J-2_Attachment_A_Schedule_of_Deliverables.pdf

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CHRONIC CONDITION WAREHOUSE Federal contract opportunity
Solicitation number
RFP-CMS-2014-8A-00092
Issued by
Department of Health and Human Services Centers for Medicare and Medicaid Services

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ATTACHMENT J-2

SCHEDULE OF DELIVERABLES

Task No.

Task Description Due Date/Frequency Activity or Documentation Required

A1 Kick off Meeting and Transition Discussion

Within 10 days of award

Agenda and draft work plan due at meeting.

Meeting notes, action items and final work plan due within 5 days after the kickoff meeting – deliver to the COR/GTL

Identification of the data center location (physical address) and description of the security methods in place (FISMA compliance documentation) as well as the training center location (if different than the data center location) – provided to COR/GTL

A2 Information Gathering and Transition Planning

Questions, issues and/or risk document with resolutions due 30 days after award.

Draft Concept of Operations document due 30 days after contract award; final due within 60 days after contract award.

Organization chart due 1-10 days after contract award.

Comprehensive listing of questions, issues and/or risks with associated resolutions. Updated reports shall be provided to the COR on a weekly basis or upon request from the COR/GTL. Updated listing to be provided through the base year contract.

Concept of Operations Plan detailing support for CMMI related tasks/services provided (draft and final) Organization chart supporting all business operations within the VRDC by type of user (CMMI contacts shall be separate from all other work).

A3 Develop Data and Infrastructure Acquisition Plan

45 days after date of award 1. Comprehensive listing of hardware/software needed to support the work in the SOW and recommendation for replacement equipment;

deliver to COR/GTL

2. Acquisition plan and schedule to receive, load and validate data files, documentation, algorithms, and SAS programs; deliver to

COR/GTL

3. Acquisition plan and schedule for transitioning the current equipment and purchasing the additional equipment specified in #1 above;

deliver to COR/GTL.

4. Procure the hardware/software upon approval from the COR/GTL.

5. Work with OIS to establish connectivity to CMS and required contractor locations via secure, dedicated lines.

A4 Review and Comment on Transition Plan

60 days after date of award Written comments/recommendations to be provided to COR/GTL. Participate in workgroup meeting.

A5 Develop Data Preparation Plan

75 days after date of award Data Preparation Plan due to COR/GTL

A6 Management Plan 90 days after date of award Detailed comprehensive plan listing all of the steps required to implement transition and operationalize the CCW/VRDC environment; deliver to COR/GTL

Task Description Due Date/Frequency Activity or Documentation Required

A7 Implement the Transition 4 months after date of award (communication with incumbent shall continue for 8 weeks)

Conduct transition based on the approved transition plan and schedule and notify COR/GTL of problems or risks that may occur; prepare correction action plans for each risk and notify COR/GTL

A8 Infrastructure Assessment Document

Upon completion of Task A7 and ongoing, updated daily, throughout transition phase and into the Operation & Maintenance Phase as needed

Provide document to COR/GTL stating the current state of the infrastructure after the transition.

Document shall be updated daily. COR/GTL reserve the right to change the update frequency to weekly as the contract moves into the Operation and Maintenance phase. Report of help desk tickets by user type and issue reported provided to COR/GTL daily (including updates and actions taken to resolve issues).

B1 Information Security Ongoing throughout duration of contract

Comply with requirements stated in the task for the duration of the contract

B1.1 System Security Plan and Disaster Recovery Plan

60 days after completion of transition (Task A7)

Submit SSP and Disaster Recovery Plan to COR/GTL and/or ISSO.

B1.2 FISMA (Risk Assessment and Independent Testing)

60 days after completion of transition (Task A7)

Risk assessment , compliance and attestation documentation provided to COR/GTL

B1.3 Privacy Compliance Within 30 days of contract award Completed and signed DUA to be provided to

COR/GTL

B2 Infrastructure Requirements

Upon completion of Task A3 and ongoing through duration of contract

Operational activity – comply with requirements in the SOW

B2.1 Ancillary Asset Management

Ongoing throughout duration of contract

Pertains to all hardware and software procurements performed under the SOW

B2.2 Database Services Ongoing throughout duration of contract

Operational activity – comply with requirements in the SOW

B2.3 Performance and Stress Testing

Ongoing throughout duration of contract

Operational activity – comply with requirements in the SOW

B2.4 Software Management and Maintenance

Upon receipt of software under Tasks A3 &A7; ongoing throughout the duration of the contract

