Limited Source Justification IPPT.pdf

FEDERAL SUPPLY SCHEDULE LIMITED-SOURCES JUSTIFICATION

Acquisition Title: Investigations Project Performance Tracker (IPPT) Agency: CMS/Center for Program Integrity (CPI)/Fraud Investigations Group (FIG) Acquisition Year:2022 Author: Sherri McQueen, Brindha Iyer

1. Description of Action:

Nature

• ____ New Requirement

• __x__ Follow-On Order

• ____ Modification of Existing Purchase Order / Contract Number

Contract Type

• __X__ Firm-Fixed Price

• ____ Time and Materials

• ____ Cost Plus Fixed Fee (CPFF)

• ____ Term

• ____ Completion

• ____ Cost Plus Award Fee (CPAF)

• ____ Other: ___________

Projected Cost / Price: __$350,000_______ Funding Source (s):____#012730_____

Name of Proposed Contractor(s): DCI Solutions

Street Address: 6245 Guardian Gateway, Suite 120

City, State, Zip: Aberdeen Proving Ground, MD 21005

2. Description of Supplies or Services:

The estimated value of the proposed action, including all options, is $___$350,000

The Center for Medicare & Medicaid Services, Center for Program Integrity’s primary mission is to detect, deter and address instances of fraud in the Medicare and Medicaid programs. In 2021, CPI managed close to 4,000 national fraud investigations, resulting in savings of over $2 billion dollars to the Medicare Trust Fund, with the support of six contractors and 74 employees across the country. To ensure the aforementioned resources critical program integrity fraud investigation projects continue and align with CPI’s mission, we procured development of a new Investigations Project Performance Tracker (IPPT) tool. The IPPT is scheduled for deployment in April 2022. However, there are a number of key functions that are pending development that are critical to ensuring the Agency’s program integrity objectives are met. For example, we anticipate a 10% increase in payment suspensions, due to credible allegations of fraud, which would expand the current suspensions inventory to 800. CPI needs to efficiently and effectively track these administrative actions to ensure compliance with our priorities. The current tracking process is manual and inefficient as it is requires the use of spreadsheets in various formats. Moreover, management of these records occupies a one full time employee that could be dedicated to other value-added projects.

CPI requires continued operations and support services for the IPPT application, which is built on the ServiceNow environment. DCI Solutions has provided unique custom coding services for the development of the investigations project tracking as a ServiceNow application. DCI Solutions is uniquely positioned to continue the necessary development of the IPPT due to in-depth knowledge of the business processes, current custom application code, required ServiceNow environment configuration, and security services that will allow for the completion of the project and provide the CMS the greatest chance for success.

The required sole source order will be for a period of 6 months which will allow for critical development and launch of the system to occur while concurrently recompeting the effort on the GSA Multiple Award Schedule

(GSA MAS).

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));

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

IPPT will on board 75 users in ServiceNow and will become critical to day to day operations of CPI’s Fraud Investigations Group (FIG) senior leadership, divisions and external stakeholders. This contract will provide the continued operations and prevent a lapse in services and provide uninterrupted and continuous support to the CPI IPPT application. The contractor will be responsible for the continued development and continuity of services to assist CPI/FIG in delivering best practice-based services that comply with CMS’ architecture and security standards. If a contract is not awarded, it will be a high-risk situation and IPPT will shut down.

This need exists because the development effort will only be partially complete by the current end date of April 2022 and cannot be handed off to a new contractor midway through without significant risks, delays, and costs.

Transitioning this requirement to a new contractor during this time and getting the new contractor up to speed would cause CMS to incur both increased cost and schedule impacts which would result in unacceptable delays to the deployment of the IPPT tool. Extending time necessary to bring the new awardee up to speed and pick up where DCI Solutions leaves off would result in redundancies introducing risk to key deliverables.

DCI Solutions is uniquely positioned to continue the necessary development of the IPPT due to their in-depth knowledge of the business processes, current custom application code, required ServiceNow environment configuration, and security services that will allow for the completion of the project and provide the CMS the greatest chance for success.

Upon initiation of the IPPT application development, CPI learned that Administrative support would not be available beyond IPPT deployment (April 2022). Without an Administrator, CPI will be unable to establish new users or maintain existing user authorities. More importantly, CPI would be unable to deploy application upgrades or security patches. As mentioned prior, the IPPT is scheduled for deployment in April 2022. However, there are a number of key functions that are pending development that are critical to ensuring the Agency’s program integrity objectives are met. For example, we anticipate a 10% increase in payment suspensions, due to credible allegations of fraud, which would expand the current suspensions inventory to 800. DCI has the requisite expertise to provide administrative support until CPI can procure a fulltime, dedicated contract resource.

