Product Strategy - JA Limited Source Justification FY26 FINAL.pdf

FEDERAL SUPPLY SCHEDULE LIMITED-SOURCES JUSTIFICATION

Acquisition Title: Medicare Payment System Modernization (MPSM) Product Strategy Agency: Centers for Medicare and Medicaid Services (CMS) Acquisition Year: 2026 Author: Michelle Barksdale/Candace Straker

1. Description of Action:

Nature

☐ New Requirement ☐ Follow-On Order ☒ Modification of Existing Purchase Order / Contract Number: Contract GS-35F-241AA / Order 75FCMC20F0052

Contract Type ☒ Firm-Fixed Price ☐ Time and Materials ☐ Cost Plus Fixed Fee (CPFF)

☐ Term ☐ Completion

☐ Cost Plus Award Fee (CPAF) ☐ Other:

Total Projected Cost / Price:

Anticipated Contract Period Anticipated Total Amount Current Total Contract Value Inclusive of all Options $1,178,752.41 Anticipated Value of Action (6-Month Extension) $174,883.10 Anticipated Total Contract Value Inclusive of all Options $1,182,285.40

Funding Source (s): Program Ops - 000231

Name of Proposed Contractor(s): Flexion Street Address: 1500 West Main Street City, State, Zip: Sun Prairie WI 535901812

2. Description of Supplies or Services:

CMS awarded the Product Strategy Medicare Payment System Modernization (MPSM) BPA call on September 6, 2022, to provide product strategy and product management subject matter expertise and support services to ensure that MPSM teams have the information necessary to make the best product decisions. CMS is transforming Medicare's claims processing system to meet evolving needs while improving flexibility, efficiency, and sustainability. By balancing modernization efforts with maintenance of current systems, CMS is developing adaptable solutions that will support future business requirements.

The Product Strategy BPA Call provides the following services:

1. Strategic recommendations to the Product Steering Committee and leadership in OIT/AMG regarding the MPSM product suite

2. Collaborates with CMS Product Managers to develop Epics and identify Leading Indicators for Minimum Viable Products.

3. Identifies potential dependencies, risks and blockers and assists with mitigation strategies.

4. Supports prioritization of the Program Backlog.

5. Develops and maintains the Product Roadmap with AMG leadership approval

6. Ensures proper maintenance of the overall product backlog

7. Participates in the Scrum of Scrums meetings.

8. Provides expert product management advice to product managers involved in modernization efforts.

This Limited Source Justification contemplates extending the contract for a period of six (6) months following the end of Option Period 5, using the authority under GSAM 538.7104-3. This 6-month period will enable the continuity of operations without a lapse or disruption given the respective value, expertise, and technical skill set of services provided. After the six-month extension, CMS will continue this work using government resources. The following table illustrates the BPA calls current contract periods:

Current Order Period of Performance Base Period 09/6/22 – 09/05/23 Option Period 1 09/06/23 – 03/05/24 Option Period 2 03/06/24 – 09/05/24 Option Period 3 09/06/24 – 03/05/25 Option Period 4 03/06/25 – 09/05/25 Option Period 5 09/06/25 – 03/05/26

Additional Period: 03/06/2026 – 09/05/2026

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 program office has been unable to hire a suitable federal employee replacement for the MPSM Product Strategy contractor because of the federal hiring freeze implemented by Presidential Memorandum dated January 20, 2025. Insourcing the work associated with this BPA call is a part of CMS’ response to Executive Order (EO) 14222 “Implementing the President's ‘Department of Government Efficiency’ Cost Efficiency Initiative.” However, CMS requires continuity of services beyond the current contract expiration date to ensure uninterrupted mission support and allow sufficient time to transition work with acceptable performance risk. To do otherwise would risk impacting CMS's ability to meet statutory deadlines for Medicare payment updates, as the contractor currently is managing several high-priority initiatives with significant interdependencies. The MPSM program is currently at a pivotal juncture in implementing key infrastructure changes that will impact multiple Medicare payment systems. Having the strategist position unfilled poses significant risk to ongoing build and modernization efforts. The current extension will provide critical support to sustain project momentum, navigate complex changes, and maintain strategic alignment. Disruption during this phase would jeopardize delivery timelines for mandated program changes scheduled for implementation. CMS/OIT will use the additional six month performance period added to this BPA call to continue searching for a viable federal employee candidate for insourcing the work. The total performance period of the BPA call is three and one half years excluding the six additional months requested here. If the current extension is approved, the performance period will be four years.

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. (GSAM 538.7104-4);

4. Market Research:

In accordance with FAR 10.001 (b)(1), market research was completed for this acquisition when the BPA call was awarded in 2022 and determined that the MPSM BPA was the best method to procure agile development services for the modernization of Medicare payment systems. An informal analysis of the current rates established under the Product Strategy BPA call confirm the rates remain fair and reasonable.

5. Actions to Increase Competition:

CMS has no immediate plans for future acquisition of the services contemplated in this justification provided a permanent federal employee is hired to complete the services under this BPA call.

6. Any other facts supporting the justification:

N/A

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

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 GSAM 538.7104-3 and constitutes a fair and reasonable price. The basis for my determination is as follows:

Contracting Officer / Date

3. CMS Competition Advocate Approval

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

N/A Name / Date

4. Head of Contracting Activity (HCA) Approval I hereby confirm the circumstances described above apply and approve the Limited Source Justification.

5. Office of Small and Disadvantaged Business Utilization

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.

N/A