Amendment 1 - Q A.doc

SSA-RFQ-10-1001

Amendment# 1

Health Information Technology Questions and Answers Question# 1

Are these SSA contracts open to the full range of options on the market or only ones that comply with the CCHIT standards?

Answer:

The American Recovery and Reinvestment Act of 2009 specified that a provider's electronic health record system must be certified to qualify for incentives. The Certification Commission for Healthcare Information Technology (CCHIT) is currently the only federally recognized authority for certification of electronic health records (EHR) systems at this time. However, the Office of the National Coordinator (ONC) and others are in the process of identifying other alternative certifications.

Since other alternative certifications may not be available in the near future, SSA is not requiring health care organizations to have a certified EHR at the time contracts are awarded. However, to receive the first payment, EHR systems certifications must be completed in addition to the submission and approval of the Sample Continuity of Care Document (CCD) as specified in Section B-1 Statement of Work, Item 4.2.1 of the RFP. It is estimated to take approximately 3 – 6 months after awards are made and notices to proceed are issued for the submission and approval of the Sample CCD to be completed. We plan to issue all notices to proceed by September 2010.

(For details on the payment process, see item 0001 in Section A-1 of the RFP.) SSA reserves the right to verify EHR systems certification prior to making payment. The certification obtained must include evaluating the EHR for suitability, quality, interoperability, data portability and security.

Question# 2 I am from a Healthcare system that has multiple physician practices with 4 different EHRs and hospitals that use another vendor’s EHR that our 3 hospitals use. The first payment is dependent on the EHR being certified, would all of our EHRs have to be certified?

What would be the time frame that the certification needs to be completed?

Answer:

Yes, the first payment is dependent on the EHR systems being certified and all participating hospital’s EHR systems would need to be certified. See response to Question 1 for the required information on the required timeframe.

Question# 3 Can a Health Information Exchange Organization/RHIO respond?

Answer:

Yes

Question# 4 Can only one of the Health Information Exchange Organization/RHIO’s hospital members respond?

Answer:

A Health Information Exchange Organization/RHIO can submit a proposal including any or all or its participating member entities. Alternatively, any of the member entities could submit a proposal on its own, for its own patient base and rating factors.

Question# 5

Can companies, collaboratives, state or other institutions respond that qualify as “organizations representing Health Information Exchanges, Regional Health Information Organizations”?

Answer:

Yes Question # 6 Does the CCHIT Certified EMR system need to be in place before award, or can they be procured after award?

Answer:

The EMR system needs to be in place before the award. The CCHIT certification does not. See response to Question 1 for more details.

Question# 7 Are behavioral health organizations also eligible to apply?

Answer:

Yes

Question# 8

The Statement of Work (SOW), Section B-1, paragraph 3, entitled Minimum Requirements, states that the “installed EHR application must be certified by CCHIT or other Department of Health and Human Services recognized certification bodies”. CCHIT has suspended their certification testing pending finalization of the Meaningful Use criteria by the National Coordinator for Health Information Technology at the Department of Health and Human Services (HHS). CCHIT's current timeline is to re-start certification testing in Jan/Feb 2010. With this constraint established, will SSA allow a delay in achieving CCHIT Certification until such certification resumes?

Answer:

Yes. See response to Question 1.

Question# 9

In the event SSA allows a delay in achieving CCHIT Certification (question above), does SSA intend to delete all reference to properly certified contractor EHR applications? Specifically, First payment will be made after SSA approval of the Sample CCD submitted by the contractor, and verification that the contractor’s EHR application is properly certified.

Answer:

No, SSA does not intend to delete all reference to properly certified EHR systems applications. Please see response to Question 1 for details about the CCHIT certification requirement.

Question# 10

The Statement of Work, Section B-1, paragraph 5, entitled SSA Tasks, states that “SSA will perform the verification process and provide feedback” in several task areas to assess satisfactory task completion. Paragraph 6, of this same Section, entitled Contractor Deliverables, identifies comments for each task area that describe elements of completion by referring to relevant sections of the SOW. Will SSA provide additional qualification details to ensure that satisfactory completion of each task area in order to avoid, potentially, several iterations of the verification process before completion is verified?

Answer:

SSA will provide detailed feedback including identifying technical/content gaps and discrepancies in an effort to reach satisfactory completion of Verification testing with as few iterations as possible. Resubmissions will be re-verified, not only for the notified changes, but also to ensure that there is no negative impact to other areas of the Verification CCD as a result of said changes.

Question# 11 Could you please provide a more specific timeline by when each milestone needs to be accomplished?

Answer:

All tasks must be completed within 1 year of the notice to proceed. We plan to issue all notices to proceed by September 2010. Specific milestones need to be included in the offeror’s technical project plan.

Question# 12 Additional guidance is requested on the patient authorization process. SSA is providing a patient authorization for release of information – is there any additional validation needed on the part of the contractor?

Will we need to get patient authorizations in each case to match the SSA authorization?

