N6264520R0064 RFP Coding Final.docx

N6264520R0064

Section SF 1449 - CONTINUATION SHEET

PERFORMANCE WORK STATEMENT

IDIQ Base Performance Work Statement Medical Coding Services OCONUS Enterprise-wide

SECTION 1 - INTRODUCTION

1.1. BACKGROUND

In order to improve military health care, it is essential to have a robust coding and auditing program within Navy Medicine. With future International Classification of Disease (ICD) versions becoming more detailed, it is imperative that health care providers learn to improve medical record documentation. The focus of this contract is to augment Navy Medical Treatment Facility (MTF) coding resources and provide education to Navy health care providers to improve documentation and coding accuracy. The ongoing requirement of the contract is improving health care provider documentation, coding and auditing practices and achieving outcomes such as reductions in claims denials and relative values of care.

1.2. SCOPE

The scope of this contract includes inpatient and outpatient medical record coding services, inpatient and outpatient medical record auditing services, medical coding and auditing training services, and Clinical Documentation Improvement Specialist (CDIS) services. In this contract, Armed Forces Health Longitudinal Technology Application (AHLTA)/MHS Genesis, Ambulatory Procedure Visit (APV), Emergency Room (ER) and Inpatient Professional Services (IPS) (also referred to as rounds) records are all considered outpatient records. The services incorporated under this contract are inherently associated with coding and auditing processes. All services provided under this contract shall be provided either on-site or remotely for Navy MTFs as specified in the individual task orders.

SECTION 2 - DUTIES

2.1. SPECIFIC DUTIES

2.1.1. The contractor shall provide a monthly report of the services rendered during the previous month at each MTF identified in the task order to the task order primary Government Point of Contact (POC), the Contracting Officer’s Representative (COR), and the Regional Patient Administration Department (PAD) Officer by the 5th business day of the month. Also, the contractor shall identify any issues regarding the services provided or any government issues that may affect their performance (i.e., inability to gain access to the Automated Information System (AIS) for new employees). The report shall contain a place for the task order primary Government POC to digitally sign to verify receipt of the deliverable and attesting that the information contained within it is accurate. The documents produced in accordance with paragraphs 2.1.3.7. and 2.1.4.6. below shall be embedded into the document. This shall be submitted as an Excel spreadsheet with a separate tab for each MTF, but only one spreadsheet per task order.

2.1.2. MEDICAL RECORD CODING SERVICES

2.1.2.1. The contractor shall code billable care including Medical Services Accounts (MSA), all Other Health Insurance (OHI) and encounters in clinic specialties requiring expertise in a specific area of medicine.

2.1.2.2. The contractor shall research/resolve problematic coding practices identified by the MTFs to include data quality discrepancy items.

2.1.2.3. The contractor shall code encounters in clinic specialties where a high level of coding expertise in a particular specialty is required.

2.1.2.4. The contractor shall resolve medical record documentation deficiencies through healthcare provider query and provide routine feedback to health care providers to correct future deficiencies.

2.1.2.5. The contractor shall work as part of a team interacting with the health care providers, government personnel and contract employees to perform medical record coding and research errors or missing documentation.

2.1.2.6. The contractor shall comply with the following turnaround times which begin upon receipt of the record.

· All outpatient non-APV records shall be coded within 3 business days.

· APVs shall be coded within 15 calendar days.

· Inpatient medical records shall be coded within 30 calendar days.

2.1.2.7. The contractor shall perform a quality assessment of records, including verification of medical record documentation (both electronic and hand written) and provide the department head and individual health care providers with feedback.

2.1.2.8. If the government does not agree with a code assigned to a medical record by the contractor, the MTF will notify the contractor of the discrepancy. The contractor shall respond with the action to be taken within 48 hours of notification. If the contractor and MTF continue to disagree, the Navy Medicine Region (East or West) will review and make the final decision on the appropriate code(s). The Region’s decision will be sent to the contractor and the code shall be changed at no cost to the government.

2.1.2.9. The contractor shall obtain physician documentation for any clinical condition or procedure to support the appropriate severity of illness, expected risk of mortality and complexity of care of the patient prior to coding the medical record.

2.1.2.10. The contractor shall advise members of the patient care team, to include the attending physicians, allied health practitioners, nurses and case managers, regarding documentation guidelines.

2.1.2.11. The contractor shall work with the MTF clinical champions, AHLTA Sustainment Trainers/Consultants, directors and department heads to develop best practices for outpatient and inpatient coding to provide educational services.

2.1.2.12. The contractor shall follow the MTF Standard Operating Procedures (SOPs) when the government systems are unavailable due to system issues.