Operational activity – comply with requirements in the SOW

B2.5 Hardware Management and Maintenance

Upon receipt of software under Tasks A3 &A7; ongoing throughout the duration of the contract

Operational activity – comply with requirements in the SOW

B2.6 Backup Recovery Ongoing throughout duration of contract (incrementally, weekly and monthly)

Operational activity – comply with requirements in the SOW

B.3 CCW Data Loads Ongoing throughout duration of contract; data load issues and/or anomalies reported within 24 business hours of identification.

Operational activity – comply with requirements in the SOW; data load updates to be reported in status meetings and documented in status reports. Detailed written description of data load issues/anomalies shall be sent to COR/GTL.

Task Description Due Date/Frequency Activity or Documentation Required

B3.1 Load and Maintain CMS Data – Part A and B Claims and Eligibility/Enrollment Data

Ongoing throughout duration of contract; weekly loads for claims;

monthly loads for eligibility/enrollment; annual load for Denominator.

Operational activity – comply with requirements in the SOW. Provide load update in status reports and status meetings. Any errors or anomalies shall be documented in writing and submitted to COR/GTL within 24 business hours.

B3.2 Load and Maintain Medicaid Data/TMSIS

Ongoing throughout duration of contract; Medicaid to be loaded upon availability; TMSIS load will be determined when available; BETA MAX to be loaded quarterly; Alpha MAX to be loaded monthly.

Operational activity – comply with requirements in the SOW. Provide load update in status reports and status meetings. Any errors or anomalies shall be documented in writing and submitted to COR/GTL within 24 business hours.

B3.3 Load and Maintain Part D Data

Ongoing throughout duration of contract; Part D SAF and Part D Tap to be loaded monthly

Operational activity – comply with requirements in the SOW. Provide load update in status reports and status meetings. Any errors or anomalies shall be documented in writing and submitted to COR/GTL within 24 business hours.

B3.4 Load and Maintain Assessment Data

Ongoing throughout duration of contract; all Assessment data to be loaded monthly

Operational activity – comply with requirements in the SOW. Provide load update in status reports and status meetings. Any errors or anomalies shall be documented in writing and submitted to COR/GTL within 24 business hours.

B3.5 Load and Maintain Provider Data

Ongoing throughout duration of contract; load on a monthly basis

Operational activity – comply with requirements in the SOW. Provide load update in status reports and status meetings. Any errors or anomalies shall be documented in writing and submitted to COR/GTL within 24 business hours.

B3.6 Load and Maintain Quality Data

Ongoing throughout duration of contract; source and frequency to be determined by the COR/GTL

Operational activity – comply with requirements in the SOW. Provide load update in status reports and status meetings. Any errors or anomalies shall be documented in writing and submitted to COR/GTL within 24 business hours.

B3.7 Load and Maintain Other Data Sources

Ongoing throughout duration of contract; source and frequency of other data sources will be determined by the COR/GTL

Operational activity – comply with requirements in the SOW. Provide load update in status reports and status meetings. Any errors or anomalies shall be documented in writing and submitted to COR/GTL within 24 business hours.

B3.8 Load and Maintain Encounter Data

Ongoing throughout duration of contract; frequency will be determined by the COR/GTL

Operational activity – comply with requirements in the SOW. Provide load update in status reports and status meetings. Any errors or anomalies shall be documented in writing and submitted to COR/GTL within 24 business hours.

B3.9 Load and Maintain MedPAR Data

Ongoing throughout duration of contract; load annually

Operational activity – comply with requirements in the SOW. Provide load update in status reports and status meetings. Any errors or anomalies shall be documented in writing and submitted to COR/GTL within 24 business hours.

Task Description Due Date/Frequency Activity or Documentation Required

B3.10 Receive and Maintain the LDS and PUF Data Files

Ongoing throughout duration of contract; file load frequency will be provided by the COR/GTL

Operational activity – comply with requirements in the SOW. Provide load update in status reports and status meetings. Any errors or anomalies shall be documented in writing and submitted to COR/GTL within 24 business hours.

B3.11 ICD-9 TO ICD-10

Conversion

As directed by COR/GTL Mapping of codes and algorithms require COR/GTL review and approval prior to implementation.

