 29, 2024, the work described above would require extending the end date of this contract by approximately two months to November 29, 2024.

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

The completion of both of the tasks, 1) and 2) noted above, are necessary to meet time sensitive expectations established by the newly hired Director of the CMCS SDG with the CMS Administrator, OMB, and State Medicaid Directors.

Concerning task 1 above, the review; consultation with subject matter experts, Office of General Counsel and OMB ; negotiations with state officials and drafting of complex documents to codify the agreement between CMS and State Medicaid Offices is very complex and time consuming. The state demand for Medicaid section 1115 demonstration authority is growing significantly, with the number of applications increasing in complexity and by more than 35 percent by volume in recent years. These increases are driven primarily by the unyielding incidence of mental health decline, substance use disorders and homelessness across states. Addressing these issues as soon as possible is both important to the well being of the state’s low income populations and to getting better control over the state’s costs associated with the needs of these individuals and their families. Addressing these needs is also a high Medicaid priority for this Administration. However, due to limited resources, CMCS SDG now has a significant backlog of applications and it is taking an average of 15 months to complete the necessary steps to achieve approval, and Governors are expressing their concerns to senior Administration officials. The data being collected and auto-populated into this flexible workplan is critical to establishing informed priority setting and understanding about where opportunities reside for efficiency throughout the review cycle. These steps have been identified as foundational to improving the length of time for demonstration approvals and for making meaningful progress toward reducing the application backlog.

The CVP contractor is the only vendor that has developed, maintained and updated PMDA, and has deep insight in the 1115 review processes. If this contract is not extended by approximately two months, the completion of this task will be delayed by approximately 6 months to permit necessary knowledge transfer to the new small business awardee and the completion of IT development and user adoption activities such that the workplan management tool can support the improvements needed in application reviews. This delay will seriously incumber needed progress on addressing the 1115 application backlog.

Concerning task 2 above, it is critical to fiscal integrity of the Medicaid section 1115 demonstration program, which represents approximately 35 percent of all federal outlays under Medicaid, to provide proper support to states in their accounting of costs that comprise the assessment of budget neutrality. This Administration is approving important new services for previously uncovered vulnerable populations under 1115 demonstration authority that states must claim and then reflect in their budget neutrality financial reporting.

The current budget neutrality workbook template does not adequately prompt data entry for these new demonstration types. Further, the updated workbook template is tied to an important efficiency improvement for states and CMS which is allowing states to report budget neutrality annually. CMS and states are eager to realize this efficiency in time and resources.

There has been a multiple month delay out of the control of CMCS SDG in acquiring OMB approval under the Paperwork Reduction Act so that use of the update workbook template could proceed.

The CVP contractor is the only vendor that has developed, maintained and updated these budget neutrality tools, and that holds necessary vendor expertise to support states and CMS by supporting technical assistance that assures this financial reporting is accurate. CVP has deep insight in 1115 budget neutrality reporting and review. If this contract is not extended by approximately two months, the completion of this task will be delayed by approximately 6 months to permit necessary knowledge transfer to the new small business awardee, the completion of the PRA process to approve the workbook template, and the readiness to provide technical assistance to states in their adoption of the new workbook template. This delay will seriously incumber the implementation of internal controls associated with financial reporting associated with 1115 demonstrations.

☐ 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:

Market resource has been completed to identify potential small businesses to solicit for the PMDA re-compete requirement. The acquisition team met in person with six small businesses to determine interest and capability in the small business community. The acquisition team determined that there is the capacity and interest for multiple bids by small businesses. The acquisition team also used information provided by the small business community that were interviewed to refine the requirements in the SOO and to enhance the current program processes and system information that will be provided with the SOO. As a result of the market research completed for the PMDA re-compete requirement, CMS has determined that this requirement will be competed among eligible small businesses.

5. Actions to Increase Competition:

A new PMDA contract with an anticipated start date of September 1, 2024 is intended to be competed in the Summer of 2024 as a targeted requirement among small businesses identified during market research.

6. Any other facts supporting the justification: N/A 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

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 contractor proposed pricing will be compared to the contractor’s GSA price list as well as the Independent Government Cost Estimate, market research, and historical data to include a comparison with the rates established on their current GSA 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.

Contracting Officer / Date

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_______________________________________________