JA_PECOS_Data_192064.pdf

JUSTIFICATION FORAN EXCEPTION TO FAIROPPORTUNITY

Acquisition Title: Provider Enrollment Chain and Ownership System (PECOS) 2.0 Data Bridge

Agency: Centers for Medicare & l\ledicaid Services

Acquisition Year: 2019

Author: Scott Roache

Description of Action:

A. Nature

a. _x_ New Requirement b.

Follow-On Order

c. _ Modification of Existing Purchase Order / Contract Number

B. Order Against . a. (HHSN316201200011W)lVultipleAward lDlQContractNumber

C. Contract Type

a. X Firm-Fixed Price

b. _ Time and lVaterials

c. _ Cost Plus Fixed Fee (CPFF) i, _ Term ii, _ Completion d, -Cost

Plus Award Fee (CPAF) e, _ Other:

D. Projected Cost / Price of contract (Base & All Options): $9,221,680

E. The total estimated value of the proposed sole source action (for modifications only):

F. Funding Source (s): 002975

G.

Basis for Approval (Far 6,303-1(d)

_x_: lndividual Basis

_: Class Basis

2. Description of Supplies or Services:

Cl\4S has an immediate need for the ongoing development of the PEC0S 2.0 redesign which includes:

Program l\lanagement Data Analysis Data Modeling

Data Migrafion (ETL)

Contractor services ¡s needed to review existìng data model and design efficient data model foìlowing the CMS Data Architecture, Standards and guidelines using CMS prefened data modelling software. ln addition, CMS needs support for the review of PECOS 2.0 user interface design, business requirements, workflows and interfaces. Specifically the design and development of new data model to support all aspects of PECOS 2.0 which, includes but not limited to user intefaces, data exkacts, data marts, business intell¡gence reports, internal and external application interfaces, The newly designed data model should accommodate historical data without losing information stored in current PECOS O&l\¡. Contractor services is also needed to develop a data dictionary; ETL mapping from existing PECOS O&M to new data modeli data mapping from newly developed data model to user interface, data marts, data extracts, business intellìgence reports, ìnternal and external ìnterfaces.

3. Authority and Rationale:

The Contracting Officer shall give every awardee a fair opportunity to be considered for a delivery/task order exceeding $3,000 unless one of the folìowing statutory exceptions applies. FAR 16.505(bX2). Mark the applicabìe exception:

_X_ The agency need for the supplies or services is so urgent that providìng a fair opportunity would result in unacceptable delays IFAR 16,505(bX2)(i)(A)];

ln June 2017, CMS awarded conhact GS-35F-4717G I Task Order # HHSIV]-500-2017-00055G/

GS-35F-4717G under the GSA lT 70 Schedule to provide PECOS 2.0 development services for redesign of the PECOS system

The objective of the PECoS 2,0 system redesign is to efficiently decrease processing time associated with provider enrollment, increase data accessibility & quality and promote program integrity.

The PECOS 2,0 system will have a flexible architecture that allows it to be modified to support the ever-changing healthcare environment and will focus on reducing the provider burden by providing an intuitive user interface and user experience w¡th the goal of promoting 100% online adoption for enrollment submission, while also standardizing and streamlining administrative processing, and supporting increased interconnectivity.

CMS determined that ¡t was not in the governmenl's best interest to exercise the option on the cun'ent task order, Rather, the Government will re-compete the revised PECOS 2.0 requirement with a planned award date of July 2020.

After careful evaluation, it was determined that the most effective opt¡on to reduce program impact as a result of development delay was to establish two sole source bridge contlacts to keep the project moving, salvage the existing work from the current PECOS 2,0 task order, and continue with limited development that focused on end-user workflows, data migration, and maintaining the infrastructure work for twelve months, CMS is moving forward with awarding a twelve-month bridge task order to CGI Federal, under the NIH NITACC vehicle, w¡thout providlng for the fair opportunity procedures, in accordance with the Exception to Fair 0pportunity procedures descr¡bed at FAR 16.505 (bX2X¡)(A)

The PECOS 2.0 redesign is cr¡tical to the Center for Program lntegrity's mission and a failure to continue progress on the PECOS 2.0 requirement will result in further delays that impact program eff¡ciency, program integrity, and provider burden as follows:

. Delay in efficiently supporting and streamlining enrollment operations for the 1.6M lVedicare FFS enrollment changes each year, and new operations related to new payment models and programs such as Medicare D¡abetes Prevent¡on, and 0pioid Treatment.