2.1.3. MEDICAL RECORD AUDIT SERVICES.

2.1.3.1. The contractor shall conduct audits of government coded medical records as stated in the individual task orders. The audit shall assess compliance with Department of Defense (DoD) requirements and industry standards, such as the use of modifiers, procedure sequencing and linkage of procedures to diagnosis codes to support medical necessity of services. The contractor shall perform the audits in accordance with the Bureau of Medicine and Surgery Instruction 6150.38 A (BUMEDINST 6150.38A) (or current version); a copy is provided as PWS Attachment II. In addition, the contractor shall use the government’s auditing tool of choice which is currently Global Code.

2.1.3.2. The contractor’s audit shall identify inaccurate/non-specific code assignments, document improvement opportunities and make recommendations for staff training. Improved documentation accurately reflects the patient/health care provider’s interaction, the chief complaint/reason for admission (including pertinent patient/family health and social histories) and co-morbidities affecting the specificity of final code assignment. The audit report (See paragraph 2.1.3.7.) shall describe the gap between the medical record documentation and the required baseline clinical documentation. This information shall be used to improve clinical documentation through provider training.

2.1.3.3. For MTFs with on-site services, the contractor shall pull the records for the audit based on the list provided by the task order primary Government POC. For those MTFs purchasing remote services, the government will provide the contractor electronic copies of the patient record and the auditing tool loaded with the data. The quantity and frequency of the audits will be stated in the task order. The task order primary Government POC will coordinate specific audit dates and provide a list of the records to be audited.

2.1.3.4. The contractor shall verify patient identification and demographic information, reason for admission, disposition date, assignment of diagnoses, procedure documentation and provider’s signature for all inpatient record audits. The inpatient audit includes a comparison of the auditor’s coded record against the original coded record and a comparison of Relative Weighted Products (RWPs).

2.1.3.5. The contractor shall verify patient identification and demographic information, chief complaint/reason for visit, encounter date, assignment of diagnoses, procedures documentation and provider’s signature for all outpatient record audits. The audit shall include a comparison of the auditor’s coded record against the original coded record and a comparison of Relative Value Unit (RVUs).

2.1.3.6. The contractor shall recode records at no additional cost, if the government determines a contractor-audited record is incorrect. The government will assess accuracy by conducting shadow audits of randomly selected contractor-audited records. See PWS Attachment III - Coding Program Management and Training Guidelines regarding government surveillance of performance.

2.1.3.7. The contractor shall e-mail the task order primary Government POC and the COR within three business days of completion of the audit. The email shall include the following information: date conducted; dates of services; guidelines used (95 or 97); summary of the audit data including common errors, trends; a compare/contrast of audit results for previously audited providers and recommendations for future training sessions. The Global Code summary report(s) defined in the task order shall be included as an attachment to the report. Other information required will be identified in the task order.

2.1.4. TRAINING SERVICES

The contractor shall provide training as stated in the individual task orders. One training session is equal to one hour of training. The task order Government POC is responsible for scheduling and confirming the training session with the providers at least two weeks in advance consistent with the Navy Medicine Training Guidelines (refer to PWS Attachment III, Coding Program Management and Training Guidelines). The primary focus of training is to increase the accuracy of medical encounter coding by improving code assignment and clinical documentation.

2.1.4.1. The contractor shall work with the government to develop training that is specific to the clinical services provided by the MTF and shall incorporate standardized Bureau of Medicine and Surgery (BUMED) training guidance provided in the Coding Program Management and Training Guidelines (PWS Attachment III) to facilitate evolving requirements. The contractor shall work with the MTF personnel and the AHLTA sustainment trainers in the performance of these services. Training topics shall include the current ICD version; Current Procedural Terminology (CPT) codes and conventions; inpatient and outpatient documentation; RVU/RWP documentation and coding; residency specific issues (as applicable); use of Healthcare Common Procedural Coding System (HCPCS) and CPT codes; inpatient and outpatient query processes; Medicare Severity-Diagnosis Related Group (MS-DRG) validation and industry coding classification updates.

2.1.4.1.1. The contractor shall ensure training materials are continuously updated to relay the most current and relevant information. The curriculum shall include specific information and examples relevant to the clinical area for which the training is provided.

2.1.4.1.2. The contractor shall not include instruction on how to use the government systems such as AHLTA/MHS Genesis, Composite Health Care System (CHCS), or Coding Compliance Editor (CCE) in their curriculum. The contractor shall inform the task order Government POC and the COR in writing of system related issues brought up during training.

2.1.4.1.3. The contractor shall participate in continuous process improvement with AHLTA sustainment trainer and aid the health care providers in determining the best process for entering information into the system.

2.1.4.2. The contractor shall incorporate audit findings and feedback from health care providers (to include residents and interns), clinical staff and government coders into their training.

2.1.4.3. The contractor shall provide updates and revisions to any templates or tools used by the health care providers related to coding.

