JA - Revenue Operations Workflow Payer Compliance - Redacted.pdf

LIMITED-SOURCES JUSTIFICATION

1. Contracting Activity: Department of Veterans Affairs (VA)

Office of Procurement Operations Technology Acquisition Center 23 Christopher Way Eatontown, NJ 07724

2. Description of Action: The proposed action is for a sole-source, Firm-Fixed-Price Task

Order to be issued under General Services Administration (GSA) Contract GS-00F- 146DA with Huron Consulting Services, LLC (Huron). This action is required to provide the VA Veterans Health Administration (VHA) Office of Finance (OF) Revenue Operations (RO) with the required support in three critical areas, which include Revenue Operations Workflow Functionality, Claims scoring, reporting, and payment efficacy, and Managerial and Technical Process Optimization. In order to obtain this support, VA requires the Huron Workflow Tool (WFT) software licenses, maintenance, sustainment, and associated technical support for the OF RO. This effort is being conducted under the GSA Multiple Award Schedule (MAS) Program. The proposed effort will be awarded under the GSA MAS contract to Huron Consulting Services, LLC, 550 West Van Buren Street, Chicago, IL 60607, (312)-583-9701.

3. Description of the Supplies or Services: VHA OF RO Program Management Office has a requirement to ensure VA’s RO remain operational. The RO and its seven regionally aligned Consolidated Patient Account Centers rely on the existing workflow management and payer compliance information technology business tools to provide industry modeled automated technologies to sustain and continuously improve revenue cycle activities in support of healthcare revenue collections.

This action will provide the OF RO with the support necessary to sustain mission-critical functions across three interdependent areas. The first, RO Workflow Functionality, encompasses the automated work queue management, task routing, denial tracking, and underpayment resolution capabilities that enable RO billing and follow-up staff to prioritize and adjudicate claims across the enterprise, which depend on real-time data feeds from VA-unique systems including Veterans Health Information Systems Architecture (VistA) and the Corporate Data Warehouse (CDW). VistA interoperability with the Huron WFT relies on VA's legacy Health Level 7 (HL7) v2.x-based, non-Fast Healthcare Interoperability Resources (FHIR) messaging architecture; the platform must support custom middleware to bridge this architecture to modern integration standards.

The second area, Claims Scoring, Reporting, and Payment Efficacy, requires the Huron WFT's analytical and intelligence capabilities to score claims by complexity and collectability, generate performance reporting against VA-specific payer agreements and over 100 insurance modeling arrangements, and measure payment outcomes to identify systemic billing gaps and recovery opportunities that directly inform OF RO's financial strategy. The third area, Managerial and Technical Process Optimization, relies on the tool's configurable dashboards, productivity tracking, and workflow analytics to provide revenue cycle leadership with the operational visibility needed to manage staff performance, meet VA financial reporting requirements, and continuously improve process efficiency across a geographically distributed workforce. To sustain these

Revenue Operations Workflow, Payer Compliance, and Technical Process Optimization

VA-26-00042471

capabilities, VA requires the continued procurement of Huron WFT software licenses, maintenance, sustainment, and associated technical support, which together ensure the platform remains integrated with VistA and CDW, compliant with applicable VA security and Authority to Operate (ATO) requirements, and operationally current to meet the evolving billing, regulatory, and reporting demands of the OF RO.

VA requires a contractor to provide project management and comprehensive technical, operational, and analytical support across three core areas: revenue workflow functionality, claims scoring and payment analysis, and managerial and technical process optimization. To meet these requirements, the contractor must deliver shippable software products and associated operational support for the Revenue Operations Sub-Product Line under the VHA Finance Product Line, encompassing the full lifecycle of design, development, testing, integration, and architectural alignment, as well as both planned and unplanned operations and maintenance activities. All services must be performed in accordance with Development, Security, and Operations principles and Scaled Agile Framework methodologies, with cross-functional Agile teams furnished by the contractor to develop and sustain platform capabilities that improve system scalability, availability, reliability, and measurement of business value.

The contractor must comply with all VA and Office of Information and Technology policies, including the Product Line Management Playbook and the Veteran-Focused Integration Process Guide or VA-approved Release Management processes, and apply modern development and operational practices to enhance VA business and customer experience outcomes.