B4 CCW Beneficiary Identifier Assignment and Maintenance

Ongoing throughout duration of contract; apply Bene ID to all CCW/VRDC files loaded. Apply Bene ID to all data extracts disseminated.

Operational activity – comply with requirements in the SOW

B5 File Creation Ongoing throughout duration of contract; create future data files, documentation, file layout, SAS version, etc.). Update data availability on website within 2 business days of file availability.

Operational activity – comply with requirements in the SOW. Email notification to COR/GTL upon completion of new file.

B5.1 Master Beneficiary Summary File and Associated Segments (for Medicare and Medicaid)

Ongoing throughout duration of contract; create files and documentation monthly

Operational activity – comply with requirements in the SOW. Email notification to COR/GTL upon completion and availability of file.

B5.2.1 Produce the MMLEADS-v2 File

Ongoing throughout duration of contract; create annual files pending availability of Medicaid data

Operational activity – comply with requirements in the SOW. Email notification to COR/GTL upon completion and availability of file.

B5.2.2 Produce all MMCO-developed Flags and apply all 27 Medicare-only Flags to Medicaid and dual enrollee data for Ongoing Years

Ongoing throughout duration of contract; update flags pending availability of Medicaid data

Operational activity – comply with requirements in the SOW. Email notification to COR/GTL upon completion and availability of file.

B5.2.3 MMLEADS-v2 PUF Ongoing throughout duration of contract; create annual files pending availability of Medicaid data

Operational activity – comply with requirements in the SOW. Email notification to COR/GTL upon completion and availability of file.

B5.3 LDS SAFS Ongoing throughout duration of contract; create annual files and documentation

Operational activity – comply with requirements in the SOW. Email notification to COR/GTL upon completion and availability of file.

B5.4 SAFS Ongoing throughout duration of contract; create files and documentation monthly

Operational activity – comply with requirements in the SOW. Email notification to COR/GTL upon completion and availability of file.

B5.5 Part D Supplemental Files

Ongoing throughout duration of contract; files to be created on an annual basis

Operational activity – comply with requirements in the SOW. Email notification to COR/GTL upon completion and availability of file.

B5.6 Development of Crosswalk Files for Research Extracts

Ongoing throughout duration of contract; create for all files extracts and VRDC requests that require a crosswalk based on their

DUA

Operational activity – comply with requirements in the SOW

Task Description Due Date/Frequency Activity or Documentation Required

B6 CCW Data Documentation and Procedure Documentation

Ongoing throughout duration of contract

Creation/revision to file documentation as stated in the SOW (hard copy as well as electronic/on-line).

Provide email notification to COR/GTL upon completion of updates.

B7 Chronic Condition Flags

Ongoing throughout duration of contract

Update existing flags and identify/propose new flags.

COR/GTL review and approval required for all proposed flags.

B8 Data File Encryption Ongoing throughout duration of contract

Encrypt all data files prior to dissemination via secure courier. Decryption password to be sent electronically to requestor separate from the data.

B9 Data Request Processing and Data Privacy

Ongoing throughout duration of contract

Operational activity – comply with requirements in the SOW. Notify COR/GTL of any requests that will take longer than 4-6 weeks to process.

B10 Coordinate with ResDAC

Ongoing throughout duration of contract

Communicate with ResDAC as required by the SOW. Participate in bi-weekly meetings.

B10.1 Develop Cost Estimates for Data Requests

Ongoing throughout duration of contract. Estimates to be completed within 48 business hours of receipt.

Cost estimates shall be provided back to ResDAC.

B10.2 Develop Query Estimates for Researchers

Ongoing throughout duration of contract. Estimates to be completed within 1-5 business days.

Query estimates shall be provided back to ResDAC.

B10.3 Participate in Conference Calls with ResDAC

Ongoing throughout duration of contract; bi-weekly conference calls

COR/GTL will forward bi-weekly meeting appointment to contractor for participation;

contractor to prepare list of discussion topics 1 business day prior to meeting.

B10.4 Maintain and Update the Specification Worksheets and VRDC Request Documentation

Ongoing throughout duration of contract; updates to be made within 24 business hours of requested change.

Changes shall be made and returned to the

COR/GTL.