2.1.4.4. The contractor shall use a variety of methods to provide training, which may include, group training, one-on-one training, webinars, web-based training, power point presentations, Defense Collaboration Services (DCS) and/or instructional videos. The government reserves the right to record any training session or copy any of the training materials provided by the contractor for educational purposes.

2.1.4.4.1. The contractor shall identify and provide a list of teaching tools/equipment required from the government at least two weeks in advance of training.

2.1.4.5. The contractor shall advise the task order Government POC and the COR in advance of developing the training schedule if any provider requires immediate training based on the audit results.

2.1.4.6. The contractor shall e-mail the task order primary Government POC and the COR within three (3) business days of each training session. The email shall include the following information: date and number of training hours; name of trainee(s) and their specialty area; training location; documentation used for training; number of records reviewed (if applicable); summary of overall findings; recommendations provided to trainees; feedback from trainees; recommended timeframe to meet again (if applicable). Any follow-up training shall not commence prior to COR approval and modification to the contract. Any other information required will be stated in the task order.

2.1.5. CLINICAL DOCUMENTATION IMPROVEMENT SPECIALIST (CDIS) SERVICES

2.1.5.1. The contractor shall perform initial and follow-up assessments regarding the inpatient provider’s documentation skills. With each assessment, inpatient record reviews shall include verification of patient identification and demographics; reason for admission; disposition date; assignment of diagnoses; procedures documentation and health care provider’s signature. The contractor shall also identify opportunities for improvement to ensure documentation used for measuring and reporting physician and hospital outcomes is accurate and complete.

2.1.5.1.1. The contractor shall perform a baseline review of all inpatient health care providers to determine if CDIS are impacting documentation. The sample size for the review shall be between 2-5% per health care provider. The review shall start within 30 calendar days of contract startup and the results of the review shall be provided in a report to the Task Order Government POC and the COR per the following schedule:

2.1.5.1.2. The contractor shall perform a baseline review of all new health care providers within 30 days of seeing patients to determine the current level of documentation detail. The sample size for the review shall be 2% per provider. A report of findings shall be provided to the Task Order Government POC and the COR within 5 business days of starting the review.

2.1.5.1.3. The contractor shall concurrently review all medical records identified in the task order(s) to identify documentation deficiencies. For an inpatient stay, the CDIS shall review the provider documentation daily and recommend an addendum to the record if necessary. If the CDIS determines a provider’s documentation is not improving, the CDIS shall recommend to the Task Order Government POC and the COR a corrective action plan to identify specific areas of improvement, a remediation plan that includes a timeline in which to achieve positive results and a follow-up plan. The corrective action plan shall be approved by the Task Order Government POC and the COR prior to implementation. A summary of all providers placed on a corrective action shall be included in the monthly report of services rendered.

2.1.5.1.4. The contractor shall perform focused inpatient medical record reviews. The initial review is performed within 24-48 hours of patient admission.

2.1.5.2. The contractor shall communicate with physicians, case managers, coders and other health care team members to obtain comprehensive medical record documentation to support the severity of illness, expected risk of mortality, and complexity of care provided to the patient. Documentation obtained shall include clinical treatment and procedures, medical decisions and diagnoses for inpatients.

2.1.5.2.1. The contractor shall initiate a query to the health care provider to clarify and explain any documentation that does not clearly and consistently describe the patient’s medical condition and hospital stay to assign the correct MS-DRG. Clarification includes obtaining accurate and complete documentation based on current clinical findings, prescribed treatment, medical interventions and/or processes. The contractor’s medical record review methodology shall comply with BUMEDINST 6150.38A (or current version) (See PWS Attachment II).

2.1.5.2.2. The contractor shall conduct routine (non-query) follow-up reviews of the medical record every 3 days until the issue is resolved.

2.1.5.2.3. The contractor shall review outstanding queries daily for provider responses and follow-up as needed to facilitate timely and accurate documentation.

2.1.5.3. The contractor shall provide education to physicians and other members of the health care team regarding compliant documentation responsibilities, coding and reimbursement issues and documentation guidelines.

2.1.5.4. The contractor shall investigate and analyze documentation issues/questions to generate and recommend solutions to the Task Order Government POC and the COR. The contractor shall prepare formal reports for the government with findings and recommendations regarding documentation, revenue and reimbursement issues. Formal reports shall be submitted to the Task Order Government POC and the COR by the 5th business day of each month.

2.1.5.5. The contractor shall provide medical record documentation education to residents and interns in the MTFs Family Practice graduate medical education (GME) program.

2.1.5.6. The contractor shall implement coding documentation improvement processes and disseminate new/updated information to improve documentation, RWP and Prospective Payment System (PPS) capture within five (5) business days after receiving approval from the government.

2.1.5.7. The contractor shall educate the health care provider on the most efficient process for capturing data in the applicable system.

2.1.5.8. The contractor shall evaluate Present on Admission (POA) indicators for each diagnosis that could potentially affect the principal diagnosis, quality indicators or MS-DRG assignment.