Answer:

SSA will attach an image of a signed form SSA-827, Authorization to Disclose Information to the Social Security Administration (SSA), just as it does now for each conventional request. SSA will also provide key elements of the form as data. The SSA-827 complies with all federal and state laws governing release of information. Please see http://www.ssa.gov/disability/professionals/ssa827_informationpage.htm for additional details, including feedback from HHS. It is the individual medical providers' responsibility to assess their legal obligations for disclosure of personally identifiable information.

Question# 13 EHR Checklist, row 61: As an EHR vendor proposing to become a contractor in this project, will we need to provide the names of all of our client physicians/practices and their transaction volumes?

Would it be sufficient to describe the client base and the total transactions that we expect to see from the group? All clients on our system will be participating – the list would be quite long.

Answer:

Yes – all of the client physicians/practices and transaction volumes need to be listed. A group listing is not sufficient. However, only those participating client physicians/practices need to be included.

Question# 14 EHR Checklist, section 7: As an ambulatory EHR vendor, how should we answer questions about clinical documentation that the provider included in the patient’s record, but did not originate? For example, providers include copies of the discharge report as faxed by the hospital, but we would not normally be the one to process this in an information release request.

Answer:

The proposal should provide answers relative to the information that is available to release as part of your proposed CCD. If scanned or otherwise imported information is available, please describe and/or provide a sample of the associated metadata.

Question# 15 In section B-1, 3.2, Minimum Requirements, the RFP states that “the Contractor’s installed EHR application must be certified by CCHIT”. Our HIE/RHIO is interfaced to multiple healthcare data providers and from one provider receives medical records information from multiple non-certified EHR/clinical applications, including their patient registration systems, medication management system, laboratory information system, radiology information system, and their clinical documentation/transcription system. If, from these multiple clinical systems we are able to create and send a CCD that adheres to SSA technical specifications, is CCHIT certification still a requirement for each of their EHR/clinical applications?

Answer:

Yes. See response to Question #1.

Question# 16 In section B-1, 4.2.1, Task Area 2: CCD Content Tasks, the RFP states that “the Contractor shall produce a Sample CCD based on available EHR content generated from their participating healthcare providers/facilities.” What is the required timeline for producing the Sample CCD?

Answer:

It is estimated to take approximately 3 – 6 months after awards are made and notices to proceed are issued for the submission and approval of the Sample CCD to be completed.

Question# 17 In section B-1, 1.6, Overview - Payment for medical evidence, the RFP states that “Payment for medical evidence will be provided under a separate arrangement.” How do we pursue payment for medical evidence?

Answer:

Social Security is required to pay for any goods and services that we receive. Payment for medical records will be made as we receive the medical records.

Question# 18

a. Is there a limit for the number of pages for the application?

b. Page 23 – (c) Employee Disposal of PII; Is this information suppose to be added to the application?

c. Submission of offers is hereby revised as follows: (2) the time specified in the solicitation for receipt of offers? What does this mean?

Answer:

a. There is no page limit to this proposal.

b. Employee Disposal of PII is not applicable to this solicitation.

c. Your proposal submission should include the time in which the solicitation specifies receipt of offers. For purposes of this solicitation, the time for receipt of offers is 4:00 EST.

Question# 19 Does SSA provide statistical data, by regions and/or by healthcare institutions, of medical evidence requests made in the last 12 months? Where can we find statistical data about request made by SSA in the last 12 months?

Answer:

No, SSA will not provide the statistics. The HIPAA Privacy Rule, 45 CFR 164.528, requires an accounting of disclosures of protected health information, including the name of the entity or person who received the information, so the health information management staff within your own organization should have that data.

Question# 20 In the evaluation process, clarify how the four different factors are weighted in the final decision (ex, Technical-Satisfactory/Price- Lower versus Technical-Outstanding/Price-Higher).

Answer:

Evaluation factors are listed in descending order of importance. In order to determine which offeror represents the best value, the Government will make a series of paired comparisons among offerors who submit acceptable offers. The Government may award to other than the lowest priced offeror based on a trade-off of the four factors.

Question# 21 If the RFP is being submitted for multiple EHRs what would be the process for receiving the payments for the certification and sample CCD submission, would it be when the first EHR is certified and the sample CCD is submitted or would all EHRs need to be certified and CCDs received from each EHR?

Answer:

All participating EHR systems need to be certified. CCDs received should include available information from all participating EHR systems.

Question# 22 Does the SSA have a population size preference? We have Medicaid claims data going back over 10 years and this data is available to Medicaid providers through an HIE. Another option is to choose a small provider engaged in a RHIO that has not only the Medicaid Claims data but other payers as well. The only difference between the two would be population size; both projects are based on a Health Information Exchange platform.

Answer:

SSA does not have a population size preference. See the RFP, page 47, Section G item #4 on how the determination of best value will be evaluated.

Question# 23 What is the revenue size limit for “small business” and if we are one, do we have to fill out the Small Business Subcontracting Plan?

