Tab 3 - PWS 06-08-2026 Final Version - Area Wide HIM Coding BPAs.docx

PERFORMANCE WORK STATEMENT (PWS)

Navajo Area Indian Health Service (NAIHS) Health Information Management (HIM) Medical Coding and Data Entry Services PWS No. NAIHS-HIM-26-01 [Month Year]

Document Revision History

[Date]

Table of Contents

· 1.0 General Information

· 2.0 Specific Requirements/Tasks

· 3.0 Contractor Quality Control

· 4.0 Delivery and Deliverables

· 5.0 Contractor Personnel Requirements

· 6.0 Special Instructions

· 7.0 Government Furnished Information and Systems

· 8.0 Security and Confidentiality

· 9.0 Performance Requirements Summary

· 10.0 Glossary of Abbreviations and Acronyms

1.0 General Information

1.1 Introduction

The Indian Health Service (IHS) is an agency within the United States Department of Health and Human Services responsible for providing federal health services to American Indians and Alaska Natives. The Navajo Area Indian Health Service (NAIHS) administers health centers and hospitals providing health care to approximately 201,583 members of the Navajo Nation across a reservation encompassing more than 25,516 square miles in northern Arizona, western New Mexico, and southern Utah.

NAIHS Health Information Management (HIM) programs support revenue integrity, clinical data accuracy, and regulatory compliance across all NAIHS Service Units. Accurate and timely medical coding is essential to Third Party Revenue collections under the ORAP program, compliance with federal coding standards, and accurate clinical and administrative data reporting.

This Performance Work Statement defines the requirements for remote outpatient and inpatient medical coding and limited data entry services on an as-needed basis in support of NAIHS HIM programs at all NAIHS Service Units.

1.2 Objective

The objective of this contract is to ensure timely, accurate, and compliant medical coding and data entry for ambulatory and inpatient encounters across all NAIHS Service Units. Contractor performance shall be evaluated based on quality, accuracy, timeliness, and regulatory compliance rather than level of effort. This requirement is limited exclusively to medical coding and associated data entry services. It does not include other revenue cycle management functions such as billing, collections, or accounts receivable.

1.3 Scope of Work

The Contractor shall provide professional medical coding and related data entry services for outpatient and inpatient encounters documented in the IHS Electronic Health Record (EHR) and Resource and Patient Management System (RPMS) across all NAIHS Service Units listed in Section 1.8.

Services include analysis of clinical documentation, assignment of appropriate diagnostic and procedural codes, data entry into RPMS/PCC, and identification and resolution of documentation deficiencies. Services may be performed by individual certified coders or teams of coders, depending on staffing shortages, workload surges, or coding backlogs at individual Service Units.

All work shall be performed remotely using Government-authorized systems and secure connections established in accordance with Section 8.0.

1.3.1 Call Order Mechanism

Services under this contract are ordered on an as-needed basis through individual call orders issued by the Contracting Officer. The Government does not guarantee any minimum volume of work. Call orders will identify the applicable Service Unit, the encounter type, the applicable coding period, and the number of encounters to be coded. The Contractor shall begin performance within the timeframe specified in each call order, which will not be fewer than five (5) business days from the date of call order issuance unless the Contractor agrees to a shorter commencement period.

The Government may place call orders with any Contractor holding a Blanket Purchase Agreement (BPA) under this requirement. Call order competition procedures are at the discretion of the Contracting Officer consistent with FAR 13.303-5.

1.4 Background

NAIHS HIM programs experience periodic coding backlogs and staffing vacancies driven by the remote and rural nature of NAIHS Service Unit locations and the ongoing national shortage of certified medical coders experienced in IHS and tribal health systems. Contract coding services supplement permanent HIM staff capacity to maintain coding currency, reduce backlog, and protect Third Party Revenue collections.

1.5 Acquisition Approach

This acquisition is organized around measurable outcomes. The Contractor's obligation is to deliver accurate, timely, and compliant coded encounters as defined in this PWS. The Government does not prescribe how the Contractor shall organize its internal coding workforce, assign work, or manage its quality control processes, provided the outcomes defined in this PWS are achieved.

1.6 Type of Contract Contemplated

Services under this contract are priced on a firm-fixed, all-inclusive per-encounter basis by encounter type, as established in the BPA pricing schedule. The per-encounter rate encompasses all costs of performance including coder labor, fringe benefits, overhead, general and administrative expenses, quality control, and profit. No separate payment will be made for any of these cost components. Pricing terms and payment conditions are addressed in the BPA terms and conditions.

