Coding_Bridge_JA_Redacted_2.pdf

J&A Number: 15-10325

Page 1 of 3 Source Selection Information – FAR 2.101 and 3.104

JUSTIFICATION AND APPROVAL FOR USE OF OTHER THAN FULL AND OPEN

COMPETITION

1. Contracting Activity.

Naval Medical Logistics Command (NMLC), Acquisition Management and Analytics Directorate, Code 05, 693 Neiman Street, Fort Detrick, MD 21702.

2. Description of the Action Being Approved.

Approval is requested to award three Indefinite Delivery Indefinite Quantity bridge contracts to Peak Government Sourcing, Inc., Caban Resources, LLC and Diamond Solutions, Inc., on a sole source basis in support of the BUMED’s requirement for coding, auditing and training services at Navy Hospitals and MTFs worldwide.

3. Description of Supplies/Services.

The purpose of the contract is to provide a comprehensive package of coding services that will enhance the overall coding function; assist Navy Military Treatment Facilities (MTFs) in improving the accuracy and completeness of coding; and aid in maximizing workload capture through appropriate medical documentation and coding at MTFs throughout Navy Medicine. The contactor shall provide inpatient and outpatient medical record coding, auditing and training services to Navy MTFs worldwide. Medical coders input appropriate codes for various medical services which will be forwarded to healthcare practitioners and providers for reimbursement. Each type of service has a specific code, and the medical coder is responsible for selecting the appropriate code for the type of service, treatment, test or encounter received. Services are provided on-site or remotely. The objective for this contract is to provide the most accurate and efficient coding, auditing and training services.

Estimated Dollar Value

The estimated dollar value of the contract is $9,275,219.32. The period of performance for this contract is 1 September 2015 through 31 August 2016. A competitive award will follow beginning 1 September 2016.

4. Statutory Authority Permitting Other Than Full and Open Competition.

10 U.S.C. 2304(c)(1), One source or limited sources.

5. Rationale Justifying Use of Cited Statutory Authority.

Approval to sole source these three contracts to the current contract holders is being requested because the Department of Health and Human Services is implementing the 10th revision of the International Statistical Classification of Diseases and Related Health Problems (ICD10) effective 1 October 2015.

This requires the entire healthcare industry to comply with the new code set. The implementation of ICD10 and the many changes it has brought with it required several re-workings of the contract documents to bring the requirement into compliance. In order to ensure all documents are correct and allow time for changes that will come up while the transition to ICD10 is underway, approval is requested to sole source bridge contracts to the three current contract holders while the documents for the new competitive contract are prepared ensuring all applicable ICD10 information is included. This would prevent a lapse in services which is an unacceptable solution because the Navy’s hospitals worldwide would become noncompliant with federal regulations.

Page 2 of 3 Source Selection Information – FAR 2.101 and 3.104

6. Description of Efforts Made to Solicit Offers from as Many Offerors as Practicable.

This requirement will not be synopsized on Federal Business Opportunities (FEDBIZOPPS), pursuant to Part 5.202 (a) (2) of the Federal Acquisition Regulation. FAR Part 5.202(2) states, “The contracting officer need not submit the notice required by 5.201 when the contracting officer determines that the proposed contract action is made under the conditions described in 6.302-2 (or, for purchases conducted using simplified acquisition procedures, if unusual and compelling urgency precludes competition to the maximum extent practicable) and the Government would be seriously injured if the agency complies with the time periods specified in 5.203.” The proposed bridge contracts will be awarded using simplified acquisition procedures because the services required are commercial services. If there is a gap in services, it will be extremely detrimental to the Government because all Navy hospitals and affiliated clinics would be in violation of the Federal regulations that govern medical services reporting and compliance. A bridge contract approval was obtained from the Naval Supply Systems Command (NAVSUP) on 14 August 2015. A Sources Sought notice was not publicized because as part of the NAVSUP Bridge Contract Approval, the PGI waiver was invoked (see DFARS PGI 206.302-1 (d)). A Sole Source Intent notice was posted on 20 August 2015 with a closing date of 3 September 2015. If another company submits a written interest in this requirement as a result of the announcement, the company’s information will be evaluated before the contract is awarded to Peak Government Solutions, Inc., Caban Resources, LLC and Diamond Solutions, Inc.

7. Determination of Fair and Reasonable Cost. The contracting officer will determine the anticipated cost to the Government of the services covered by this Justification & Approval for Use of Other Than Full and Open Competition will be fair and reasonable by conducting a cost analysis before an award is made.

8. Actions to Remove Barriers to Future Competition.

A competitive, multiple award, Indefinite Delivery Indefinite Quantity Firm-Fixed Price contract will be awarded no later than 31 August 2016.

9. Contracting Point Of Contact.

The point of contact at NMLC is Mr. Erik Przygocki who can be reached at DSN 343-0244, commercial

(301) 619-0244 or by email at erik.j.przygocki.civ@mail.mil.

See Approvals on Next Page mailto:erik.j.przygocki.civ@mail.mil

Page 3 of 3 Source Selection Information – FAR 2.101 and 3.104

CERTIFICATIONS AND APPROVAL

TECHNICAL/REQUIREMENTS CERTIFICATION

I certify that the facts and representations under my cognizance which are included in this Justification and its supporting acquisition planning documents, except as noted herein, are complete and accurate to the best of my knowledge and belief.

Technical Cognizance:

Meradith Morina, Code 05, Analyst

LEGAL SUFFICIENCY REVIEW

I have determined this Justification is legally sufficient.

Office of Counsel

CONTRACTING OFFICER CERTIFICATION

I certify that this Justification is accurate and complete to the best of my knowledge and belief. To the extent that the J&A value is between $150K and $650K, the Contracting Officer’s signature below also represents approval of the J&A.

Lorri J. Loveland, Contracting Officer

CONTRACTING ACTIVITY COMPETITION ADVOCATE REVIEW

To the extent that the J&A value is between $650K and $12.5M, the Competition Advocate’s signature below also represents approval of the J&A.

Darin Callahan, Competition Advocate

JUSTIFICATION AND APPROVAL FOR USE OF OTHER THAN FULL AND OPEN COMPETITION