Answer:

The size standard for this solicitation is $34.5 million (NAICS Code 622110). The Small Business subcontracting Plan is required with proposal submission if the offeror is not a small business, and the offer exceeds $550,000.

Question# 24 Question removed - not applicable to the RFP. ___________________________________________________________ Question# 25 Can we provide information from our Clinical Data Warehouse as opposed to our transactional database? The data warehouse is refreshed every 24 hours. A requirement to use the transactional database may impose significant burdens on transactional response time in the production environment.

Answer:

As long as the organization can respond to the requirements contained within the Statement of Work, we have no preference.

Question# 26 Will this effort fund mapping of local nonstandard document and data codes to standard codes such as SNOMED CT, RXNORM or HL7 codes? We currently use a detailed non standard homegrown coding system for diagnoses and problems. The system is more granular than ICD-9. We have document types coded using non standard codes. Our medication data is coded with FIrst Databank codes and is not mapped to RXNORM. Will this project fund mapping some or all of this content to standards such as SNOMED CT, HL7 and RXNORM codes?

Answer:

SSA does not specify the methods or technical steps needed to meet the critical factors and requirements detailed in the RFP.

Question# 27 Per the RFP, a minimum requirement is that the installed EHR application must be certified by the CCHIT or other Department of Health and Human Services recognized certification bodies. Per the CCHIT website, only one company is certified for enterprise electronic health records. Does this mean my firm should not bother to submit a response to the RFP?

Answer:

You may respond. See response to Question #1 for more information.

Question# 28 CCHIT Certification for EHRs - Does the SSA contemplate some flexibility in the use of a combination of CCHIT certified and non-certified EHRs? For example could our proposal include 10 hospitals running the certified version of Meditech (5.6) and two hospitals running a pre-certification release of Meditech (5.5)?

Answer:

Certification must be obtained by all participating EHR applications. See response to Question #1 for more information about the timeframes needed for the certifications.

Question# 29 Would the SSA consider dis-engaging the requirement for providers to be using a certified EHR? We believe that the inpatient certification designation from 2007 is irrelevant to the interoperability required by this RFP.

Answer:

No. See response to Question #1.

Question# 30 We understand the timing expected for the SSA Tasks in Section 5, and would like to understand if SSA intends to coordinate all contracts on an identical schedule or on a staggered schedule. In other words, will all successful proposals result in contracts let on the same day, or will the execution be spread over a period of time?

Answer:

We plan to award the contracts at the beginning of calendar year 2010. However, not all notices to proceed will be issued at that time. We plan to issue all notices to proceed by September 2010.

Question# 31 Do opportunities exist, associated with this solicitation that is appropriate for a small IT consulting business with interest and experience in Health IT?

Answer:

This acquisition is open to any organization or team that can meet the requirements specified in the solicitation.

Question# 32 As a state agency that operates a statewide health information exchange, which includes Medicaid claims and other data (and will be incrementally expanding to include hospitals, labs, and physicians from throughout the state) with the capacity to produce a Continuity of Care Document, do we meet the definition of an eligible entity?

Answer:

Yes

Question# 33 An HIE or provider gateway may be a different organization than the HIE administrative organization. Will SSA accept proposals from the technology vendor who handles the gateway?

Answer:

This acquisition is open to any organization or team that can meet the requirements specified in the solicitation.

Question# 34 Will the xacml define the type and duration of information that has been authorized or is it a general authorization for all information?

Answer:

SSA Form 827, Authorization to Disclose Information to the Social Security Administration (SSA), is a broad and specific authorization for information. The SSA-827 complies with all federal and state laws governing release of information. The XACML statement contains a rule-start-date and a rule-end-date which is a 12 month period.

Question# 35

Could local HIE consent policies be in conflict with the authorization from SSA?

Answer:

No. See response to Question #12.

Question# 36

A CCD is not currently in our HIE’s roadmap within one year. Will SSA consider proposals that may not begin implementation immediately after award?

Answer:

Requirement specified within the Statement of Work must be completed within 1 year of the notice to proceed. See responses to Questions #11 and #16 for further clarification.

Question# 37

Must the documents provided be in a structured xml format only or will scanned document level documents be sufficient?

Answer:

Please refer to SSA’s Implementation Guide located on www.SSA.gov/hit/rfi2.htm as well as Section 7 of the Content Checklist (Section E. Attachment 1 of the RFP) for details on the document requirements.

Question# 38

If an HIE did not respond to the RFI, can it still respond to the RFP?

Answer:

Yes

Question# 39

It is my understanding that the pilot with MedVirginia included uninterrupted transactions. Will this be a requirement in this RFP or will SSA allow interrupted transactions as long as they flow through the NHIN?

Answer:

No, the current NHIN protocols will not allow interrupted transactions but may be supported in the future.

Question# 40 How is SSA authenticating who has access to health information? Does SSA plan to use/require strong multi-factor authentication for this information exchange?