1.7 Period of Performance

Each BPA established under this solicitation shall have a period of one (1) year from the date of establishment, with up to four (4) annual renewal periods at the Government's discretion, for a total potential BPA period of five (5) years. BPA renewals are contingent upon the continuing need for services, the availability of funds, and satisfactory Contractor performance as documented through the Government's quality assurance surveillance activities.

Individual call orders may be placed at any time during the BPA period. The period of performance for each call order shall be specified in the call order.

1.8 Place of Performance

All services shall be performed remotely from the Contractor's place of business using secure Government-authorized access to RPMS and IHS EHR systems. Services are provided in support of all NAIHS Service Units, which include:

The applicable Service Unit will be identified in each call order.

1.9 Applicable Documents

The Contractor shall perform all work in compliance with the following:

· IHS ORAP Internal Control Policy and Revenue Operations Manual

· ICD-10-CM Official Guidelines for Coding and Reporting (current year)

· ICD-10-PCS Official Guidelines for Coding and Reporting (current year)

· CPT Editorial Panel Guidelines (current year AMA publication)

· HCPCS Level II Guidelines

· CMS Evaluation and Management Documentation Guidelines

· National Correct Coding Initiative (NCCI) Edits

· Local Coverage Determinations (LCDs) applicable to IHS facilities

· Health Insurance Portability and Accountability Act (HIPAA) of 1996

· Privacy Act of 1974

· Computer Security Act of 1987

· IHS General Directives: http://www.ihs.gov

· IHS Computer Security Directives: http://security.ihs.gov

· AHIMA Standards of Ethical Coding

· AAPC Code of Ethics

2.0 Specific Requirements/Tasks

2.1 Task 1 – Outpatient and Ambulatory Medical Coding

The Contractor shall accurately code outpatient and ambulatory encounters documented in the IHS EHR using all applicable coding conventions. The Contractor shall:

· Assign appropriate diagnosis codes using ICD-10-CM, coded to the highest level of specificity supported by clinical documentation;

· Assign appropriate procedure codes using CPT, HCPCS Level II, CDT, or DSM, as applicable to the encounter type;

· Assign Evaluation and Management (E/M) levels in accordance with current CMS E/M documentation guidelines;

· Apply modifiers correctly and in accordance with NCCI edits and applicable LCD requirements;

· Review ancillary services — including pharmacy, radiology, and laboratory — and merge into encounters when appropriate and consistent with IHS coding policy; and

· Enter all coded data into RPMS/PCC in accordance with Section 2.3.

Turnaround Standard: Outpatient and ambulatory encounters shall be coded and entered into RPMS/PCC within five (5) business days of the date the encounter is made available to the Contractor for coding.

2.2 Task 2 – Inpatient Medical Coding

The Contractor shall accurately code inpatient records in accordance with ICD-10-CM and ICD-10-PCS Official Guidelines. The Contractor shall:

· Review inpatient records for documentation completeness and accuracy prior to coding;

· Assign final diagnoses and all procedures performed using ICD-10-CM and ICD-10-PCS, coded to the highest level of specificity supported by documentation;

· Assign the appropriate Diagnosis Related Group (DRG) and apply Major Complication or Comorbidity (MCC) and Complication or Comorbidity (CC) designations accurately; and

· Enter all coded data into RPMS/PCC in accordance with Section 2.3.

Turnaround Standard: Inpatient records shall be coded and entered within thirty (30) calendar days of the date of patient discharge, or within thirty (30) calendar days of the date the record is made available to the Contractor, whichever is later.

2.3 Task 3 – Data Entry Services

The Contractor shall enter all encounter data into the RPMS Patient Care Component (PCC) accurately and completely, including:

· All diagnosis and procedure codes assigned under Tasks 1 and 2;

· Visit-specific data elements required for GPRA reporting and Promoting Interoperability indicators, when not auto-populated by the system; and

· Any additional data elements required by the applicable Service Unit's HIM program as specified in the call order.

All data entry shall be performed concurrently with coding and completed within the turnaround timeframes established in Sections 2.1 and 2.2.

2.4 Task 4 – Documentation Deficiency Management

The Contractor shall identify incomplete or insufficient clinical documentation that prevents accurate code assignment and manage deficiencies as follows:

· Notify the provider of the deficiency through RPMS/EHR or the Secure Data Transfer System (SDTS) within two (2) business days of identifying the deficiency;

· Track all open deficiencies and perform follow-up with the provider at intervals not to exceed five (5) business days per attempt;

· Escalate unresolved deficiencies to the Service Unit HIM Point of Contact after three (3) unsuccessful follow-up attempts; and

· Include deficiency status in the weekly deficiency report required by Section 4.0.

