VA118-16-D-1001-001.docx

Control Number TAC-19-54752

JUSTIFICATION

FOR AN EXCEPTION TO FAIR OPPORTUNITY

2. Description of Action: The proposed sole source Task Order (TO), issued under the Transformation Twenty-One Total Technology Next Generation Contract VA118-16-D-1001, is to provide additional and ongoing development and sustainment services for the Community Care Referrals and Authorizations (CCRA) project with Cognosante MVH, LLC. (Cognosante) for the HealthShare Referral Manager (HSRM), Software as a Service (SaaS) solution.

3. Description of the Supplies or Services: The proposed action is to provide additional development and sustainment services for the HSRM, SaaS product hosted at Amazon Web Services FedRAMP High Government Cloud with middleware HealthConnect systems hosted at VA Regional Datacenters.

The HSRM solution is used by the Veterans Health Administration, Office of Community Care (OCC) to support the non-VA provider referral, authorization and payment processes associated with the Choice Act and Maintaining Internal Systems and Strengthening Integrated Outside Networks (MISSION) Act. The HSRM solution has upgraded VA’s legacy referral processes by integrating industry best practices, automating previously manual processes and providing a non-VA Provider portal for sharing Veterans’ referral and medical documentation. HSRM is used by facility OCC staff to generate referrals and authorizations for Veterans receiving care in the community. This system is designed to be used by Clinical and VA community care staff located at VA medical centers, outpatient clinics, community-based outpatient clinics, and Veterans Integrated Service Network offices. The HSRM solution is an integral component of the community care information technology architecture that allows Veterans to receive care from community providers. In addition to providing referral information to VA payment systems to ensure timely and accurate medical claims reimbursements, HSRM also shares referral information with third party healthcare network administrators for effective referral management and Veterans’ claims adjudication.

The HSRM solution is a SaaS solution that is intended to be used enterprise-wide. As a SaaS solution, HSRM is provided to VA as a service. All modifications to the HSRM solution are provided as part of a monthly subscription and changes to HSRM are maintained and owned by the HSRM vendor. The HSRM solution is also integrated with VA specific data sources to ensure optimal performance. These data sources include Veterans Health Information Systems and Technology Architecture (VistA), Electronic Claims Adjudication System (eCAMS), Community Care Reimbursement System (CCRS), Provider Profile Management System (PPMS), as well as other VA systems providing critical Veteran and medical information. The development and software source code for the integration with VA specific data points is not provided as part of the SaaS solution.

This proposed TO support includes a monthly subscription for the SaaS solution to include software maintenance, sustainment configuration, and development. The proposed TO support also includes cloud and network infrastructure, software development, system testing, integration testing, software installation, implementation (product/service), training, customer support, optimization (technical/operational), and adaptive, perfective, and corrective maintenance for VA specific integration.

In addition, the proposed TO includes services for operational expertise and support to VA users and non-VA users external to the VA network to ensure a successful implementation and continued sustainment of the HSRM SaaS solution. This includes creating, operating and maintaining a customer support call center to provide end user support for all HSRM users external to the VA network. This expertise and support includes communications with the workforce and external stakeholders, as well as organizational change management, training, and documentation.

VA awarded the competitive TO in June 2017 for $ for CCRA. The Cognosante SaaS solution was modified and customized to meet the specific configuration needed for a referrals and authorizations system so that it will integrate with VA’s existing provider payment systems/applications. The modifications, customization, integration, release and training were completed over a course of 24 months and the requirement for additional enhancements and support is expected to continue for at least an additional 12 months. Cognosante’s initial modifications to the SaaS solution were completed and nationally deployed in September 2018. The HSRM solution initial integration with VA’s eCAMS began in April 2019 and HSRM will be released to all VA facilities by July 2019.

The proposed TO is for a base period of 12 months, with two 12-month option periods, if exercised. The total estimated value of the proposed action is $ inclusive of option periods.

4. Statutory Authority: The statutory authority permitting an exception to fair opportunity is Section 41 U.S.C. 4106(c)(2) as implemented by the Federal Acquisition Regulation (FAR) 16.505(b)(2)(i)(B), entitled “Only one awardee is capable of providing the supplies or services required at the level of quality required because the supplies or services ordered are unique or highly specialized.”

5. Rationale Supporting Use of Authority Cited Above: The proposed source for this action is Cognosante, 3190 Fairview Park Drive, Falls Church, VA 22042. The previous TO for this effort was competitively awarded to Cognosante. The justification for awarding to Cognosante is based on the unacceptable delays that would result if a new solution were selected, and the duplication of cost to VA if VA were to conduct a competition and award to another vendor. The initial TO for this effort implemented the Cognosante brand HSRM solution’s native workflow within VA and adapted the OCC business processes to that workflow. Continuation of this effort by Cognosante is critical to VA, since significant delays would result if a new solution were selected for implementation, with its own set of brand-specific business processes, (re)engineering, new development, testing, training, deployment, and data migration.