B11 Cohort Estimator and Pricing Tool

Ongoing throughout duration of contract; tool to be updated with new files/years within 5 business days of file availability.

Maintain and update tool to include newly available files and years.

B12 Data Dissemination

Ongoing throughout duration of contract

Monthly data extract report to

CMMI GTL

Weekly non-CMMI extract reports to COR

Using the media acquired in Task A3, contractor shall fulfill data requests listed in all B12 subtasks below.

All CMMI data extracts require coordination with CMMI GTL (final data extract criteria document sent to CMMI GTL).

Weekly report of all non-CMMI data request to COR (requested received, requests pending, requests in process and requests shipped)

B12.1 Create and Deliver Complex/Custom Research Identifiable Files

Ongoing throughout duration of contract; approximately 75 custom requests for CMS/CMMI and 55 custom requests for external researchers per month

Requests shall be processed/fulfilled within 4-6 weeks of receipt of request and approved DUA

Task Description Due Date/Frequency Activity or Documentation Required

B12.2 Create and Deliver Standard Research Identifiable File Data Extracts

Ongoing throughout duration of contract; approximately 10 requests per month.

Requests shall be processed/fulfilled within 2-4 weeks of receipt of request and approved DUA

B12.3 Create and Deliver Standard State Extract Files

Ongoing throughout duration of contract; approximately 5 requests per month

Requests shall be processed/fulfilled within 2-4 weeks of receipt of request and approved DUA

B12.4 Copy and Deliver Public Use Files

Ongoing throughout duration of contract; approximately 85 requests per month

Requests shall be processed/fulfilled within 1 week of receipt of request

B12.5 Copy and Deliver Limited Data Set Files

Ongoing throughout duration of contract; approximately 125 requests month

Requests shall be processed/fulfilled within 2 weeks of receipt of request and approved DUA

B12.6 As needed, provide Medicare data and MMLEADS-v2 to CMS- Approved Users

Ongoing throughout duration of contract; approximately 5 requests per month

Requests shall be processed/fulfilled within 4 weeks of receipt of request and approved DUA

B12.7 Minimum Necessary Extraction Requirements

Ongoing throughout duration of contract

Operational activity – comply with requirements in the SOW

B13 Qualified Entity Activities

Ongoing throughout duration of contract; upon receipt of QE data request.

Operational activity – contractor shall comply with the QE file requirements. QE data extracts to be reported as a separate tab within the non-CMMI weekly data dissemination report.

B13.1 Create QE Data Extracts and Validate Data

Ongoing throughout duration of contract

Using media acquired in Task A3, process/fulfill QE requests within 4 weeks of receipt of request and approved DUA

B13.2 Create Secure Download Environment for QE Files

Ongoing throughout duration of contract

Using licenses, equipment, etc. from Task A3, provide approved QE users with the capability to download their files via secure connection

B14 Program, Evaluation, Beneficiary and Provider Repository/Storage, and State-Specific Data Extracts (CMMI)

Ongoing throughout duration of contract

Operational activity – comply with requirements in the SOW

B15 VRDC Workspace, Analysis and Development

Ongoing throughout duration of contract

Operational activity – comply with requirements in the SOW. Monthly tracking/reporting of VRDC users (CMMI and non-CMMI shall be tracked and reported separately).

B15.1 User Authentication/Identity Management

Ongoing throughout duration of contract

Operational activity – comply with requirements in the SOW

B15.2 User Role Management Ongoing throughout duration of contract

Operational activity – comply with requirements in the SOW

B15.3 Security Ongoing throughout duration of contract

Task Description Due Date/Frequency Activity or Documentation Required

B15.4 VRDC User Library Maintenance/Archiving, Performance and Reporting

Ongoing throughout duration of contract; business requirements, process models, flow diagrams, etc. to be provided to COR/GTL upon request.

Operational activity – comply with requirements and documentation in the SOW. Monitoring and usage reports to be provided to COR/GTL (and users).

B15.5 Workbench Ongoing throughout duration of contract

Operational activity – comply with requirements in the SOW. Notify COR/GTL of upcoming releases and get approval prior to implementing the release.

B15.6 File Transfer Request System

Ongoing throughout duration of contract

Operational activity – comply with requirements in the SOW. Track and report all files by user to

COR/GTL.