The Contractor shall charge the Government only once per completed encounter, regardless of the number of deficiency follow-up attempts required to obtain sufficient documentation for coding.

2.5 Task 5 – Reporting

The Contractor shall submit the following reports in accordance with Section 4.0:

· Weekly Deficiency Status Report — a summary of all open deficiencies by Service Unit, including the encounter identifier, provider, deficiency type, date of initial notification, number of follow-up attempts, and current status;

· Monthly Performance Report — a summary of completed encounters by Service Unit and encounter type, coding accuracy rate based on the Contractor's internal quality audit, on-time completion rate, backlog status, and any issues or risks identified during the period; and

· Ad Hoc Reports — as requested by the COR or Service Unit HIM Point of Contact with reasonable advance notice.

3.0 Contractor Quality Control

3.1 Quality Control Plan

The Contractor shall develop, implement, and maintain a Quality Control Plan (QCP) to ensure services performed under this contract meet the standards set forth in this PWS. The Contractor shall submit the QCP to the CO within 15 calendar days of BPA establishment. The Contractor shall update the QCP whenever a material change in operations, coding methodology, or quality control processes occurs, and shall submit the updated QCP to the CO within 10 calendar days of the change.

3.2 Minimum QCP Requirements

At a minimum, the QCP shall address:

· The Contractor's internal coding audit process, including audit frequency, sample size methodology, and the process for identifying and correcting coding errors;

· The Contractor's process for monitoring coder certification currency across all personnel performing services under this contract, including the frequency of checks and the system used to track expiration dates;

· The Contractor's process for identifying and responding to a coder whose certification lapses or is subject to adverse action, including the timeline for notifying the CO and removing the affected coder from performance;

· The Contractor's approach to managing workload surges, backlogs, and multiple concurrent call orders across Service Units;

· The Contractor's internal complaint and corrective action process, including how coding errors, documentation deficiencies, and performance concerns are identified, documented, and resolved; and

· The name, certification credentials, and contact information of the Contractor's designated quality control manager.

3.3 Government Rights

The Government will conduct its own surveillance of contract performance through the QASP maintained separately by the COR. The existence of the Contractor's QCP does not reduce or replace the Government's independent surveillance activities. The Government reserves the right to conduct coding audits of any encounters coded under this contract at any time during the period of performance.

4.0 Delivery and Deliverables

5.0 Contractor Personnel Requirements

5.1 Certification Requirements

All personnel performing coding services under this contract shall maintain current, active certification through the American Health Information Management Association (AHIMA) and/or the American Academy of Professional Coders (AAPC) throughout the period of performance. Acceptable credentials include:

Outpatient and Ambulatory Coding: CCS, CCS-P, CPC, CPC-P, COC Inpatient Coding: CIC, CPC-H The Contractor shall ensure that coders are assigned to encounter types consistent with their certification. Inpatient coding shall be performed only by personnel holding an inpatient-appropriate certification. The Contractor shall notify the CO within 24 hours of any coder whose certification lapses, is suspended, or is subject to adverse action, and shall immediately remove that coder from performance under this contract.

5.2 Experience Requirements

All personnel performing coding services under this contract shall have:

· A minimum of two (2) years of recent medical coding experience relevant to the encounter types they will code under this contract; and

· Demonstrated experience using RPMS, IHS EHR, PCC, or a comparable federal or tribal healthcare electronic health record system. Coders without prior RPMS experience shall complete Government-provided RPMS orientation before performing independent coding under this contract.

5.3 HSPD-12 Security Clearance and System Access

Each coder performing services under this contract shall complete the Homeland Security Presidential Directive 12 (HSPD-12) security clearance process, including fingerprinting and a background investigation, before being granted access to RPMS, IHS EHR, or any other Government information system. The Contractor shall:

· Initiate the HSPD-12 process for each coder sufficiently in advance of their scheduled start date to allow for clearance completion;

· Account for HSPD-12 processing timelines — which may require 14 to 30 calendar days for a complete and acceptable package — in all call order planning and staffing submissions;

· Notify the CO immediately if a coder receives an unfavorable adjudication or if information arises that may affect the outcome of a pending investigation; and

· Remove from performance any coder who receives an unfavorable adjudication and provide a replacement as needed.

At a minimum, a coder may begin work upon receipt of a favorable FBI National Criminal History Check (fingerprint check) result, provided all other pre-placement requirements of this section have been satisfied and a complete background investigation package has been submitted.