2.1.5.9. The contractor shall monitor compliance with policies and procedures relevant to the clinical data management program and make recommendations to improve compliance, obtain government approval for implementation and take action.

2.1.5.10. The contractor shall collect and analyze data to correct identified complex coding deficiencies and improve reimbursement capture.

2.1.5.11. The contractor shall utilize enterprise-prescribed tools to monitor the completeness of clinical documentation and accuracy of code assignments.

2.1.5.12. The contractor shall make daily rounds and interact with health care team members to ensure consistent documentation practices. The contractor shall work closely with any department impacting admissions to include, Scheduling, Insurance Verification, Operating Room (OR), Post-Anesthesia Care Unit (PACU), Emergency Department (ED) and the Admitting Office for direct admits. The contractor shall seek clarification from physicians regarding proper documentation as it relates to reimbursement.

2.1.5.13. The contractor shall achieve minimum departmental productivity standards of 20-25 reviews per day, inclusive of initial and follow-up reviews.

2.2. APPLICABLE DIRECTIVES AND REFERENCES

The following legal, regulatory, policy, and security documents are relevant to the performance of contract services.

The contractor shall comply with all mandatory documents listed below and referenced throughout Section 2.1.

Mandatory Compliance

(See PWS Attachment I) Subj: Requirement to Correct Codes When Reviewed By Coder/Auditor and Found To Be Inaccurate (or current version)

(See PWS Attachment II) Coding Program Standard Business Practices, Processes, and Reporting Guidelines

Department of Defense (DOD)

Administrative Instruction No. 15 (DOD AI-15), April 19, 2017 https://www.esd.whs.mil/Directives/issuances/admin_inst/

OSD Records and Information Management Program

TRICARE Operations

TRICARE Operations Manual 6010.56-M, Chapter 2, dtd Feb 1, 2008 https://manuals.health.mil/pages/DisplayManual.aspx?SeriesId=OPERATIONS

Records Management

https://www.esd.whs.mil/Portals/54/Documents/DD/issuances/dodi/858201p.pdf?ver=2019-12-09-143118-860

Security of Unclassified DoD Information on Non-DoD Information Systems (or current version)

(see PWS Attachment III, Coding Program Management and Training Guidelines) Coding Program Management and Training Guidelines

https://www.med.navy.mil/policy-guidance/Documents/PII%20Incident%20Final%20Signed%20Copy.pdf

PII Incident Reporting Requirements

DOD

5400.11R dtd May 14, 2007 http://www.dtic.mil/whs/directives/corres/pdf/540011r.pdf

DoD Privacy Program

https://www.doncio.navy.mil/uploads/0303FTP35332.pdf

Loss of Personally Identifiable Information Reporting Process

https://www.secnav.navy.mil/doni/Directives/05000%20General%20Management%20Security%20and%20Safety%20Services/05-200%20Management%20Program%20and%20Techniques%20Services/5239.19A.pdf DON Computer Network Incident Response and Reporting Requirements

http://uscode.house.gov/browse/prelim@title41&edition=prelim Public Contracts

http://uscode.house.gov/view.xhtml?req=granuleid%3AUSC-prelim-title44&saved=L3ByZWxpbUB0aXRsZTQ0L2NoYXB0ZXIzMQ%3D%3D%7CZ3JhbnVsZWlkOlVTQy1wcmVsaW0tdGl0bGU0NC1jaGFwdGVyMzE%3D%7C%7C%7C0%7Cfalse%7Cprelim&edition=prelim Public Printing and Documents

https://www.govinfo.gov/content/pkg/CFR-2011-title36-vol3/pdf/CFR-2011-title36-vol3-chapXII-subchapB.pdf

Records Management

(or current version)

American Health Information Management Association Code of Ethics

https://www.esd.whs.mil/Portals/54/Documents/DD/issuances/dodd/550007p.pdf

Standards of Conduct

https://www.esd.whs.mil/Portals/54/Documents/DD/issuances/dodi/602518p.pdf

Privacy of Individually Identifiable Health Information in DoD Health Care Programs

https://www.esd.whs.mil/Portals/54/Documents/DD/issuances/dodi/540011p.pdf DOD Privacy Program

http://www.prim.osd.mil/Documents/DoDI_8500-2_IA_Implementation.pdf

Information Assurance (IA) Implementation

https://www.esd.whs.mil/Portals/54/Documents/DD/issuances/dodi/858002_2015_dodi.pdf

Security of Individually Identifiable Health Information in DoD Healthcare Programs

https://www.esd.whs.mil/Portals/54/Documents/DD/issuances/dodi/100013p.pdf?ver=2019-04-08-104412-223

Identification (ID) Cards for Members of the Uniformed Services, Their Dependents, and Other Eligible Individuals

https://www.tecom.marines.mil/Portals/90/Docs/5211.5E.pdf DON Privacy Program

SECTION 3 – HOURS OF OPERATION

3.1. Specific days and hours of operation are defined in the individual task orders for on-site services. The contractor’s employees may work outside the duty hours stated in the task order, at no additional cost to the government, to manage any backlog with coordination and written approval from the COR and Contracting Officer. Services are not required on the observance of federal holidays at any Navy MTF.

