Justification Approval - Federal Supply Schedule_Redacted.pdf

facilitating payment processing for pharmaceutical manufacturers and Part D plans across several key programs, including the Coverage Gap Discount Program, the Manufacturer Discount Program, the Medicare Part B Program for Discarded Drug Rebates, and the Medicare Inflation Rebate Programs for Medicare Parts B and D.

Central to this effort is the Manufacturer Payment Portal (MPP), a secure, web-based platform that enables pharmaceutical manufacturers and Part D plans to efficiently manage invoice payment processing, generate reports, and submit disputes. All financial transactions are conducted through Automated Clearing House (ACH) processing, ensuring strict adherence to established national financial standards.

This effort also supports a public-facing website and a dedicated help desk that offers comprehensive assistance to pharmaceutical manufacturers and Part D plans. These services encompass user onboarding, invoice distribution and payment reminders, technical support, and the prompt resolution of manufacturer disputes — ensuring seamless program participation and operational continuity.

The current contract is a General Services Administration (GSA) Multiple Award Schedule (MAS) order (GS-35F-0462V/75FCMC21F0076) awarded using fair opportunity to Palmetto GBA with a total period of performance from August 8, 2021, to August 7, 2026. The current contract period runs from August 8, 2025, to August 7, 2026. To date, the total financial obligations under this contract amount to

This justification seeks approval to issue a two-year logical follow-on to the incumbent contractor, Palmetto GBA, for the CDGP requirement. The extension is necessary to ensure continuity of payment operations and to efficiently execute two concurrent modernization initiatives during a defined bridge period: (1) the integration of the Global Benchmark for Efficient Drug Pricing (GLOBE) program into the Manufacturer Payment Portal (MPP), and (2) the migration of the MPP infrastructure to the CMS Amazon Web Services (AWS) Cloud Enclave.

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 GSAM 538.7104-3. Mark the applicable exception and for each discuss how the cited authority applies in accordance with GSAM 538.7104-3.

An urgent and compelling need exists, and following the procedures would result in unacceptable delays (GSAM 538.7104-3(b)(i)));

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 (GSAM 538.7104-3(b)(ii))); 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 (GSAM 538.7104-3(b)(iii)).

The original GSA MAS order (GS-35F-0462V/75FCMC21F0076) was awarded through fair opportunity procedures and was not previously issued under sole-source or limited-source authority. The new work under this follow-on is a direct continuation of the same program scope — CGDP payment processing operations

— with added modernization tasks that are operationally tied to the existing contract environment. Awarding this work to the incumbent contractor is in the interest of economy and efficiency for the following reasons:

1. GLOBE Program Integration: The integration of the GLOBE program into the existing MPP requires familiarity with the current payment processing environment, system architecture, and operational workflows developed under the original contract. Leveraging the incumbent's existing knowledge of the system avoids schedule and performance risk of GLOBE program meeting its statutory deadline of January 2028, given any new contractor would require ramp-up and discovery time to pick up where the previous contractor left off.

2. CMS AWS Cloud Migration: All server infrastructure supporting this contract currently resides within the existing contract environment. Executing the cloud migration under the follow-on contract — rather than through a separate or new award — is the most economical and efficient approach, as it avoids duplicative infrastructure costs, reduces transition risk, and leverages work already performed under the original order.

3. Foundation for Full and Open Recompete: Completing both the GLOBE integration and the AWS

Cloud migration during the bridge period will modernize the technical environment and reduce complexity, directly enabling CMS to conduct a full and open traditional recompete in Fall 2027.

The follow-on is explicitly structured as a bridge to competition, not a long-term sole-source arrangement. It enables greater competition in the future because it eliminates the incumbent advantage associated with MPP hosting on Palmetto owned and operated infrastructure.

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 538.7104-4(b).

4. Market Research:

Market research was not conducted for this limited-source action, as the purpose of this award is to bridge ongoing operations through a defined period of concurrent modernization activity. The scope of work under this follow-on is a continuation of services already being performed under a competitively awarded contract.

Market research will be completed for the subsequent recompete of this requirement in accordance with FAR Part 10 procedures.

5. Actions to Increase Competition:

This acquisition is a logical follow-on to an original Federal Supply Schedule order that was awarded through fair opportunity procedures, and the original order was not previously issued under sole-source or limited-source procedures, thus meeting the requirements of (GSAM 538.7103-3(a)(2))Following this bridge period, CMS plans to conduct a competitive acquisition. The completion of the GLOBE integration and CMS Cloud migration during the bridge period will modernize the technical environment and reduce transition complexity, positioning CMS to effectively recompete the requirement in FALL 2027.

6. Any other facts supporting the justification:

Palmetto GBA has demonstrated consistently good performance within CMS's established governance framework throughout the life of the current contract. During the bridge period, the contractor shall maintain all existing governance structures, including regular stakeholder meetings, status reporting cadences, sprint reviews, backlog prioritization, and change management discussions consistent with CMS's iterative delivery expectations.

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.

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 538.7102- 2(b)(4) and constitutes a fair and reasonable price.

Contracting Officer / Date

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

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

7. HHS Competition Advocate Approval

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.