The development and testing process of a new system would take approximately 18 months for full customization, deployment and implementation at a level that Cognosante has already reached with the existing HSRM. This would delay Veterans’ ability to receive timely medical care, especially in rural areas where special services are not offered in-house by VA, and require extensive coordination and travel time to access facilities, as well as redundancies throughout the Veteran interface process when trying to manage their care. A new solution at this time would also negatively impact claims processing and the non-VA providers ability to receive prompt payments for Veterans’ medical care. These factors cause serious implications to the timely and necessary care Veterans need to receive, as well as impacts the availability of that care.

In addition, Cognosante HSRM is a commercial referral solution that has been customized for VA with regular maintenance releases as part of the monthly subscription fee to meet requirements that are unique to VA. It is currently deployed nationally and will be supporting all 142 VA facilities by July 2019. Since the existing HSRM solution has already been customized as part of the competitive award, custom interfaces that currently exist would require re-development and integration with a new solution.

To expand on the above, the HSRM solution is a critical piece of the OCC’s Community Care Network (CCN) contract. The CCN is a “system of systems” approach aimed at addressing enterprise-wide challenges that supports both the Choice Act and MISSION Act. It includes requirements for identification of providers for various medical and surgical inpatient and outpatient services, a network of high-performing healthcare providers, delivery of patient-centered care, monitoring and management of quality, useful data and performance metrics to improve services payment and processing of claims, and enhancements of Veterans’ healthcare experiences. The system of systems approach is part of VA’s transformation plan for healthcare to become an integrated and interoperable delivery system that involves vendors performing additional functions (i.e. risk management, case management and network adequacy monitoring) in collaboration with VA, beyond the development of a community provider network. The CCRA solution provided by Cognosante is the cornerstone of VA’s changes for Community Care. Without the Cognosante solution, all of the projects and programs aligned to work with CCN will need to be re-aligned and integrated with a new vendor’s brand-specific solution. The first region, consisting of six total CCN regions, was awarded in January 2019, has completed testing, and was deployed in June 2019, with healthcare delivery starting simultaneously. VA has worked with Cognosante on requirements, implementation, testing and training to ensure full interoperability with CCN. Cognosante is scheduled to start healthcare delivery in June 2019 to limited locations and will expand through January 2020. Two additional CCN regions were awarded in May 2019 and will begin healthcare delivery in November 2019, at limited locations, and with continued rollout through May 2020. It is anticipated the remaining CCN regions will be awarded in Fiscal Year 2020 with continued rollout through at least Fiscal Year 2021. During the rollout and implementation of the CCN through all six regions, VA requires seamless support for referrals and authorizations and only the existing solution, which is currently fielded, can meet this seamless support requirement. The CCN Healthcare Network and all associated information technology systems have been configured, designed, and tested to only work with the HSRM solution. Use of any other brand name solution would require a complete re-configuration, re-design, and re-testing of the Data Access Service, CCRS, Enrollment System, PPMS, Standardized Episodes of Care database, Community Care Non-Network Claims, and each CCN Healthcare Network. This would entail re-developing thousands of lines of code, phased transition, and extensive training of both VA and CCN resources, and, based on previous configuration, design and testing efforts, would cost an estimated $ dependent upon the new HSRM solution.

As a result, procuring a new solution at this time through competitive methods would result in substantial duplication of time and cost to the Government that is not expected to be recovered in competition and would also result in unacceptable delays in providing critical services to Veterans.

6. Efforts to Obtain Competition: Market research was conducted, details of which are in Section 8 below. This effort did not yield any additional sources that can meet the Government’s requirements. There is no competition anticipated for this acquisition. In accordance with FAR 5.301 and 16.505(b)(2)(ii)(D), the award notice for this action will be synopsized on the Federal Business Opportunities Page (FBO) and the justification will be made publicly available within 14 days of award.

7. Actions to Increase Competition: The Government will continue to conduct market research to ascertain if there are changes in the market place that would enable future actions to be competed.

8. Market Research: The Government’s technical experts conducted market research by posting a Request for Information on FBO on March 14, 2019. The market research asked for a SaaS CCRA solution hosted in a FedRAMP High Government Cloud with operational expertise and support to VA users and non-VA users external to the VA network to ensure a successful implementation and sustainment of a CCRA solution. VA requested that the CCRA solution must also have architectural and technical capabilities to connect with over 155 separate VistA systems. In addition, the CCRA solution would require bidirectional communication and architectural capabilities to connect with six upstream VA systems and five downstream VA systems. VA also identified 132 must-have requirements that any proposed solution must provide to ensure seamless support. A total of three responses from large businesses were received; including, Acumen Solutions Incorporated (Acumen), Document Storage Systems (DSS) Incorporated, and Cognosante. Acumen and DSS were deemed not capable of meeting VA’s needs. Acumen and DSS were notified that they were deemed not capable of meeting the requirement. No further response was received. Based on its already-completed efforts, Cognosante was deemed capable. Based on this market research, VA has determined that only Cognosante can meet all of VA’s requirements.

9. Other Facts: None.