3. 2. All closings for severe weather or other emergency shall be at the sole discretion of the government for on-site services. The contractor shall provide services unless notified by the task order primary Government POC that a closing due to weather conditions or other emergency is authorized. The contractor will receive guidance from the Government task order primary Government POC of the MTF protocol for closings.

3.3. Remote services are not bound by defined service hours, however some facilities do not have 24/7 Information Technology (IT) support. It is the contractor’s responsibility to ensure that individuals providing remote coding services are informed of the operating hours for the IT department of the MTF they are servicing in the event IT support is required. The hours of operation and contact information for the IT department will be included in the task orders.

3.4 Situational Telework. The Contractor is authorized to enable its contractor employees to telework upon coordination with COR or Task Order Contracting Officer. The Contractor shall have written Policy Guidance established and provide adequate oversight of work products to ensure contract compliance while teleworking, which will be provided to the Government. Telework arrangements shall commence with Contracting Officer Representative (COR) approval under the following:

· Teleworking on the part of the company is voluntary;

· Teleworking shall not result in an increase in contract price;

· The Contractor is responsible for continuity of performance in accordance with the terms of the contract;

· Government allowing telework shall be coordinated between the Contractor’s Program Manager and the Government and approved by the Contracting Officer and/or the Contracting Officer Representative; and

· Any equipment provided by the Government for telework purposes will be treated as Government Furnished Equipment, and shall be returned at the end of the telework arrangement.

· The contractor shall monitor worker access, performance and duty hours.

SECTION 4 – DELIVERABLES

4.1. Contract Data Requirements List (PWS Attachment IV)

4.2. Schedule of Deliverables

Up to 350 Report Due After Start of Review Within 5 business days Number of Providers Between 350 and 700 Report Due After Start of Review Within 10 business days Number of Providers Greater than 700 Report Due After Start of Review Within 15 business days

SECTION 5 – QUALITY ASSURANCE SURVEILLENCE PLAN (QASP)

5.1. QASP Matrix

Quality Level

2.1.2.8.

2.1.3.6.

2.1.5.11.

2.1.4.1.1.

2.1.4.2.

2.1.5.5.

Feedback: 80% of students rated the quality of the training effective.

2.1.5.1.2.

2.1.5.1.3.

2.1.5.1.4.

2.1.5.4.

Inspection& Observation

Bi-annual

Inspection: 90% of the reports are accurate.

as required for corrective actions 100%

Acceptance

SECTION 6 - QUALIFICATIONS

6.1. GENERAL QUALIFICATIONS

The contractor shall ensure their contractor employees are fully trained to provide services consistent with ICD-10 and future mandated coding changes.

6.1.1. Be a U.S. Citizen per PWS Attachment V, Citizenship Requirements.

6.2. CODING, AUDITING, TRAINING AND CODING CONSULTATION SERVICES

6.2.1. The contractor’s professional staff shall possess and maintain certifications issued by a nationally recognized certifying professional body for coding professionals. An apprenticeship certification is not considered acceptable under this contract.

6.2.2. The contractor’s professional staff shall possess a minimum of 2 years of experience working in their discipline.

6.3. CLINICAL DOCUMENTATION IMPROVEMENT SERVICES

6.3.1. Bachelor’s degree in a health-related field with a minimum of 5 years clinical experience including but not limited to; acute patient care, health services, public health, long-term care administration, hospital organization and management, strategic planning and health systems.

6.3.2. Two years in the last five years focused on inpatient coding, healthcare and coding regulations including code structure, clinical documentation, MS-DRG experience, criteria-based chart reviews (ex. Utilization Management or Case Management), and quality improvement experience working with a physician’s group.

SECTION 7 – RESUME

7.1. Ten (10) days after contract award, the contractor shall submit a resume to the COR for each contract employee. Prior to contract employees providing services under this contract, the COR will verify the compliance of each contract employee with the qualification requirements applicable to the labor category required to perform the work.

7.2. The contractor shall maintain a personnel roster for all individuals who are providing services under this contract. The contractor shall provide a copy of the list to the COR within 30 days prior to performance of services under this contract and as required to maintain currency of the information.

7.3. The contractor shall inform the COR of any terminations of employment within 24 hours of the action.

SECTION 8 - GOVERNMENT AND CONTRACTOR FURNISHED ITEMS.