. Delays in CMS' ability to collect information needed to implement upcoming rule requirements related to Provider Enrollment program integrity enforcement authority.

. Further delays in enhancing Cl\4S' ability to collect, associate, and maintain enrollment information that supports detecting fraud, waste and abuse, which can potentially cost the government millions of dollars.

. Delay in efficiently supporting Medicare and l\¡edicaid alignment through reduced duplication of data collection, and more sheamlined sharing of information between programs, . Continued burden to the provider community due to excessive duplicate data entry, and less usability - PECOS 2.0 will be more intuitive and user-friendly. Additionally, this will delay efforts to transition community to all online enrollment, Cunently - 50% of all applications are online, but MACs can process online applications at a rate of 2:1.

. PECOS 2.0 will significantly reduce any delays in providing services to beneficiaries as a result of delays in processing by adding automation for processing the most common low+isk applications.

. The additional enhancements to the legacy PECOS that are required to maintain the most basic level of operations and statutory or regulalory compliance will continue to be costly to CMS, and will be unusable by PECOS 2.0, and result in "throw away" code,

4. Provide a statement of the act¡ons, if any, the agency may take to remove or overcome any baniers that led to the exception to fair opportunity before any subsequent acquisit¡on for the supplies or services is made: The

Government wilì competitively acquire these services by July 2020.

5, State any other facts supporting the justification: N/A

Approvals:

Program Office Certification. This is to certify that portions of this justifìcation have been developed by the undersigned program office personnel, including supporting information and/or data vetifying the Government's minimum needs, schedule requirements and other rationale for Exceptions to

Fair 0pportunity, which form tho basis for this justification, Digitally sìgned by Bradley S.

Bradley S. Roache -S Roache -S Date: 2019.07.16 16r19r34 -04'00'

Contracting Officer Representative (COR) / Date

Diqitally sìgned by Richârd P

Richard P. Gilbert -S G¡lbert -S Dateì 201 9.07.'16 16r24r25 -04'00'

Program/Project Manager (P/PM) / Date

Best Value Determination. By my sìgnature below, after review of the relevant documents, I have determined that the order subject to this Justification represents the best value for the Government as set forth in FAR 16.505(b)(2)(ii)(B)(5), and const¡tutes a fair and reasonable price. The basis for my determination is as follows:

The Contracting Officer will obtain certified cost and pricing data as there are no exemptions applicable, FAR 15,403-1 (a) (3) requires cost analysis to be performed when obtaining certified cost and pricing data.

The Contracting Officer will perform cost or price analysis by using the analysis technique described at FAR 15.404-1(c). Additionally, a price analysis as described in FAR '15,404-1 (b)(2)(v) will be used to determine if the price compared to the IGCE is fair and reasonable.

Contracting Officer Certification: This is to certify that the justifìcation 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.

Tonya D. Anderson -S B:llijä,';';,:îli,'#å1?¿iå3:'*".

Contracting Officer / Date

Additional OAGM Approvals:

lhereby confirm the circumstances described above apply and approve the justification for

Exceptions to Fair Opportunity, Diqitally signed by Aaron M.

Aaron M. Blackshire -$ elåckshire-s Dateì 2019.07.18 07:34:29 -04'00'

OAGM Division Director / Date

Digitally signed bY LYandra

Lyandra Emmanuel -$ emmanugl -s- ^.Date: 2019.07.22 15:53:23 -0400'

OAGM Group Director/ Date

Head of Contracting Authority (HCA)Approval

I hereby confirm that the circumstances described above apply and approve this Justification for

Exception(s) to Fair Opportunity, Melissa A.

Starinsky -S

Dlglt.lly r¡sêd by l¡telß3. À 9t3dnrlry -S oate: 2019.6s I 332:49 -910Û

HCA Name / Date

Competition Advocate APProval

I hereby confirm that the circumstances described above apply and approve this Justification.for air Opportunity

79t Name /