JA LSJ LFO FSS1_Redacted.pdf

To date, a total of approximately $93,112,929 has been obligated.

The current period of performance is:

Base Period: September 1, 2021 through December 31, 2023 Option Period 1: September 1, 2023 through August 31, 2024 Option Period 2: September 1, 2024 through August 31, 2025 Option Period 3: September 1, 2025 through August 31, 2026

The proposed LFO period of performance is:

Base period: September 1, 2026 through August 31, 2027 Transition Out: June 1, 2027 – August 31, 2027

Program Background Section 1899 of the Social Security Act established the Shared Savings Program, which promotes accountability for a patient population, fosters coordination of items and services under Medicare Parts A and B, encourages investment in infrastructure and redesigned care processes for high quality and efficient health care service delivery, and promotes higher value care. The Shared Savings Program is a voluntary program that encourages groups of doctors, hospitals, and other health care providers to come together as an ACO to lower growth in expenditures and improve quality. An ACO agrees to be held accountable for the quality, cost, and experience of care of an assigned Medicare FFS beneficiary population. ACOs that successfully meet quality and savings requirements share a percentage of the achieved savings with Medicare.

On March 23, 2010, the Patient Protection and Affordable Care Act (Pub. L. 111–148) was enacted, followed by enactment of the Health Care and Education Reconciliation Act of 2010 (Pub. L. 111–152) on March 30, 2010, which amended certain provisions of Public Law 111– 148 (hereinafter collectively referred to as “the Affordable Care Act”).

Section 3022 of the Affordable Care Act amended Title XVIII of the Social Security Act (42 U.S.C. 1395 et seq.) by adding section 1899 to the Social Security Act to establish the Shared Savings Program to facilitate coordination and cooperation among health care providers to improve the quality of care for Medicare FFS beneficiaries and reduce the rate of growth in expenditures under Medicare Parts A and B. See 42 U.S.C.

1395jjj.

The Shared Savings Program regulations are codified at 42 CFR part 425. The final rule establishing the Shared Savings Program appeared in the November 2, 2011, Federal Register (Medicare Program; Medicare Shared Savings Program: Accountable Care Organizations; final rule (76 FR 67802). Several subsequent rules provided updates to the Shared Savings Program, and additional information on the statutory and regulatory basis for the program is provided on the Shared Savings Program, Program Statutes & Regulations webpage.

https://www.govinfo.gov/link/plaw/114/public/10https://www.federalregister.gov/citation/81-FR-77008

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

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

As stated above and detailed below, the Center for Medicare (CM), Performance-Based Payment Policy Group (P3) requires the continuation of services with RTI to ensure successful completion of actions outlined below:

A. SAS to Python Migration

In 2025, CMS mandated that all SAS operations be transitioned to open-source software (e.g., Python) with a December 2026 completion date. RTI has spent the past year converting datasets and code accumulated since the program's inception in 2012 from SAS to Python to comply with this requirement.

This transition includes:

Parallel programming in SAS and Python to test efficacy Maintaining current operations to produce over 3,000 reports annually Independent validation of all converted specifications and code Quality assurance testing across multiple data environments (IDR Snowflake, IDR Cloud, etc.)

RTI is currently on schedule and on budget to complete the SAS to Python transition before the end of 2026.

However, the original recompete schedule overlaps with this tremendous data conversion effort, creating significant complexity and risk. A competitive transition during this critical period would require:

The new contractor to complete the SAS migration while simultaneously learning RTI's existing systems

Dual knowledge transfer (operational processes AND migration methodology) Potential delays to the December 2026 migration deadline Risk to ongoing operations serving 12+ million beneficiaries

Awarding an LFO allows RTI to complete the migration prior to any transition, significantly reducing risk and ensuring continuity of mission-critical operations.

B. Rulemaking Implementation and Policy Development

A September 1, 2026 contract transition would impact our ability to conduct rulemaking for the Shared Savings Program through the Calendar Year 2027 Physician Fee Schedule rule, as the transition would occur after completion of the proposed rule and as development of the final rule commences. This puts at risk the development and implementation of policies that advance the Administration's healthcare strategy.

During the proposed LFO period, the contractor will be responsible for:

- Developing and implementing ambitious regulatory reforms designed to accelerate accountable care service delivery, including:

Benchmarking adjustments Accountable Care Prospective Trend refinements Revisions to increase ACO participation and savings Refinements to the assignment algorithm to reduce gaming Interoperability assessments Updates to quality reporting requirements supporting transition to digital quality measurement

- Operationalizing new policies effective with Performance Years 2025 and 2026:

Prepaid Shared Savings option Extreme and uncontrollable circumstances policy revisions (cyberattacks, ransomware, malware) Improved quarterly prediction methodology ACO PC Flex Model integration into financial reconciliation

A transition during this period would disrupt policy implementation and create inefficiencies in translating regulatory changes into operational specifications.