8.1. GOVERNMENT FURNISHED ITEMS

8.1.1. The government will provide the auditing tool of choice, which is currently the Global Code. This includes the tool, directions for usage and a maximum of 2 training sessions not to exceed a total of 4 hours per year for contractor personnel. The task order primary Government POC or their designee will provide the training on how to use the Global Code.

8.1.2. AUTOMATED INFORMATION SYSTEMS (AIS)

The government will provide access to the AIS required for the performance of services on the contract and will maintain all hardware and systems. Access to sensitive data will be at a level appropriate to the performance of services.

8.1.3. ON-SITE SERVICES

8.1.3.1. The government will provide, without cost, the facilities, materials, consumable supplies and equipment required to perform the on-site duties, with the exception of the services specified under this contract. The government will provide routine scheduled maintenance and repair of government-provided equipment according to MTF Instructions. Upon contractor’s request, through the task order Government POC, the government will provide repairs of government provided equipment in accordance with MTF Instructions.

8.1.3.2. The contractor shall coordinate with the Material Management Department to order department supplies. The contractor shall research products, make recommendations for purchase, enter new item requests, and create replenishment requests to be submitted by the appropriate government official. The contractor is liable for loss of or damage to supplies and equipment if such loss or damage is due to negligence or willful misuse. The contractor shall ensure efficient and economical use of supplies.

8.1.3.3. For services performed on-site, at no time during the term of this contract shall the contractor remove government furnished supplies or equipment from the MTF.

8.1.3.4. The contract employees shall comply with the military base policies and instructions for gaining access to the military base for on-site services. The identification badge shall be worn during performance of work and anytime the contractor is on the premises. The contractor shall ensure all government furnished items are returned during a proper check-out with the task order Government POC when the contract employee is no longer providing services under this contract.

8.1.3.5. The Government task order primary Government POC will provide written confirmation to the contractor for training sessions, which includes the audit dates, the MTF name and contact information (See 2.1.4.).

8.1.3.6. The government will provide any teaching tools/equipment identified by the contractor as being required for training. The government will notify the contractor if the materials are unavailable (See 2.1.4.4.1.).

8.1.4. REMOTE SERVICES

8.1.4.1. As indicated in the task orders, at some MTFs, the government may issue laptops to the contractor in support of remote services. If a government furnished laptop is provided to perform remote services, as detailed in Section C.12.2., contract employees shall exchange the laptop at the MTF every 60 days starting from issuance, unless the task order states otherwise. The contractor employee shall possess and maintain a National Agency Check with Law and Credit (NACLC) security clearance before being eligible to receive and use the government furnished laptop.

8.2. CONTRACTOR FURNISHED ITEMS

8.2.1. The contractor shall supply current resources and references (e.g. ICD (current version), CPT, and HCPCS) for each contract employee. Specific requirements will be identified in the individual task orders.

8.2.2. The contractor’s headquarters personnel shall use Microsoft-compatible programs possessing Health Insurance Portability and Accountability Act (HIPAA) compliant encryption capabilities to receive encrypted e-mails from government e-mail accounts.

8.2.3. REMOTE SERVICES

8.2.3.1. The contractor shall provide a Juniper device for remote services requiring a B2B connection.

8.2.3.2. As indicated in the task orders, at some MTFs the contractor shall provide a laptop and a CAC reader to their employees to provide remote services. The contractor’s employee shall possess and maintain a National Agency Check with Law and Credit (NACLC) security clearance before being eligible to access the Government network. The contractor shall be responsible for complying with data security requirements and data destruction requirements identified in the Data Sharing Agreement.

SECTION 9 – QUALITY CONTROL

9.1. The services specified in this contract and the task orders shall be performed in accordance with established principles and ethics of the medical record coding profession. The quality of services shall meet or exceed the current recognized standards established by American Health Information Management Association (AHIMA), American Academy of Professional Coders (AAPC), the MTF, BUMED, DON, the DoD Health Affairs (HA), and those other professional associations and government agencies which specify standards of performance for the medical record coding profession. The contractor shall adhere to and comply with all DoD, DON, BUMED, and Regional and local MTF instructions, notices, Coding Compliance Plans and Coding SOPs as well as BUMED policy letters, notes/notices and memorandums which may be in effect during the term of the contract.

9.1.1. The contractor shall comply with applicable laws and DoD regulations for disposing of copies of patient care records that are in the contractor’s possession.

9.1.2. The contractor shall utilize the BUMED Coding Program Management and Training Guidelines, Military Health Systems (MHS) coding guidelines and MTF processes to monitor and evaluate the completeness of clinical documentation and accuracy of code assignments. For additional information refer to the link in Section 2.2.

9.2. The contractor shall become acquainted with and obey all MTF regulations. In addition, the contractor shall comply with DoD and MTF instructions, Standard Operating Procedures (SOPs) and policies applicable to data quality, ethics and services rendered in a federal facility.

