23-RHCO-P-493 REDACTED KO Determination Limit Competition.pdf

For All Actions At or Below the Simplified Acquisition Threshold FAR Subpart 13.1 Control No: 23-RHCO-P-493

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Memorandum for Record – Limiting Competition at or below the Simplified Acquisition Threshold

1. Contracting Activity: Regional Health Contracting Office-Pacific, Health Contracting Branch, Joint Base Lewis-McChord (JBLM), 673 Woodland Square Loop SE, Lacey WA 98503.

2. Description of Action:

Nature: New Requirement Purchase Request Number: 0011968532 Pricing/Contract Type: Fixed Price Funds: Defense Health Program

FY: 2023

Name of Proposed Contractor(s) and Address:

3M Health Information Systems Inc.

575 West Murray Boulevard, Murray, UT 84123

UEI: LUYEUMH42L88

Cage Code: 3L5X5

3. Description of Supplies:

This requirement is for the procurement of the software license and installation of the 3M 360 Encompass System- Clinical Documentation Improvement (CDI) System Software Module. This software is an optional extension module for the medical health programs currently in use. The 3M 360 software module uses built in algorithms to coach coders and clinicians on selecting the appropriate billing and work capture codes for their encounters to ensure that Madigan gets all credit for care retendered and ensures the accuracy of 3rd party billing. This module helps reduce significant number of errors and results in an increased correct billing rate for medical coders.

Estimated Total Contract Value and Period of Performance:

Base Period: 23 Sept. 2023 through 22 Sep 2024 Option Period 1: 23 Sept. 2024 through 22 Sep 2025 Option Period 2: 23 Sept. 2025 through 22 Sep 2026

Value:

Total: $ 2 ,702.00

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4. Authority:

FAR 13.106-1(b)(1): For purchases not exceeding the simplified acquisition threshold (SAT), only one source reasonably available, urgency, exclusive licensing agreements, brand name, or industrial mobilization. As required by FAR 13.106-3(b)(3)(i), this memorandum explains the absence of competition for this acquisition, as only one source will be solicited for this requirement and the requirement is not expected to exceed the simplified acquisition threshold.

5. Reasons for Authority Cited:

a. Madigan Army Medical Center at Joint Base Lewis McChord (JBLM) Washington, currently utilizes current 3M 360 coding system and the MHS GENESIS patient software systems. Madigan Army Medical Center requires additional system support for the medical coding of services provided to increase accuracy in billing of services. In order to achieve this increase in accuracy any software procured must work with the current 3M 360 coding system and MHS GENISIS patient software system.

Only the 3M 360 Encompass System- Clinical Documentation Improvement (CDI) System Software module will perform the correct required functions while interfacing with existing software. Lastly, 3M is the only vendor who has Authority to Operate and interact with the Cerner data in MHS GENSIS under the main overarching contract. As such there are no other products that will be allowed to interface with MHS GENESIS over the enterprise data service in place to support both departments.

b. If this software is not purchased Madigan Army Medical Center at JBLM will continue to fall further behind on accounting for care. As the Defense Health Agency basis all reimbursements on this information it could greatly hurt Madigan’s ability to provide tertiary care for the Puget Sound beneficiaries.

6. Publicizing Contract Actions: There is no exception to the requirement to synopsize. A notification will be posted to the government point of entry (www.SAM.gov).

7. Market Research:

This is a new requirement for MAMC, as such there is no local procurement history available. Market research was conducted from January through July 2023. This requirement was found to be commercial in nature based upon previous DoD procurement using commercial product acquisition procedures under FAR part 12 (DFARS 212.102(a)(ii)(A)). In researching this capability discussions were held with other Military Treatment Facilities (MTF’s) and

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Veterans Administration medical treatment facilities. It was found that other Defense Health Agencies (DHA), MTF’s and Veteran Administration (VA) facilities were actively using the 3M 360 CDI software module, and that module was procured under larger support software contracts for the entirety of the 3M software suite. In review of these historical actions, the Contract Specialist contacted the vendor and found that the DHA supporting order HT001521F0255, was originally awarded as a Coding Compliance Editor and that as part of a modification 3M agreed to convert it to the 360 Encompass system and retained the original pricing due to the shift to MHS GENISIS. Data for these existing contracts was requested however, no meaningful data was readily available to

MAMC.

8. Other Facts: N/A

9. Technical/Requirements Certification: I certify that the supporting data under my cognizance which are included in the justification are accurate and complete to the best of my knowledge and belief.

10. Contracting Officer Certification/Approval:

I hereby determine that the anticipated cost or price to the Government for this contract action will be fair and reasonable based upon price analysis techniques identified at FAR 13.106-3(a)(2).

I certify that this justification is accurate and complete to the best of my knowledge and belief, and that completing this purchase as a sole source is in the best interest of the Government. Additionally, I approve this justification to limit competition subject to the availability of funds and provided that the services or supplies herein described have otherwise been authorized for acquisition.

Scott Barr, Contracting Officer

Date: 2023.08.03 13:16:09 -07'00'

BARR.SCOTT.

A.

Digitally signed by

BARR.SCOTT.

Date: 2023.08.04 08:45:38 -07'00'