C. ACO PC Flex Model Integration

Effective January 1, 2025, the CMS Innovation Center began testing the ACO PC Flex Model within the Medicare Shared Savings Program (Shared Savings Program). In Performance Year (PY) 2025, ACO PC Flex Model ACOs were incorporated for the first time into Shared Savings Program financial reconciliation calculations.

This integration requires:

Extension of beneficiary assignment methodology to the CMS Certification Numbers, Tax Identification Numbers, and National Provider Identifier levels

Development of new Prospective Primary Care Payment (PPCP) calculations Creation of ACO PC Flex County Rate Book Implementation of complex payment mechanisms and repayment calculations Coordination with multiple CMS contractors and systems

RTI has developed these new methodologies and is positioned to execute the first full year of operations during the LFO period. A transition would require the new contractor to learn and execute these complex, newly-developed processes while they are still being refined based on initial operational experience.

D. Critical Financial Operations

The contractor will calculate annual performance payments expected to exceed the $4.1 billion paid to over 475 ACOs for Performance Year 2024. These calculations directly impact:

Medicare Trust Fund savings (estimated at $2 billion to $6 billion against benchmarks annually) Payment accuracy for over 650,000 healthcare providers Healthcare delivery for 12+ million Medicare beneficiaries

The contractor will also calculate and process:

Advance Investment Payments totaling approximately $7 million annually for 25+ ACOs Prepaid Shared Savings Payments on a quarterly basis Over 25,000 quarterly and annual performance reports

Any disruption to these operations could affect program integrity, provider payments, and beneficiary care.

E. Operational Continuity and Institutional Knowledge

RTI has been successfully performing ACO PAOS services for over ten years and has demonstrated high-quality performance throughout. The contractor maintains:

Deep institutional knowledge of program evolution since 2012 Established relationships with CMS staff, ACOs, and other CMS contractors Validated systems and processes for all program functions Expertise in the complex regulatory and statutory framework

A LFO will preserve this expertise through the critical migration and policy implementation period, ensuring:

Continuity of operations for mission-critical functions Successful completion of the SAS migration Smooth implementation of new policies and the ACO PC Flex Model Preservation of institutional knowledge for transfer to future contractor

F. Resource Optimization

Significant CMS resources within the Performance-based Payment Policy Group are currently dedicated to:

Supporting SAS to Python migration Implementing ACO PC Flex Model Developing and implementing major policy reforms Managing ongoing program operations

These resource demands limit the staff available to support conducting a new solicitation and managing a potential transition during this critical period. An LFO allows CMS to:

Focus resources on successful policy implementation

Ensure migration completion Plan and execute a more effective future competition Avoid transition risks during a period of maximum operational complexity

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 original GSA task order (GS00F354CA, task order 75FCMC21F0064) was competed on the GSA MAS SIN 541611 in 2021. 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. Therefore, ordering activities are not required to make a separate determination of fair and reasonable pricing, except for a price evaluation as required by 8.405-2(d). Based on RTI’s strong track record of performance with this work, CMS believes that RTI is still capable of completing this work to ensure successful implementation of this important work. The Contracting Officer will ensure the level of effort, mix of labor proposed, and total price is reasonable for the modification.

5. Actions to Increase Competition:

Once the logical follow-on is complete, there will no longer be any barriers that lead to this exception to fair opportunity. At the completion of the new 12-month period of performance, it is anticipated that the NSA work will be successfully implemented such that a competitive procurement can be conducted without risk to CMS’ compliance with the statute.

6. Any other facts supporting the justification:

Not applicable.

RTI represents the best value to the Government.

Malissa Shin - Contracting Officer / Date

3. CMS Competition Advocate Approval

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

Lyandra Emmanuel – Competition Advocate / Date

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

Douglas Bergevin / Date

5. Office of Small and Disadvantaged Business Utilization

___N/A______________________________________________ Name / Date

6. OGC Legal Review

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7. HHS Competition Advocate Approval

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8. Senior Procurement Executive (SPE) Approval

Based on the foregoing justification, I hereby confirm the circumstances described above apply and approve

MALISSA M. SHIN -S

Digitally signed by MALISSA M.

SHIN -S

Date: 2026.03.19 14:08:04 -04'00'

Lyandra Emmanuel -S

Digitally signed by Lyandra Emmanuel -S Date: 2026.04.10 16:35:06 -04'00'

DOUGLAS D. BERGEVIN -S

Digitally signed by DOUGLAS D. BERGEVIN -S Date: 2026.04.12 22:40:03 -04'00' the Limited Source Justification.

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