9.3. The contractor shall comply with federal, state, local, and Joint Commission health, fire and safety regulations.

9.4. The contractor shall establish, submit for government approval and implement a Quality Control Plan (QCP) that is consistent with the applicable MTFs Quality Improvement Plan at the task order level for the specific MTFs.

9.5. The contractor shall submit a Quality Control Plan to the COR and the Contracting Officer for review no later than the start of the contract. The QCP shall include (a) a plan for providing services by appropriately qualified personnel; (b) a plan to ensure maintenance and enforcement of the other requirements for contractor employees as specified in Section 11.1.; and (c) procedures the contractor shall implement to ensure the successful completion of tasks identified in this Performance Work Statement (PWS).

9.6. Upon receipt of the contractor's QCP, the COR will review and provide comments to the contractor. If the COR finds deficiencies in any portion of the proposed QCP, the contractor shall have five (5) working days to correct the deficiencies. The COR will provide final approval of the QCP.

9.7. Sixty (60) days prior to exercising any option year under this contract, the contractor shall submit to the COR an updated QCP that is consistent with updated Joint Commission standards and updated MTF Quality Control Program. The revised QCP shall be subject to the same review process as that required at the time of contract award.

9.8. INDEPENDENT CONTRACTOR

The services provided by the contractor are provided in the capacity of an independent contractor. The government will evaluate the quality of services for purposes of contract inspection and acceptance. The contractor shall be solely responsible for any and all liability caused by the acts or omissions of its agents or employees. The contractor shall not in any manner represent or infer that it is an instrumentality or agent of the United States Government. The contractor shall recognize that the Commanding Officer maintains administrative and operational responsibility for all activities within the command and may take such actions as necessary to preserve and maintain the integrity of the command, subject to the limitations prescribed by law and U.S. Navy Regulations.

9.9. MODIFICATIONS

The Contracting Officer will designate and authorize an individual to act as the Contracting Officer's Representative (COR). Any such representative appointed will be specifically designated by letter from the Contracting Officer. The COR exclusively represents the Contracting Officer in all technical phases of the work, but is not authorized to issue Change Orders, Supplemental Agreements, or direct any contract performance requiring contractual modification or adjustment. Changes in the scope of work can only be made by modification properly executed by the Contracting Officer. All observations made by persons other than the Contracting Officer or the COR are strictly advisory and shall not influence the contractor's operations except for administrative requirements and responsibilities specified herein.

SECTION 10 - START OF SERVICES

10.1. BACKGROUND INVESTIGATION

The MTF is responsible for assistance with the security processes involved with on-site services. The COR is responsible for all security processes for remote services.

10.1.1. The Contractor Appointing Personnel shall report to the COR on the first day of contract performance. The COR shall provide direction for a proper check-in and any additional documentation or instructions that may be necessary for contract performance. The Contractor Appointing Personnel shall return the completed check-in sheet to the COR within ten business days.

10.1.2. Upon receipt of an adjudicated Federal background investigation or at a minimum advanced fingerprint results, the Command Trusted Agent will enter contract employee into the Contractor Verification System (CVS). The contractor employee is responsible for completing the CVS application for requesting issuance of a Common Access Card (CAC).

10.1.3. Ten days prior to performance of services under this contract, the contractor’s Security Representative shall submit to the MTF Security Manager, via the COR, the necessary documents to obtain the appropriate Federal background investigation.

10.2. ORIENTATION

The contractor employees shall complete command and information systems orientation within thirty days of the beginning of services. Command Orientation will take place during normal business hours.

10.2.1. All on-site contractor employees shall complete approximately 16 hours of orientation regarding MTF information systems required for performance of services.

10.2.2. All contractor employees shall be required to attend systems training, unless they have previous experience using the information systems utilized under this contract. On-site employees will receive training during the MTF orientation. Remote employees shall attend classes onboard the MTF at the contractor’s expense or request training via video conference from the region in which the remote services are being provided. Contractor employees must pass a systems test or attend training before access to the system(s) will be granted.

10.2.3. The contractor employees shall participate in periodic training as systems are upgraded in order to provide services required by the contract. The government will use modalities that allow remote staff to stay current.

10.2.4. The task order primary Government POC may waive training for individuals who have previously worked at the MTF on a case-by-case basis.

10.2.5. The contractor employees shall complete mandatory Navy and DoD on-line training as indicated above. On-line training may require the contractor’s employees to enter their Social Security Number to document and track compliance with training requirements.