Answer:

SSA does not provide health information. A claimant signed SSA Form 827, Authorization to Disclose Information to the Social Security Administration (SSA), just as it does now for each conventional request, provides authorization for the release of medical information. The SSA-827 complies with all federal and state laws governing release of information. Please see http://www.ssa.gov/disability/professionals/ssa827_informationpage.htm for additional details authorizes SSA to access Health information.

Question# 41 Is it a requirement to use the NHIN connect gateway or can another gateway that conforms to all the NHIN standards and interoperability requirements be used in its place?

Answer:

It is not required to use the NHIN CONNECT gateway as long as the gateway conforms to the NHIN standards.

Question# 42

Will this RFP cover costs for implementing a NHIN gateway?

Answer:

SSA does not specify the methods or technical steps needed to meet the critical factors and requirements detailed in the RFP. We anticipate award of fixed-priced contracts.

Question# 43 Attachment #1 (EHR Content Checklist) states, “Minimum EHR content requirements for consideration of proposal: To be further considered for funding under SSA's ARRA contracts, proposals must indicate availability of structured data in the EHRs for at least one sub-element in this section of the EHR Content Checklist.”

a. How will the ability to provide the other remaining data elements be evaluated?

b. Will preference be given to organizations who are able to transmit a higher percentage of the information in the EHR Content Checklist?

c. Is the expectation that all data elements in the checklist will need to be submitted?

Answer:

a. The checklist details how the data elements will be evaluated.

b. Yes. The providers will be ranked based on the EHR content as stated in Section G of the RFP.

c. No. We do not expect that all data elements will be included. The content checklist provides the opportunity to detail which elements are available and which are not. The content checklist also highlights which are minimum content requirements.

Question# 44 Section F-1, pg. 42; How does Requirement 13 differ from Requirement 10, regarding the Electronic Health Records Content Checklist Document? Can SSA please clarify what is expected in the response to Requirement 13 regarding the Electronic Health Records Content Checklist Document?

Answer:

An offeror’s response to # 13 of section F-1 should supplement the offeror’s responses in the Electronic Health Records Content Checklist (#10). Responses should include demonstrated experience of the offeror’s organization in integrating the primary EHR with other information systems in the organization’s clinical context and any additional information that further describes the offeror’s demonstrated ability to perform the requirements of the solicitation.

Question# 45

Will the government accept aggregated CCDs?

Answer:

Yes. We prefer individual CCD’s; however, aggregate CCD’s are acceptable.

Question# 46 Will the government accept the HITSP32 in lieu of the ASTM?

Answer:

SSA will only accept CCDs, which are based on the efforts developed between ASTM and HL7.

Question# 47

What is the approval process for the sample CCDs?

Answer:

See the RFP, Section B - Statement of Work. This process is identified in Section 4.2.

Question# 48

Can an offeror include multiple geographic areas/RHIOs in their response?

Answer: Yes

Question# 49 If a healthcare provider partners with more than one HIE and both win does that exclude the organization or the health care provider?

Answer:

Not necessarily. While we cannot pay twice for the same service, to the extent that offers are not duplicative, they may be considered.

Question# 50 Is an organization limited to one proposal or may an organization submit multiple proposals– if so, will only one award be given?

Answer:

While we cannot pay twice for the same service, to the extent that offers are not duplicative, they may be considered.

Question# 51 Does the funding for the disbursement between partners or subcontractors needs to be defined in the proposal?

Answer:

No. However, information on subcontract costs should be outlined in the Small Business Subcontracting Plan if completion of the plan is required.

Question# 52

If a hospital is working with an HIE – could this be considered a joint venture?

Answer:

If the hospital and the HIE create a new business entity, then it would be considered a joint venture; however if the hospital and HIE are working together it should be considered a prime contractor and subcontractor relationship.

Question# 53 Do all subcontractors need to be defined in the proposal? Or can qualifications be defined?

Answer:

All subcontractors and qualifications need to be defined in the proposal.

Question# 54 If not planning to subcontract, how much of the Small Business Subcontracting Plan has to be filled in?

Answer:

If you are not subcontracting any part of this requirement, then the subcontracting plan does not need to be completed. However, please note the requirements of the subcontracting plan indicated on pg. 40 of the solicitation.

Question# 55 If the proposal contains multiple healthcare providers with multiple EHRs when will the requirement for EHR certification be met, when the first EHR is certified?

Answer:

See response to Question #21. All certifications must be completed.

Question# 56 Does the one year period of performance include the receipt of the 5% production records?

Answer:

Yes

Question# 57 Will SSA entertain proposals that specify a starting date in the May-July timeframe of 2010?

Answer:

Yes

Question# 58 The 5% production target is based on the annual volume of requests to the provider facility from the state DDS community. Due to the nature of SSA’s disparate legacy systems and varied representations of providers, this information is not readily available.

a. Will SSA provide a contact to obtain the number of requests for each participating facility for purposes of providing the response to the RFP?

b. Will the 5% include those requests that SSA does not identify which are received by mail?

c. What process will SSA use to verify the information provided in responses?