B15.7 Secure File Transfer System

Ongoing throughout duration of contract

Operational activity – comply with requirements in the SOW. Track and report all files by user to

COR/GTL.

B15.8 OIPDA Users Ongoing throughout duration of contract;

Operational activity – comply with requirements in the SOW

B15.9 CMMI/Contractor Users Ongoing throughout duration of contract; up to 500 users; create up to 72 complex/custom extracts per month for VRDC users

Operational activity – comply with requirements in the SOW

B15.10 Other CMS Contractor Users

Ongoing throughout duration of contract

Operational activity – comply with requirements in the SOW

B15.11 Federal and State Agency/Contractor Users

Ongoing throughout duration of contract

Operational activity – comply with requirements in the SOW

B15.12 External Researchers and Federal Grantees

Ongoing throughout duration of contract

Operational activity – comply with requirements in the SOW

B15.13 Statistical Output Review

Ongoing throughout duration of contract; approximately 40 output review requests per every 48 business hours

Operational activity – comply with requirements in the SOW; monthly reports to be provided to

COR/GTL;

B16 Universal Content Management

Ongoing throughout duration of contract

Operational activity – comply with requirements in the SOW

B17 Analytical Support;

CMMI State Model Support Briefing

Ongoing throughout duration of contract

State Model Briefing due six months after contract award, semi-annual thereafter

Operational activity – comply with requirements in the SOW

B18 Operational & Technical Support

Ongoing throughout duration of contract

Operational activity – comply with requirements in the SOW

B19 Data Request Tracking Ongoing throughout duration of contract

Operational activity – comply with requirements in the SOW; reports to be provided to COR/GTL

B19.1 Data Request Tracking System

Ongoing throughout duration of contract

Task Description Due Date/Frequency Activity or Documentation Required

B19.2 CCW Access Request System (CARS)

Ongoing throughout duration of contract

Operational activity – comply with requirements in the SOW; onboarding instructions to be updated and maintained. Notify COR/GTL of upcoming releases and get approval prior to implementing the release.

B20 Business Intelligence Support and Reporting

Ongoing throughout duration of contract

Operational activity – comply with requirements in the SOW

B21 Training Ongoing throughout duration of contract

Operational activity – comply with requirements in the SOW; training schedules and documentation to be provided to the COR/GTL. Reports/survey results to be provided to COR/GTL within 5 business days of the training session

B22 Help Desk Management System

Ongoing throughout duration of contract

Operational activity – comply with requirements in the SOW

B22.1 Help Desk and Operations

Ongoing throughout duration of contract; assign tickets upon receipt of issue and respond to tickets within 24 business hours.

Operational activity – comply with requirements in the SOW

B22.2 Tracking and Reporting Help Desk Calls

Ongoing throughout duration of contract; bi-weekly reports

Operational activity – comply with requirements in the SOW; ticket information to be provide to COR/GTL in the bi-weekly status report or can be a separate report.

B23 User Group Calls Ongoing throughout duration of contract

Two calls per month (1 for CMMI users and 1 for VRDC users)

B24 Geographic Variation in Medicare and Medicaid

Ongoing throughout duration of contract

Operational activity – comply with requirements in the SOW

B24.1 Maintenance and Expansion of the GVDB

Ongoing throughout duration of contract

Operational activity – comply with the requirements in the SOW

B24.1 A

Create GVDB Files for New Years

End of March 2015 and end of September 2015 and all subsequent years covered under the contract

Operational activity – comply with the requirements in the SOW

B24.1 B

Update GVDB Files for Earlier Years as Needed to Ensure Consistency

End of March 2015 and end of September 2015 and all subsequent years covered under the contract

Operational activity – comply with the requirements in the SOW

B24.1 C

Produce Monthly ‘Real- Time’ Versions of GVDB Files

Created monthly throughout duration of contract

Operational activity – comply with the requirements in the SOW

B24.1 D

Provide Documentation End of March 2015 and end of September 2015 and all subsequent years covered under the contract

Operational activity – comply with the requirements in the SOW

B24.2 Update the Geographic Variation PUF

Ongoing throughout duration of contract

Operational activity – comply with the requirements in the SOW

B24.2 A

Update the GV PUF End of December (for 2015 and all future yearly updates)

Operational activity – comply with the requirements in the SOW

Task Description Due Date/Frequency Activity or Documentation Required

B24.3 Analysis of Dual Eligibles

End of December (for 2015 and all future yearly updates)