5.4 Language and Communication Requirements

All coders performing services under this contract shall read, write, speak, and understand English sufficiently to communicate effectively with providers, HIM staff, and Government personnel, and to accurately interpret clinical documentation written in English.

5.5 Privacy and Security Training

Prior to being granted access to any Government information system, each coder shall complete all IHS-required IT security and privacy training, including HIPAA and Privacy Act training. The Government will provide access to required training through Government-authorized channels. The Contractor bears responsibility for ensuring all its personnel complete required training before system access is granted.

6.0 Special Instructions

6.1 Continuity of Services

The Contractor shall maintain uninterrupted coding services throughout the period of performance for all active call orders. The Contractor's obligation to ensure continuity includes maintaining a sufficient pipeline of pre-credentialed, HSPD-12-cleared coders to absorb unplanned personnel changes without interruption to call order performance.

6.2 Point of Contact

The Contractor shall designate a point of contact with full authority to act on all matters relating to daily BPA and call order operations. This individual shall be available by telephone and email during normal business hours, Monday through Friday, excluding federal holidays. The Contractor shall designate an alternate point of contact and the circumstances under which the alternate serves as primary. Both designations shall be provided to the CO in writing before the BPA establishment date.

6.3 Non-Personal Services

This contract is a non-personal services contract. Contractor personnel shall not be subject to the supervision and control of Government personnel in the day-to-day performance of coding work. The Government does not direct how the Contractor assigns encounters to individual coders, manages internal quality reviews, or organizes its workforce. Government technical direction is limited to identifying the encounters to be coded, the applicable coding period, and the performance standards against which output will be measured.

6.4 System Access and Remote Work Requirements

The Contractor shall access Government systems only through Government-authorized secure connections and shall comply with all IHS IT security policies and procedures made available at BPA establishment. The Contractor shall not store, copy, transmit, or retain any Government data — including patient records, encounter data, or coded information — on non-Government systems or personal devices. All work product produced under this contract is the property of the Government.

6.5 Ordering Procedures

Call orders may be placed by the Contracting Officer at any time during the BPA period. Each call order will specify the Service Unit, encounter type, coding period, estimated number of encounters, commencement date, and applicable performance period. The Contractor shall acknowledge receipt of each call order in writing within one (1) business day of issuance.

When the Government elects to obtain competition among BPA holders prior to placing a call order, each BPA holder will be provided a brief description of the requirement and an opportunity to submit a quote. The Contracting Officer will award the call order to the BPA holder offering the best value consistent with the call order requirements.

7.0 Government Furnished Information and Systems

7.1 Systems Access

The Government will provide authorized remote access to the following systems for performance of this contract:

· Resource and Patient Management System (RPMS)

· IHS Electronic Health Record (EHR)

· Patient Care Component (PCC)

· Secure Data Transfer System (SDTS)

· Any additional systems identified in individual call orders System access is contingent upon completion of HSPD-12 clearance and all required security and privacy training per Section 5.3 and 5.5.

7.2 Orientation and Training

The Government will provide facility-specific and system-specific orientation necessary for the Contractor to perform required services, including RPMS orientation for coders without prior RPMS experience. Training will be provided only when the subject matter is necessary to perform the coding services required under this contract. The Government is not obligated to provide training for continuing education, certification maintenance, or individual professional development.

7.3 Coding Guidelines and Policy Documents

The Government will provide access to applicable IHS HIM coding guidelines, ORAP Internal Control Policy, Revenue Operations Manual, and Service Unit-specific coding policies upon BPA establishment and as updated during the period of performance.

8.0 Security and Confidentiality

The Contractor shall protect all Personally Identifiable Information (PII) and Protected Health Information (PHI) accessed or generated under this contract in accordance with HIPAA, the Privacy Act, the Computer Security Act, and all applicable IHS IT security policies and directives.

The Contractor shall:

· Complete all required IHS IT security and privacy training before accessing any Government system;

· Access Government systems only through authorized secure connections;

· Report any actual or suspected data breach, unauthorized access, or privacy incident to the CO and COR immediately upon discovery, and in no case later than one hour after discovery;

· Not retain any Government data on non-Government devices or systems; and

· Upon completion or termination of each call order, ensure that all Government-issued access credentials are deactivated and all Government data is purged from Contractor systems within two (2) business days.

9.0 Performance Requirements Summary

The following Performance Requirements Summary (PRS) identifies each performance requirement, the performance standard, the Acceptable Quality Level (AQL), and the method of surveillance. The Government will use the PRS in conjunction with the Quality Assurance Surveillance Plan (QASP) to assess Contractor performance.

10.0 Glossary of Abbreviations and Acronyms