Answer:

a. No. The 5% figure is based on the estimated transaction volume figure(s) entered in section 3.0 of the Electronic Health Records Checklist for each organization, medical providers and facilities that will be participating. The estimated transaction volume is based on historical transaction data for release of information to the state DDS community. The health information management staff within your own organization should have that data.

b. SSA will not identify the estimated transaction volume. The computation pf the historical annual production volume expected may include transactions received by mail. The required production submittals, to meet the contract performance, as defined in RFP Section A-1; 0003, must come through the NHIN.

c. SSA will monitor the numbers of requests and responses and whether the responses comply with Section 4.2.3 of the Statement of Work in the RFP.

Question# 59 The use of an uninterrupted transaction removes the provider’s ability to assess the authorization as provided for by HIPAA. This places a risk on the provider. The employee in the field office may write restrictions on the SSA-827 which affect the validity to be used without review.

a. What actions has SSA taken with HHS/OCR to ensure this approach is acceptable?

b. Is a letter of approval available from HHS/OCR?

c. Will SSA provide information as to the rate of accurate completion of 827s?

d. Will SSA provide information as to the rate of modifications made to 827s to change the scope of the request?

e.

Were studies performed on the BIDMC and MedVirginia 827s?

f. How will SSA handle any authorizations found after the fact to have had problems?

g.

Will SSA modify their system to exclude any 827s with changes?

Answer:

a. SSA is working with the HHS-sponsored NHIN Cooperative to support interrupted transactions.

b. This information is not relevant to an offeror’s ability to respond to this solicitation.

c. This information is not relevant to an offeror’s ability to respond to this solicitation.

d. This information is not relevant to an offeror’s ability to respond to this solicitation.

e. This information is not relevant to an offeror’s ability to respond to this solicitation.

f. This information is not relevant to an offeror’s ability to respond to this solicitation.

g. This information is not relevant to an offeror’s ability to respond to this solicitation.

Question# 60 NHIN specifications are constantly changing.

a.

Will SSA accept the interrupted transaction which is being developed for the NHIN?

b.

If not, will SSA accept the transaction when approved for the NHIN if during the period of performance?

c.

Will SSA freeze the specifications, and at what version?

d. If the versions are different from one awardee start date to another awardee start date, is SSA prepared to support all environments so as not to disadvantage any vendor in meeting the 5% target?

e. Will SSA accept the transactions for moving unstructured data files which may not provide the codes necessary for MEGAHIT evaluation, but would provide substantial numbers of records within minutes?

Answer:

a. SSA will be implementing the approved NHIN specifications at the time of award and notice to proceed.

b. SSA will utilize the approved NHIN specifications at time of award and notice to proceed.

c. SSA has no control over the version of NHIN specifications. SSA will utilize the approved NHIN specifications at time of award and notice to proceed.

d. SSA plans to support compatible versions.

e. SSA will not accept unstructured data files via the NHIN.

Question# 61 Verification CCDs will be on patients selected by SSA. In some cases, not all data for the CCD may exist in the patient record. What process will SSA follow to ensure that selected patients have been treated sufficiently by the facility to ensure a fully populated CCD?

Answer:

SSA will screen current cases with medical evidence received traditionally from the facility, and identify cases with broad relevant content. The selected cases will provide a sufficient cross-section of the facility's types of medical records to evaluate the CCD.

Question# 62 Governance of the NHIN has not been resolved by ONC. Decision in this realm could impact awardees in significant financial ways during the period of performance.

a. Has ONC agreed to add the awardees to the NHIN Cooperative?

b. If decisions are made that would assess significant fees for any aspect of the NHIN participation, will SSA adjust the contract to cover these fees?

c. If not, will SSA provide an estimate of all potential NHIN fees?

d. If the awardees are not included in the NHIN Cooperative, what process will SSA put in place to leverage SSA’s representation to address issues raised by awardees?

Answer:

a.

This information is not relevant to an offeror’s ability to respond to this solicitation.

b.

SSA plans to issue a firm fixed-price contract.

c.

No d.

This information is not relevant to an offeror’s ability to respond to this solicitation.

Question# 63 SSA’s post-5%-production plans may impact the investment necessary. Does SSA intend to continue the process with those vendors who choose to maintain this system?

Answer:

Yes. However, SSA will not continue to pay the offeror to maintain the system upon expiration of the contract.

Question# 64 SSA has asked for a fixed price contract under this RFP. Would the Agency consider an alternate “fixed price” model using the same milestones as listed in Section A-1, but using a price based on the number of providers, certified EHRs, or institutions included, which might change over time as the solution matures and more providers are added?

Answer:

No

Question# 65 Section 4.3.3 of the Statement of Work requires that the contractor “…develop a system to support the following NHIN transactions…” which includes Health Information Event Messaging (HIEM). Since the HIEM is not currently part of the SSA transaction for disability determination, is a solution that does not implement HIEM but does implement the full SSA transaction using the Messaging Platform, Authorization Framework, Subject Discovery, Query for Documents, and Retrieve Documents sufficient and acceptable?