The scope of required support also includes the provision, installation, maintenance, migration, and sustainment of commercial software components and licenses necessary to operate VA's automated payer compliance and workflow management tools, including Robotic Process Automation (RPA) software, hosted on VA servers with a required transition path to VA cloud environments. The RO Workflow functionality specifically must also be migrated from internal servers and be delivered as a Software-as-a-Service solution or hosted within the VA Enterprise Cloud (VAEC) on either AWS or Microsoft Azure, and fully operational during performance. The Contractor shall also be responsible for developing a cloud migration plan based on the selected cloud hosting environment to VAEC. Additionally, the contractor must provide continued development, configuration, modeling, maintenance, and sustainment services for RO information technology tools, including healthcare insurance modeling across more than 100 payer agreements, as well as consulting services in support of revenue cycle business operations and practices, and the delivery, updating, and maintenance of training materials associated with Revenue Operations technology and business processes.

The period of performance for this proposed action consists of 1 12-month base period, 1 12-month option periods and 7 Optional Tasks. The base period and option periods shall consist of continuity and maintenance of the current system as well as system training and the development of staffing models and reports. The total estimated value of the proposed action is inclusive of all option periods and optional tasks.

4. Statutory Authority: This acquisition is conducted under the authority of the Federal Supply Schedule Program. The specific authority providing for a limited source award is Revolutionary FAR Overhaul (RFO) 8.401(b) and General Services Administration Manual/Regulation (GSAM/R) 538.7104-3(b)(1)(ii), “Only one source is capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized.”

5. Rationale Supporting Use of Authority Cited Above: The proposed source for this action is Huron Consulting Services LLC. Based on market research, as described in Section 8 of this justification, it was determined that there is no competition among vendors for the required Huron WFT. The previous Task Order was awarded to FavorTech Consulting (FTC) on a sole source basis, as a result of Huron confirming an exclusive teaming arrangement with FTC for the same technical requirements.

VA's revenue cycle operations depend on the Huron WFT and its embedded UiPath RPA platform as a single, inseparable technical environment. The Huron WFT's automation logic, orchestrations, VistA/CDW integrations, and 100+ insurance modeling arrangements are proprietary to Huron and cannot be operated, licensed, or reconfigured on any other platform. No other source is capable of providing this functionality at the required level of quality.

From a financial standpoint, the Huron WFT manages the routing, tracking, and resolution of claims, denials, and underpayments across the enterprise. Without its automated work queue and denial tracking capabilities, billing staff would be forced into manual processes that cannot meet payer timely filing deadlines, placing tens of millions of dollars in annual third-party reimbursements at risk of permanent write-off.

Any alternative solution would require an estimated total cost of $11.5 million for a full transition, including $3.1 million in implementation costs and $2.8 million per year in annual recurring costs sustained in parallel with current operations for a 4-year transition period. These expenditures would occur in parallel with the cost to maintain current operations for an estimated 48-month transition period. These estimates are based on previous acquisition history. The estimated duplicated costs would not be recovered through competition. Furthermore, this system is set to be sunset and transitioned into the Federal Electronic Health Record Modernization effort at a future date.

The operational and patient impact of a transition would be equally significant. VA's revenue cycle workforce, has built deep institutional proficiency around the Huron WFT's workflows, work queues, and reporting tools. A platform transition would require enterprise-wide retraining and would trigger a well-documented productivity decline lasting 6 to 12 months post-implementation, directly increasing aged accounts receivable, slowing claims processing, and reducing the VA's capacity to resolve denial backlogs. These operational disruptions carry downstream consequences for Veterans, including delayed resolution of billing disputes, inaccurate patient liability determinations, and a degraded financial experience for a population that includes a disproportionate share of elderly, disabled, and economically vulnerable individuals.

The compliance and technical barriers to replacement are equally prohibitive. VA's revenue cycle operations must satisfy a uniquely complex regulatory environment encompassing Health Insurance Portability and Accountability Act, Centers for Medicare and Medicaid Services billing requirements, VA Financial Policy, Federal Acquisition Regulation, and over 100 insurance modeling agreements governing third-party payer billing. The Huron WFT has been configured and validated within this framework over the course of its operational deployment of approximately four years. Any replacement solution would arrive as a commercially configured platform with no inherent knowledge of these requirements, necessitating a full reconfiguration, testing, and validation effort during which the VA would face elevated risk of billing errors, inappropriate claim submissions, and audit findings subject to Office of Inspector General, Government Accountability Office, and Congressional scrutiny. Additionally, any replacement system would require a VA ATO before connecting to VA systems, a process that can add months and significant cost to any implementation.

