Redacted JA.pdf

Claims Processing System Support Control Number VA-25-00019752 Extension

JUSTIFICATION

FOR AN EXCEPTION TO FAIR OPPORTUNITY

1. Contracting Activity: Department of Veterans Affairs (VA)

Office of Procurement, Acquisition, and Logistics Technology Acquisition Center 23 Christopher Way Eatontown, NJ 07724

2. Description of Action: The proposed sole source action is for a modification to the Firm-Fixed-Price (FFP) with Cost Reimbursable travel Task Order (TO) 36C10B21N10270008 issued under Transformation Twenty-One Total Technology Next Generation (T4NG) Contract VA118-16-D-1027 with King Street Technology Partners, LLC (KSTP) (formerly SBG Technology Solutions Inc.), 7989 Glenn Ferry Road, Pfafftown, NC 27040. The purpose of this modification is to extend Option Period 2 for one month, with two additional one-month option periods for the continuation of Claims Processing System Support (CPSS) due to a protest filed against the competitive follow-on award.

3. Description of the Supplies or Services: On September 5, 2024, a new General Services Administration (GSA) TO, 47QTCA22D009N 36C10B24F0305 for Community Care Development, Security, Operations (DevSecOps) Support (CC DSO) was awarded to Veterans EZ Info Inc. (VetsEZ) using competitive procedures to provide the Community Care Product Line (CCPL) enhancements and maintenance of critical Community Care (CC) products, in support of VA, Office of Information and Technology (OIT), Office of Community Care. On September 15, 2024, an unsuccessful offeror filed a Government Accountability Office (GAO) protest challenging the award to VetsEZ.

The timing of the protest filing resulted in the stay of contract performance of that award pursuant to 31 U.S.C. § 3553 (d)(3)(A)(ii). A decision from GAO may not be finalized until December. As a result, VA faces a gap in CPSS as this current CPSS TO expires on November 30, 2024, and was planned to transition to the CC DSO TO for consolidated CCPL support. A break in service for the CPSS efforts would be catastrophic to Veterans and the operations of VA. As such, an extension of TO 36C10B21N10270008 is being sought to ensure there will be no lapse in support of the critical Claims Processing Systems while GAO renders its decision. This proposed action provides operations support of the Claims Processing System which receives payment from large, contracted vendors providing healthcare to Veterans. Services consist of operations, maintenance, and enhancement of the existing Claims Processing System, including project management, requirements analysis, design, development, software security, integration, testing, release support, training, warranty, and documentation. VA requires continued services to ensure key system capabilities are delivered and sustained, providing clinicians and Veterans uninterrupted support for this critical Claims Processing System.

The period of performance of this extension is one month through December 31, 2024, with two additional one-month option periods, if required, to facilitate transition support through February 28, 2025, once the protest decision is rendered. The total estimated value of this proposed modification is , which includes Optional Task 1.

However, there are unused months in Optional Task 1 from the original TO award that will cover the cost of the overall 3-month extension in the amount of . As such, the overall TO value is estimated to only increase by to

4. Statutory Authority: The statutory authority permitting an exception to fair opportunity is Section 41 U.S.C. 4106(c)(2) as implemented by the Federal Acquisition services is so urgent that providing a fair opportunity would result in unacceptable

5. Rationale Supporting Use of Authority Cited Above: The proposed source for this action is KSTP, 7989 Glenn Ferry Road, Pfafftown, NC 27040. KSTP was awarded the CPSS TO on August 2, 2021, on a competitive basis under Service-Disabled Veteran- Owned Small Business (SDVOSB) set-aside procedures on the T4NG contract vehicle.

The Office of Integrated Veteran Care (IVC) (previously known as Office of Community Care [OCC]) Integrated External Network (IEN) Community Care Reimbursement System (CCRS), known as the Claims Processing System, operates as the central repository for IEN claims data and provides data integrity, reimbursement validation, revenue recovery processes, and analytics functionalities that provide meaningful analyses to reduce improper payments. As the IEN Claims process grows and new programs are added, the Claims Processing System must remain configurable and scalable to meet evolving business needs. As such, the IEN requires continued maintenance and improvements of the Claims Processing System, to handle automated processing of invoices from validation to payment, including the verification of payment accuracy of the invoices submitted by the contracted Community Care Networks (CCNs) and future partners for future state claims processing. The Claims Processing System is hosted in VA Enterprise Cloud (VAEC) within Amazon Web Service (AWS) FedRAMP High Federal Information Security Management Act of 2002 (FISMA) Cloud Service Provider (CSP) classification.