Answer:

HIEM is used as an example of the NHIN transactions and even though it is not currently implemented as part of the transaction set used for SSA disability, it may be utilized in the future specifications.

Question# 66 Please confirm that you want the technical approach and pricing information in the same volume.

The technical information and price information should be submitted as two separate volumes.

Question# 67 Is there a limit for the proposal? Could you specify the limit, and which sections are applicable to the page count?

Answer:

No, there is no page limit.

Question# 68 Would the SSA be able to provide historical transaction data for the State Disability Determination Services sites for previous years?

Answer:

No, SSA will not provide the historical transaction data. The HIPAA Privacy Rule, 45 CFR 164.528, requires an accounting of disclosures of protected health information, including the name of the entity or person who received the information, so the health information management staff within your own organization should have that data.

Question# 69 Section 2.1.1.1 of the RFP states “Sample CCD is based on de-identified electronic health record content generated from the participating healthcare providers/facilities' EHR system”

a) Is the “Implementation Guide for Healthcare Partner” the only technical specification of Continuity of Care Document (CCD)?

b) If not, what other technical specification exist?

c) Is the CCD the same as “structured medical information”?

d) Are there any open/proprietary source code for CCD creation, dissemination, and aggregation?

e) Is there a WSDL (Web Services Definition Language) defined for CCD?

f) Is there a mapping reference between CCD and HL7?

g) Are there any vendors/systems/repositories certified as CCD compliant?

Answer:

a. No, However the Implementation Guide is SSA’s technical specifications.

b. The CCD specification is a structured constraint on the HL7 Clinical Document Architecture (CDA) standard. Refer to website www.HL7.org for more information.

c. The CCD specification is a structured constraint on the HL7 Clinical Document Architecture (CDA) standard. Refer to website www.HL7.org for more information.

d. Refer to website www.HL7.org for more information.

e. Technical specifications can be located on www.SSA.gov/hit/rfi2.htm

f. Refer to website www.HL7.org for more information.

g. For a list of certified Electronic Health Records applications see http://www.cchit.org/

Question# 70 Section 1.4 of the RFP states “Medical providers need a certified Electronic Health Record (EHR) application and must be able to demonstrate the technical ability to create a Sample CCD with de-identified electronic health record information.”

a. Is there a list of certified EHR applications? Is CCHIT the only authority?

b. Is there a definition of “technical ability to create a Sample CCD with de-identified electronic health record information.”? Who and what determines “technical ability”?

c. What is the sufficient medical information to support SSA’s disability program? Are there any specification/protocols?

d. How does SSA plan to validate the content and interoperability of the CCD?

Answer:

a.

Currently CCHIT is the only authority. The website cited in the RFP provides this information. See www.cchit.org for further information.

b.

The information contained in the RFP, Section B details the technical criteria. This information is also detailed in SSA’s Implementation Guide can be found on www.SSA.gov/hit/rfi2.htm c.

See SSA’s Implementation Guide can be found on www.SSA.gov/hit/rfi2.htm and the EHR Content Checklist – RFP Section E; Attachment 1.

d.

This information is not relevant to an offeror’s ability to respond to this solicitation.

Question# 71 Section 4.1.2 of the RFP states that the contractors system shall conform to the most current industry standards, including HL7, IHE, CDA, CCD, and HITSP”. Is the NIST CCD the tool for CCD compliance?

Answer:

Yes

Question# 72 Section 4.2.1 of the RFP states that the Contractor shall produce a Sample CCD based on available EHR content generated from their participating healthcare providers/facilities. What CCD segments are required/optional in the sample CCD?

Answer:

The details for the required content for the EHR content are provided in Section 7 of the EHR Content Checklist and SSA’s Implementation Guide.

Question# 73 Section 4.2.3 - Can you identify the systems that will participate the Production CCD exchange?

Answer:

The offeror’s developed production system for this solicitation, as well as SSA’s system and the NHIN gateway.

Question# 74 Section 4.3.1 - Is there any current use of the CONNECT gateway software at SSA?

Answer:

This information is not relevant to an offeror’s ability to respond to this solicitation.

Question# 75 Section 4.2.3 talks about volume, it says “…a minimum number of production CCDs up to 5% of their expected annual volume”. We are an HIE and process approximately 3 million results each month. Could you please clarify whether or not you mean 5% of the total volume or records that come through our HIE for the community or 5% of the annual volume of all disability determinations for our geographical area or 5% of each participating provider’s disability determinations?

Answer:

Up to 5% of the offeror’s production volume with SSA.

Question# 76 Section 4.2.1 discusses the generation of a Sample CCD. Does ‘a Sample’ mean ONE CCD, period; or ONE CCD from each participating provider?

Answer:

One CCD from each participating EHR System.

Question# 77 Section 4.3.9 – could you please provide specifics around ‘…Contractor shall support NHIN interoperability testing for all SSA lifecycle environments’. Do you have more specifics regarding your definition of ‘support?