6. Efforts to Obtain Competition: Market research was conducted, details of which are in the market research section of this document. This effort did not yield any additional sources that can meet the Government’s requirements. There is no competition anticipated for this acquisition. In accordance with GSAM/R 538.7104-3(b)(3) this justification will be made publicly available within 14 days of award.

7. Actions to Increase Competition: The Government will continue to conduct market research to ascertain if there are changes in the marketplace that would enable future actions to be competed.

8. Market Research: Market research was conducted by VA Subject Matter Experts (SMEs) via web-based research and independent technical review. From January through June 2026, VA technical experts reviewed comparable COTS revenue cycle and RPA products, including solutions offered by Nthrive, Quadax, and Finthrive, against VA's functional and technical requirements. This review found that while these vendors offer products broadly similar in category to the Huron WFT, none held demonstrated VistA or CDW integration and none had a configured equivalent to VA's 100+ insurance modeling arrangements. Any of these products would require full custom integration development, including the HL7 v2.x middleware necessary to bridge VA's non-FHIR VistA architecture, along with site-by-site configuration across more than 25 facility National Provider Identifiers. VA's review found no evidence that any of these products could meet VA's requirements without the duplication of cost and time described in Section 5.

VA also issued RFI number 36C10B26Q0210 via SAM.gov on February 20, 2026, seeking sources for VA's requirements or other potential commercial solutions. The RFI yielded 12 responses, independently reviewed by VA SMEs against the requirements, Of the 12 respondents, only two — Blue Water Thinking LLC and FavorTech Consulting LLC — were determined capable of meeting all requirements; both proposed the Huron WFT as the foundation of their technical solution. The remaining 10 respondents were determined not capable, specifically , none demonstrated the healthcare-specific technical capabilities required for Revenue Operations, particularly in payer compliance modeling, insurance carrier agreement analysis, revenue-cycle workflow expertise, X12 EDI support, and large-scale RPA integrations. In addition, no respondent demonstrated the VistA interoperability required to support VA-unique integrations, custom middleware needs, or the established data-exchange dependencies between VistA and Revenue Operations systems.

VA's review, which included the RFI record, found that the existing Revenue Operations Workflow Tool (ROWFT) configuration is proprietary to Huron and cannot be reconfigured to operate with any other RPA or workflow platform. Replacing the existing solution would require a duplication of time and cost for a complete redesign and redevelopment, including new integrations between any replacement tool, VistA, the Financial Services Center, and other VA systems as described above. As noted above VA SMEs estimate this effort would require a four-year transition period.

On May 7, 2026 Huron confirmed this teaming arrangement is still active. During follow-up conversation with Huron through June 22, 2026, this teaming arrangement was later confirmed to only apply to GSA Alliant and T4NG2 and if the solicitation was released on any other contract vehicle then Huron would not authorize the use of its ROWFT and would in fact submit its proposal only as the prime contractor for this requirement. On August 6, 2026 an amendment was posted via Contract Opportunities that this requirement would be solicited as a Sole Source under GSA MAS to Huron Consulting Services, LLC.

9. Other Facts: None.

Technical/Requirements Certification I certify that the supporting data under my cognizance, which are included in this justification, are accurate and complete to the best of my knowledge and belief.

Best Value Determination

I hereby determine that the proposed contract action will represent the best value to the Government consistent with FAR 8.404(d). GSA has already determined that the prices on the FSS contract are fair and reasonable. Further price analysis, to include an analysis of proposed level of effort and mix of labor, will be conducted and subsequent negotiations held as necessary. Additionally, price discounts will be sought.

Contracting Officer Certification/Approval

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

Office of General Counsel (OGC) Review

I have reviewed this document and find it legally sufficient, based on the representations set forth in the documents and, if any, attachments. The HCA’s approval is an independently supported decision not wholly reliant on the legal sufficiency determination.

HCA Approval

In my role as Head of the Contracting Activity, based on the foregoing justification, I hereby approve with the acquisition of Huron Workflow Tool (WFT) software licenses, maintenance, sustainment, and associated technical support, pursuant to the authority cited in Section 4 above, subject to availability of funds, and provided that the services herein described have otherwise been authorized for acquisition.