10.3. OCCUPATIONAL HEALTH REQUIREMENTS FOR ON-SITE SERVICES

10.3.1. Within 30 days prior to performance of services, the contractor’s employees shall obtain, at the contractor expense, documentation of required immunizations and physical testing, and a statement from the contractor employee’s licensed medical practitioner or a report of a physical examination. The physical examination and immunization documentation shall be submitted to the COR prior to the start of services. The requirements are provided on the HEALTH EXAMINATION AND IMMUNIZATION/SCREENING REQUIREMENT FORM, the current version of which is available at: https://www.med.navy.mil/sites/nmlc/handbooks/Physical%20Exam%20and%20Immunization%20Form.pdf?Mobile=1&Source=%2Fsites%2Fnmlc%2F%5Flayouts%2Fmobile%2Fview%2Easpx%3FList%3Dbb6872af%252D40d8%252D474e%252D99d2%252D6e3d373f07a8%26View%3De25e6026%252D202c%252D454f%252Da553%252D3ce1665892ad%26CurrentPage%3D1 The MTF will identify any contract employees who are not required to complete this documentation after contract award. Declinations shall only be permitted based on either the contract employee’s religious convictions or medical contraindications (as documented by a qualified health care provider).

10.4. EMERGENCY PREPAREDNESS PLAN

10.4.1. The contractor shall participate in executing the Emergency Preparedness Plan (drills and actual emergencies) as scheduled by the MTF (typically semiannually) for on-site services. The MTF maintains a personnel re-call list with personal contact information for all military, civil service and contractor employees which are required to prepare in advance for an actual emergency. Upon commencement of performance, the contractor shall provide the task order primary Government POC with a list of personal contact information for a designated contractor representative. Should an emergency occur that will affect the contractor, the designated representative will be contacted.

SECTION 11 – STANDARDS

11.1. OTHER REQUIREMENTS

11.1.1. All financial, statistical, personnel, and technical data which are furnished, produced, or otherwise available to the contractor during the performance of this contract are considered confidential business information and shall not be used for purposes other than performance of work under this contract. Such data shall not be released by the contractor without prior written consent of the COR. Any presentation of any statistical or analytical materials, or any reports based on information obtained from studies covered by this contract, will be subject to review and approval by the COR before publication or dissemination. All inquiries from the media shall be forwarded to the Command Public Affairs Officer via the MTF COR.

11.1.2. All records produced in the performance of this contract and all evaluations of patients are the property of, and subject to the exclusive control of, the government. The contractor may retain a copy of all such records or evaluations, but may not provide further copies or disclose the information from such records or evaluations to third parties. All requests from other treatment facilities or other individuals for patient records shall be handled in accordance with procedures specified by applicable MTF instructions.

11.1.3. When creating and maintaining official government records, the contractor shall comply with all federal requirements established by 44 United States Code (USC), 41 USC, 36 Code of Federal Regulations (CFR), Department of Defense (DOD) Administrative Instruction No. 15 (DOD AI-15), “OSD Records and Information Management Program” May 3, 2013 and Chapter 2 of the TRICARE Operations Manual. For additional information refer to the links in Section 2.2.

11.1.3.1 Unclassified DoD information provided to or developed by non-DoD entities in support of DoD activities is to be protected according to the information safeguards described in DoDI 8582.01 dtd December 9, 2019, Security of Unclassified DoD Information on Non-DoD Information Systems (or current version).

11.2. CONTRACT EMPLOYEE STANDARDS

11.2.1. Eating by contract employees is prohibited in patient care areas/clinics and is restricted to designated areas. Smoking is prohibited in all clinic facilities.

11.2.2. The contractor and all contract employees shall comply with all MTF checkout processes. These processes include returning government property, i.e., identification badges, laptops, etc., to the MTF upon a contract employees last day of service. Failure to do so promptly may result in delay of payment to the contractor.

11.2.3. Confidentiality Agreement. All contract employees shall sign a confidentiality form (See PWS Attachment VI) stating they have read and agree to conform to the confidentiality requirements of the government and their profession regarding the protection and confidentiality of personal health information. The contract employee shall sign the form prior to start of services. The signed agreement will be maintained at the MTF.

11.3. CODING ETHICS.

Contract employees shall follow the standards of ethical coding developed by AHIMA's Coding Policy and Strategy Committee. For additional information refer to the link in Section 2.2.

11.4. CONFLICT OF INTEREST

11.4.1. The contractor shall not, while performing services under this contract, advise, recommend, or suggest to persons eligible to receive medical care at the government’s expense that such persons should receive care from the contractor at any place other than a government facility.

11.4.2. The contractor shall not hire any employee for performance under this contract whose employment would result in a conflict with government or DoD Standards of Conduct, DoD 5500.07 (see link in 2.2. for additional information)

11.4.3. The contractor is not prohibited by reason of their performance under this contract from outside employment if there is no conflict with the performance of services.

11.4.3.1. The contractor shall not use any government facilities or other government property in connection with outside employment.

SECTION 12 – REMOTE SERVICES

12.1. Remote Service Options. The government acknowledges that this is a non-personal services contract and the contractor is to determine the method for delivering services remotely; however, because of the limitations imposed by the government systems and the variance between MTFs, only the three options below may be used.