Answer:

The support is evaluated based on what the offeror includes in its technical proposal in response to Section 4.3.9 and 4.3.10.

Question# 78 Section 5 - SSA Tasks – Are there any more specifics regarding exactly what items will be reviewed in order for SSA to Approve a Production CCD? For example, it mentions ‘….will be reviewed for Content and Compliance with Standards.’ Are there any criteria - in addition to Content and Compliance with Standards - that we must pass?

Answer:

No additional criteria are available. The production CCDs will be evaluated based on content and continued compliance with the standards as stated in the Statement of Work.

Question# 79 If an EMR is in the CCHIT certification process, will the proposal from this EMR be allowed?

Answer:

Yes. See response to Question #1 for more details.

Question# 80 ONC has stated that certification bodies other than the CCHIT will be used to certify EMRs, but these certification bodies have not yet been named. Will proposals for uncertified EMRs be accepted if the EMR makes a commitment to become certified either by CCHIT or by the other ONC-approved certification bodies?

Answer:

Yes. See response to Question #1 for more details.

Question# 81 Since the current written authorization speaks to releasing information "regarding my treatment, hospitalization, and outpatient care for my impairment(s)" does SSA require the ability for data to be filtered to exclude clinical data that is not relevant, especially if it might contain particularly sensitive health information?

Answer:

No, the claimant-signed authorization form SSA-827, Authorization to Disclose Information to the Social Security Administration is a very broad authorization. The SSA-827 complies with all federal and state laws governing release of information. It is the providers' responsibility to determine limitations under existing law and regulation. However, as noted on the form SSA-827, providers should exclude separately housed sensitive information, as strictly defined in 45 CFR 164.501.

Question# 82 Can an organization that creates a CCD with more data elements than SSA details in its implementation guide just submit that CCD or does it need to be filtered to only include the specific SSA payload?

Answer:

The data does not have to be filtered. However, the "additional" data should be identifiable by the normal demarcation mechanisms available within the CCD standard (i.e. - use of <templateId> and <id> elements).

Question# 83 Does every participating provider need to have a certified EHR system implemented in its practice, or can a subset of participating providers meet that requirement?

Every provider, participating in the offer, needs to have a certified EHR system. See Question #1 for more details.

Question# 84 Does SSA require representations and certifications from subcontractors?

Answer:

Yes, either through completion of the representations and certification provision in the RFP or via the Online Representations & Certification Application (ORCA) system.

Question# 85 What are the SSA requirements for security certificates?

Answer:

See the RFP, Section B - Statement of Work, refer to Section 4.3.6

Question# 86

Would NHIN specify and align with HITSP C32 v2.5 for CCD definition?

Refer to the following website listed in the RFP: NHIN Transactions http://healthit.hhs.gov/NHIN (Look for "Interface Specifications" under "Resources")

Question# 87 What is the NHIN position on HIE aggregation of data across multiple sources vs. support of specific OIDs?

Refer to the following website listed in the RFP: http://healthit.hhs.gov/NHIN

Question# 88 At what level does SSA interpret OIDs? Sending application along with separate OIDs for each environment?

Answer:

SSA has assigned a separate OID to each of its testing environments and has the ability to identify gateways with separate OIDS.

Question# 89 What sort of protocol is required for transporting/accepting unstructured data to SSA?

Answer:

At this time, SSA is not accepting unstructured data via the NHIN.

Question# 90 Is the C62 (CCD-wrapped PDF) construct acceptable or is that to be determined over the course of the project?

Answer: Yes.

Question# 91

Which version of the NHIN specifications is expected to be utilized?

Answer:

Vendor is expected to utilize the NHIN specifications in use at time of award and the notice to proceed.

Question# 92 Are state-level systems and determination included in the scope of this solicitation?

Answer:

This information is not relevant to an offeror’s ability to respond to this solicitation.

Question# 93

Will states receive copies of the records retrieved?

Answer:

The state disability determination services (DDS) will have access to the medical information we receive and will use the medical information we receive in the medical eligibility determination of a claimant’s application for Social Security disability benefits in accordance with social security policies.

Question# 94 From the perspective of the HIE responding to the RFP…Does the HIE only respond to requests with the data “known” by the HIE, or does the HIE need to go out to providers in the region to request additional records that may not already be “known” by the HIE?

Answer:

If the HIE proposes to use a central repository (SSA's interpretation of "known") to obtain medical records, the repository should be regularly refreshed with current clinical information from the individual providers. If the HIE will use a distributed model, requests for additional records are expected. Such issues should be discussed in the technical proposal.

Question# 95 Do requests come from SSA 24 x 7? If so, is the 5 hour response time required around the clock?

Answer:

Yes, currently 24 x 7.

Question# 96

Does the 5 hour response time to the request take into account the possibility of an ambiguous patient match based on the patient demographics sent with the request from SSA and the need for human intervention on the HIE side to determine the appropriate patient match to respond to the SSA request?