Operational activity – comply with the requirements in the SOW

B24.4 PDAG Ad Hoc Requests Ongoing throughout duration of contract

Operational activity – comply with the requirements in the SOW

B24.4 A

Construct and Analyze Episodes of Care

Ongoing upon CMS request Operational activity – comply with the requirements in the SOW

B24.4 B

Impact of Patent Expirations on Part D

Ongoing upon CMS request Operational activity – comply with the requirements in the SOW

B24.4 C

Use Assessment and Inspection Data

Ongoing upon CMS request Operational activity – comply with the requirements in the SOW

B24.4E Other Analyses as Needed

Ongoing upon CMS request Operational activity – comply with the requirements in the SOW

B24.5 ‘Real-Time’ Medicare Tracking Report

Ongoing throughout duration of contract

Operational activity – comply with the requirements in the SOW

B24.5 A

Develop Statistics for Report

Ongoing upon CMS request Operational activity – comply with the requirements in the SOW

B24.5 B

Develop Automated Process for Producing Report

Ongoing upon CMS request Operational activity – comply with the requirements in the SOW

B24.5 C

Provide Documentation Ongoing upon CMS request Operational activity – comply with the requirements in the SOW

B24.6 Provider Analysis Ongoing throughout duration of contract

Operational activity – comply with the requirements in the SOW

B24.6 A

Develop and Update Data for Part A Providers

End of March (for 2015 and all future updates)

Operational activity – comply with the requirements in the SOW

B24.6 D

Provide Documentation End of March (for 2015 and all future updates)

Operational activity – comply with the requirements in the SOW

B25 Website Ongoing throughout duration of contract

Operational activity – comply with requirements in the SOW. All updates coordinated and approved by COR/GTL prior to implementation.

B26 508 Compliance Ongoing throughout duration of contract

Operational activity – comply with requirements in the SOW

B27 Conferences As directed by COR/GTL B28 User, Status and

Progress Reports Ongoing throughout the duration of the contract:

1. Weekly reports due by noon on Monday following the reporting week

2. Monthly reports due the 10th day of month following the reporting month

3. Ad hoc reports to be defined

4. Legislative reports to be defined

Reports due to COR/GTL

Task Description Due Date/Frequency Activity or Documentation Required

B29 Status Meetings Ongoing throughout the duration of the contract; bi-weekly meetings for each functional area.

Respective GTL’S will determine day/time for meeting

Functional areas: CCW/VRDC research, CCW/VRDC infrastructure, CMMI, PDAG, MMLEADS, State Model. Meeting agenda shall be prepared and distributed to attendees one day prior to meeting. Meeting notes including any action items due within 2 business days of the meeting date.

B30 Service Level Agreements

Ongoing throughout duration of contract

Operational activity – comply with requirements in the SOW

B31 Earned Value Management (EVM)

Ongoing throughout the duration of the contract; due the 10th day of each month following the reporting month

Monthly report due to COR/GTL

OPTIONAL TASKS

B24.2 B

Update CMS Reports on Beneficiaries with Chronic Conditions

To be defined when exercised

B24.4 D

Linkage of GVDB to Other Data Sources

To be defined when exercised

B24.6 B

Develop Data for Part B Providers

To be defined when exercised

B24.6 C

Conduct In-Depth Examination of Provider Community for Selected Areas

To be defined when exercised

C1 Inventory of Equipment to Transition

6 months before end of contract period

Detailed inventory of equipment to be transitioned (requirements in SOW) to be provided to COR/GTL

C2 Inventory of CCW Data Files to Transition

6 months before end of contract period

Detailed inventory of all CCW/VRDC data files (requirements in SOW) to be provided to COR/GTL

C3 Business Process Document

6 months before end of contract period

Document to be provided to COR/GTL (requirements for document contained in SOW)

C4 Database and File Documentation

6 months before end of contract period

Document to be provided to COR/GTL (requirements for document contained in SOW)

C5 List of Pending Data Requests and Information Needed to Fulfill

6 months before end of contract period

Report and hard copies of outstanding data requests to be provided to COR/GTL (requirements for report contained in SOW)

C6 Development of Transition Plan

6 months before end of contract period

Transition plan to be provided to COR/GTL (requirements for plan contained in the SOW)

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