Continuous sustainment of Information Technology (IT) products ensure vital support remains intact with adequate risk mitigation for successful transition of critical CC systems. The CCPL Delivery Operations Product Line must maintain continuous delivery and manage on-going risks, requiring continued support of the current KSTP team. Based on contracts for similar Health DevSecOps services, new vendors require a minimum of two months to fully transition and provide development and sustainment services at levels consistent with prior vendor services and meet demanding requirements of the IVC business for maintaining the capability of network claims processing. The post-COVID-19 National Crisis continues to create additional complexity during this time as qualified resources are in high demand with limited availability. The clinical and IT environment of the post-COVID- DevSecOps migration, both compounds and exacerbates the known risks of transition.

CCRS is a complex and business critical application, processing between 4-5 million CCN provider claims per month and rendering adjudication decisions which results in over $2.5 billion in remittance to our networked CC providers as governed by our CCN agreements. Although the technology employed is common to industry, what is uncommon is the technical competency to understand the claims payment determination and authorization business rules and health care data variations that are inherent to CC requirements that can only be learned through clinical collaboration.

Given these additional complexities it is estimated that a vendor, other than KSTP, would require up to two months to onboard resources and develop sound knowledge of complex workflows to capably fulfill CC requirements. The current vendor has a unique understanding and experience of the clinical aspects of the technical workflows that could take another vendor months to obtain comparable knowledge. Due to the technical complexities of the CCPL systems, extensive dependencies of incremental releases, and criticality of seamless support for systems that facilitate the care of Veterans, the successful transition to another vendor would require a minimum of two months, as planned in the original CPSS TO. This timeframe is essential for completion of business critical and mandated capability enhancements.

While transition to a new vendor may be necessary, VA must maintain and sustain the current CCPL systems in order to fulfill its commitment to the care of Veterans while the protest decision is rendered. Extensive efforts are involved with acclimating to the CCPL environment. A new team would require up to two months to onboard qualified order to perform at a similar level of expertise. The proposed extension will ensure critical support is provided during this time while the protest decision is rendered. Any longevity. Only KSTP can meet the current requirements of VA on day one.

6. Efforts to Obtain Competition: Market research was conducted, details of which are in the market research section of this document. This effort did not yield any additional on day one. There is no competition anticipated for this acquisition. In accordance with FAR 5.301 and 16.505(b)(2)(ii)(D), the award notice for this action will be synopsized on the Contracting Opportunities website, SAM.gov and the justification will be made publicly available within 14 days of award.

7. Actions to Increase Competition: There are no barriers to competition. The requirements under this effort were just competed under a competitive acquisition and VA is currently awaiting the decision of the GAO protest.

8. Market Research: VA performed market research from December 2023 through April 2024 and found that numerous companies provide similar services to those required in support of CCPL (including CPSS), leading to a competitive solicitation issued on May 14, 2024. The Government technical experts conducted additional market research in October websites. As a result of that market research, it was reconfirmed that numerous T4NG Prime contract holders appear capable of performing the effort; including American Communications Solutions, LLC., B3 Group, LLC. now part of Octo, Insignia Technologies Services LLC., Sierra7 and VetsEZ; however, none of them would be able to provide the seamless support required for the Claims Processing System on day one.

No sources were found that can provide CPSS in the timeframe required and without causing a break in support as outlined in Section 5 of the Justification. Only KSTP is capable of providing seamless Claims Processing System Support until a decision is rendered on the protest. As a result, based on the market research described, VA has determined that only KSTP on day one.

9. Other Facts: None

Approval

In my role as procuring activity Advocate for Competition, based on the foregoing justification, I hereby approve the acquisition of a FFP modification to be issued under the T4NG Contract VA118-16-D-1027 TO 36C10B21N10270008 for CPSS, on an other than fair opportunity basis pursuant to the authority cited in Section 4 above, subject to availability of funds, and provided that the services herein described have otherwise been authorized for acquisition.