MSI Bridge LFO JA.pdf

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MSI Bridge J&A
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2400509
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This is a Justification for an Exception to Fair Opportunity document for a Marketplace System Integrator (MSI) contract with the Centers for Medicare and Medicaid Services (CMS). The justification seeks approval for a sole-source follow-on task order to Booz Allen Hamilton under the existing HHSM-500-2016-00015I Multiple Award IDIQ Contract for the 2025/2026 acquisition year. The contract type is a Hybrid Time and Materials and Firm Fixed Price Contract with a projected cost of $92,199,484.65 for the twelve-month period.

CMS is invoking the logical follow-on exception under FAR 16.505(b)(2)(i)(C) to award this sole-source order in the interest of economy and efficiency. The MSI contractor performs critical system integration activities, release management, environment management, and communication for Exchange environments hosted in cloud platforms, while also reviewing legislative changes for proper integration with the Federally Facilitated Exchange (FFE). The justification emphasizes that transitioning to a new contractor during ongoing Marketplace modernization efforts would create unacceptable performance risks, project delays, and additional costs. The current contractor has deep knowledge of the existing systems and marketplace operations, and their continuity is essential during the COVID-19 Public Health Emergency unwinding and planned system modernizations. The document includes multiple approval signatures from contracting officers, competition advocates, and senior procurement executives, with the final Senior Procurement Executive approval dated December 20, 2024.

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justification contemplates the award of a new task order for one year of systems integration services beyond the end of the current order providing for these services.

2. Description of Supplies or Services:

The MSI Contractor performs system integration activities, release management, environment management, communication, and participates in the change control process for Exchange environments that are hosted in a cloud platform. Additionally, the MSI Contractor reviews legislative changes to the work overseen by CMS and the Center for Consumer Information and Insurance Oversight (CCIIO) so that proper integration to the Insurance Marketplace cloud environment aligns with and incorporates appropriately into the Federally Facilitated Exchange (FFE).

The follow-on order contemplated in this justification will provide up to twelve months of severable services to continue this effort while CMS performs work to modernize components of the Exchange environments, with the goal of transitioning the services to a successor contract after July 2026.

3. Authority and Rationale:

The Contracting Officer shall give every awardee a fair opportunity to be considered for a delivery/task order exceeding $3,500 unless one of the following statutory exceptions applies. FAR 16.505(b)(2). Mark the applicable exception:

The agency need for the supplies or services is so urgent that providing a fair opportunity would result in unacceptable delays [FAR 16.505(b)(2)(i)(A)];

Only one awardee 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 [FAR16.505(b)(2)(i)(B)];

The order must be issued on a sole-source basis in the interest of economy and efficiency because it is a logical follow-on to an order already issued under the contract, provided that all awardees were given a fair opportunity to be considered for the original order [FAR 16.505(b)(2)(i)(C)]; or

This logical follow-on will help manage performance risk associated with implementation of changes to the Exchange environments and systems that would otherwise be realized if contract transition were to occur concurrently. The risk will be avoided by delaying transition until after the work is complete. As detailed below, issuing the MSI contract on a sole-source basis is in the interest of economy and efficiency because it promotes continuity and stability, knowledge retention, cost savings and avoidance, efficiency in project management, and risk mitigation.

The MSI Contractor is has a critical role in the implementation of many important Marketplace initiatives currently underway or planned for the near future. MSI is tasked with coordinating different Marketplace subsystems to deliver a single integrated solution. As the Marketplace user base grows during unwinding of the COVID-19 Public Health Emergency and the movement of beneficiaries from Medicaid to Marketplace, it

5. State any other facts supporting the justification:

None

4. Head of Contracting Activity (HCA) Approval I hereby confirm that the circumstances described above apply and approve this Justification for Exception to Fair Opportunity.

HCA Name / Date

5. Office of Small and Disadvantaged Business Utilization

Name / Date

6. HHS Competition Advocate Approval

Jennifer Johnson Jennifer Johnson (Dec 20, 2024 12:06 EST)

Name / Date

7. Senior Procurement Executive (SPE) Approval Based on the foregoing justification, I hereby confirm the circumstances described above apply and approve the Justification for Exceptions to Fair Opportunity as set forth in FAR 16.505(b)(2)(i)(C)- The order must be issued on a sole-source basis in the interest of economy and efficiency because it is a logical follow-on to an order already issued under the contract, provided that all awardees were given a fair opportunity to be considered for the original order.

Anthony S. Kram Anthony S. Kram (Dec 20, 2024 16:45 EST)

SPE Name / Date

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