DCI Solutions has a proven track record and demonstrated success with the implementation of ServiceNow Application (SNAP) application in the Office of Strategy, Performance and Results. Through the use of DCI Solutions ServiceNow expertise, OSPR’s internal business processes was significantly automated, eliminating manual tracking of spreadsheets resulting in improved efficiencies. With the ServiceNow expertise of DCI Solutions, CPI/FIG’s goal is to achieve a reduction of 50% in maintenance hours within 6 months of deployment; this is equivalent to 160 to 180 hours. IPPT is expected to eliminate the spreadsheet tracker within 60 days of deployment and all new fraud projects initiated outside of UCM are processed through IPPT within 30 days of deployment.

To prevent a lapse in development and services, and to be mindful of the use of tax-payer dollars, CMS requires the execution of a contract to DCI Solutions for the continuation of the support services until the completion of the IPPT application and a transition can be achieved under the more permanent competitive procurement solution.

____: 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:

The Program Office conducted the market research to identify capable ServiceNow developers. The market research included the following IDIQs – CMS SPARC and GSA IT MSA schedule. GSA Acquisition Gateway was used as an avenue to look for the capable ServiceNow development vendors. The Program Office decided that DCI Solutions is the capable vendor to support IPPT for a bridge contract of 6 months. No other vendor has the necessary in-depth knowledge of CPI’s fraud investigations operations, or the custom code to be able hit the ground running to complete the remaining backlog develop items, and administrative support.

Although there are other Contractors that have the technical expertise to provide these types of services, it would require a transition period which incurs risk to complete the key strategic deliverables including product launch during a critical time in the IPPT lifecycle whereas a six month sole source order would be more cost and time efficient for the Government. The requested sole source order is necessary to complete key strategic deliverables as required to execute deployment of the system. DCI Solutions possesses the requisite institutional knowledge and expertise to accomplish the completion of these key required deliverables.

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). The Contracting Officer will ensure the level of effort, mix of labor proposed, and total price is reasonable for the order.

5. Actions to Increase Competition:

This request for the sole source contract to DCI Solutions is a short-term bridge interim solution for a period of 6 months. The program office intends (Center for Program Integrity (CPI)) intends to re-compete the IPPT delivery order to be awarded by the end of this requested six-month period of performance. The intended re-compete for IPPT is expected to result in an increased competition. The re-compete is expected to be conducted via GSA Multiple Award Schedule (MAS) which is expected to result in a large number of qualified potential offerors.

6. Any other facts supporting the justification:

The current maintainer of the CPI ServiceNow environment is scheduled to transition off the instance in April 2022, leaving the environment without an administrator. It is critical that the contract is awarded to rectify this situation. DCI Solutions will be able to provide the administration of the environment with short preparation time to ensure continuity of operations.

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

Best Value Determination. 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 an Independent Government Cost Estimate, market research, and historical data to include a comparison with the rates established on their current BPA 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.

2. Contracting Officer Certification: 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.

Contracting Officer / Date

OAGM Approvals <If the contract is <$750,000, the CO is the approving official and all other approval signatures below should be marked as N/A.>

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

__N/A________________________________________________ OAGM Division Director / Date

_N/A_________________________________________________ OAGM Group Director / Date

3. Head of Contracting Activity (HCA) Approval <If the contract and <$15M the HCA is an approving official. All other approval signatures below should be marked as N/A.> I hereby confirm the circumstances described above apply and approve the Limited Source Justification.

_______________N/A___________________________________ HCA Name / Date

4. CMS Competition Advocate (CA) Approval <For all contracts $15 M, but not exceeding $75M, the CA is the approving official. All other approval signatures below should be marked as N/A.> I hereby confirm the circumstances described above apply and approve the Limited Source Justification.

__________________N/A_________________________________ Name / Date

5. OGC Legal Review the General Law Division of the Office of the General Counsel prior to routing to the Department for review.>

________________N/A_________________________________

6. Office of Small and Disadvantaged Business Utilization <If the contract is

_________________N/A________________________________

7. Senior Procurement Executive (SPE) Approval

<If the contract is $75 Mark N/A if not required.> Based on the foregoing justification, I hereby approve the procurement of (state supplies/services being procured) on an other than full and open competition basis pursuant to the authority of (state the full statutory authority and FAR cite and title, consistent with paragraph 4, e.g. 41 U.S.C. 253(c)(1)), as implemented by FAR 6.302-1), subject to the availability of funds, and provided that the services herein described have otherwise been authorized for acquisition.

_____________________N/A____________________________