Answer:

The current NHIN protocols do not support human intervention (interrupted) for patient match and assumes exact patient match scenarios only.

Question# 97

FAR Clause 52.219-9, Small Business Subcontracting Plan (April 2008)

The commercial terms and conditions include the referenced FAR provision, which requires submission of a small business subcontracting plan reflecting the offeror’s goals for subcontracting with subcontractors. Since the government intends to award a firm-fixed price contract and has not required and cost or pricing data, we believe it is inappropriate to require cost reporting during project execution. Would the government consider waiving that provision as well as FAR clause 52.219-16, Liquidated Damages - Subcontracting Plan which is included by reference in section C-2?

Answer:

No

Question# 98 It is our understanding that non-profit organizations are considered large businesses for the purposes of the small business subcontracting requirements regardless of their staff size and/or yearly revenues. Can you clarify whether non-profits can be considered small businesses? If not, would SSA consider waiving the small business plan requirement for non-profits that meet the size standard?

Answer:

According to the U.S. Small Business Administration, the term “other-than-small” business refers to any entity that is not classified as a small business. This includes large businesses, state and local governments, non-profit organizations, public utilities, educational institutions, and foreign-owned firms that receive Federal contracts, if any portion of the contract is to be performed in the United States. Therefore, non-profit organizations cannot be considered as small businesses. In addition, SSA cannot waive the small business plan requirements for non-profit organizations.

Question# 99 Section A.1 - Where are the facilities required to reside?

Answer:

There is no geographical requirement under this solicitation.

Question# 100 Section 1.1 - Is the Contractor allowed to include a solution to improve the Social Security Administration (SSA) disability program in the proposal?

Answer:

At this time, SSA is not requesting additional solutions; rather, we are requesting responses to our proposed solution.

Question# 101 Section 4.2.3 - What is the current standard for SSA requesting medical records electronically from providers?

Answer:

This information is not relevant to an offeror’s ability to respond to this solicitation.

Question# 102 Who are the Medical providers? Is there a list?

Answer:

This information is not relevant to an offeror’s ability to respond to this solicitation.

Question# 103 Are RHIOs or other organizations considered as Medical Providers?

Answer:

Yes, as long as the RHIO has access to the medical records.

Question# 104 Section 2.1.1 states “The proposed consensus standard for a patient health summary that harmonizes use of the ASTM Continuity of Care Record (CCR) and HL7 Care Record Summary (CRS). It is designed to operate within the HL7 Clinical Document Architecture.” Are there any design documents/references that are available?

Answer:

Refer to the following website listed in the RFP: www.HL7.org

Question# 105 Section 2.1.1 states “It contains various sections such as patient demographics, insurance information, diagnosis and problem list, medications, allergies and care plan.” Is there a data dictionary/XML schema of CCD?

Answer:

The CCD specification is a structured constraint on the HL7 Clinical Document Architecture (CDA) standard. All data sections and schema can be based on the HL7 CDA standards. See www.HL7.org for more information.

Question# 106 Section 4.1.4 - Is there a list of NHIN standard transactions and expected Service Level Agreements (SLAs)?

Answer:

See the RFP, Section B - Statement of Work, refer to section 4.3.3 for the SSA required NHIN transactions.

Question# 107 Section 4.2.2 - “The Verification CCDs must be developed in compliance with the guidelines provided in SSA’s Implementation Guide”. Can you refer to specific section in the Implementation Guide?

Answer:

The Implementation Guide should be reviewed in its entirety.

Question# 108 Section 4.3.3 - “The Contractor shall develop a system to support the following NHIN transactions” Are there any requirements for such system?

Answer:

Refer to the NHIN website referenced in the RFP and the Implementation Guide.

Question# 109 If an HIE proposes delivering volume for multiple provider entities, how can we know how much volume to estimate per provider?

Surveying hundreds of practices to see how many SSA requests they receive each year would be exhaustively time consuming. Do you have a breakdown of SSA record requests by provider tax ID and by provider specialty?

a. How are the 15 million record requests spread?

i. Geographically

ii. By provider type

iii. By provider specialty

iv. By provider tax ID

b. How are the 10.5 million responses (70% of the requests) spread?

i. Geographically

ii. By provider type

iii. By provider specialty

iv. By provider tax ID

Answer:

The estimated transaction volume is required information that must be submitted in section 3.0 of the Electronic Health Records Checklist for each organization, medical providers and facilities that will be participating. The estimated transaction volume is based on historical transaction data for release of information to the state DDS community. The HIPAA Privacy Rule, 45 CFR 164.528, requires an accounting of disclosures of protected health information, including the name of the entity or person who received the information, so the health information management staff within your own organization should have that data . The information requested in parts "a" and "b" of the question is not relevant to an offeror's ability to respond to this solicitation.

Question# 110 What service levels are being contemplated between SSA and HIE / NHIN Gateways?

Answer:

This information is not relevant to an offeror’s ability to respond to this solicitation.

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