W81K04-17-R-0001_Q&A_03Apr2017.pdf

Document Pg # Para # Question Government Reponse

Draft W81K04- 17-R-0001 65 3.2.1.

Is it possible for a CLIN: quantity of training hours to be considered and included in the contract? How will 3.2.

Government Unique Training be addressed in the contract and billed.

No. Per PWS 3.2.2, "When directed by the KO, CSPs shall complete all such training in a paid status as part of the normal services required and billed under the contract." The offerors should include costs of 5-day training (paid status) per FTE in its price per record.

The travel costs are reimbursable and will be billed after training is completed.

Draft W81K04- 17-R-0001 66 3.2.1.

Is it possible for a CLIN: quantity of training hours to be considered and included in the contract for staff after 3.2.

Government Unique Training SHARP/ systems training? EX:

new system gynesis, PASBA VTC updates, CARA findings that need to be addressed within staff and coding updates etc...

No. If additional unique government training is incorporated into contract, a modification will ensue and will allow the contractor to revise price per record for "paid status" of contractors attending the additional government unique training.

Draft W81K04- 17-R-0001 66 3.2.1. Can the contracting staff attend PASBA VTC? If so will they also be provided with CEU?

Yes, if this question is referring to the monthly education sessions. The Government will not provide contractor staff with CEU.

Draft W81K04- 17-R-0001 70 5.2.8

Will the contractor be provided access to the PASBA website?

Contractor would request access only for contract Trainers, Coding Supervisors, Auditors, Coaches; not requesting for coders.

Contractors may request access to the PASBA website via the assigned COR to complete their duties pursuant the PWS.

17-R-0001 70 5.2.8

Will any guidance provided from the PASBA office be suffice for all facilities? Ex: coding question sent to PASBA, PASBA representative responds but doesn't send out MEMO to all facilities. One facility has the guidance and the others do not.

The other facilities may chose not follow that guidance.

No, not all questions/answers pertain to all MTFs. The contractor(s) will receive coding updates at the same time it is provided to the enterprise. Guidance will be issued if it's pertinent to the enterprise.

Draft W81K04- 17-R-0001 70 5.2.8

PASBA auditors have their own trends of coding and do not audit encounters the same, nor per the guidance of their own office. For EX: I had 4 physical encounters from 2 different basis same documentation and all four were audited differently. How will these issues be addressed? Will such instances be deducted from the contractor?

All records will be audited IAW MHS Coding Guidelines and treated equally across the enterprise.

Draft W81K04- 17-R-0001 70 5.2.8

Can the contractor mediate their own CARA audit findings?

Currently the facilities DQ or Coding supervisors dispute CARA audits due to the claim of only a 1 day turn around. It's found that the DQ or Coding supervisors do not dispute all findings but the contractor still has to take the hit for errors that they do not agree with that could and should have been disputed.

There is no provision that a contractor cannot dispute their own audit results. This will be the decision of the region and MTF COR.

Draft W81K04- 17-R-0001 70 5.2.8

Could a 3-7 business day turnaround for the CARA disputes be considered instead of 1 day turn around for CARA disputes? The amount of CARA pull varies per the facility with the stipulation that if CARA doesn't receive a response from the contractor after 7 days the CARA audit findings will stand. (I think because the facility claim to have a short turn around this is why all encounters are not mediated as they could/ should be).

Unfortunately, this process cannot change. The audits are completed within certain timeframes in order to provide data to other systems and programs.

17-R-0001 65-66 3.1 and 4

Does the contractor have to provide computers or is the CD suffice? We have a bootable media CD that kicks the coder out of their current operating system and allows the coders to access AVHE systems. This CD prevents a breach of security because the coder is not allowed to print or save data.

Do not understand the context of this question.

Draft W81K04- 17-R-0001 65 3.1.2

Per DHA personal computers are computers that are not issued by the government. Currently, the MH helpdesk will not assist with installing CAC credentials and Citrix for AVHE. Is DHA aware that they will be assisting contractors that are not using government issued computers?

There is no requirement for DHA to assist contractors.

See PWS 1.5.1, last sentence, "The DHA Service Center will manage account provisioning processes for AVHE and the Citrix-based platform to access MHS Genesis."

DHA will assist contractors with "account provisioning processes and the Citrix-based platform to access MHS Genesis."

Draft W81K04- 17-R-0001 68 5.1.2

How will the contract include and cover billing for the trainers, auditors, coaches necessary for a successful performance on the contract? 5.1.2 The contractor shall maintain internal coding compliance teams (e.g., Project Manager/Project Leader, Coding Compliance Managers, Coding Auditors, Coding Team Leads/ Workload Coordinators/Coding Project Leaders, and IT, etc.).

Contractors overhead (direct and indirect) costs of doing business to meet the PWS shall be included in price per record.

17-R-0001 not mentioned in draft

Is it possible to insert in the contract that coders with current clearance are in processed with in two weeks? Some facilities have taken up to 6 months to provide system access for coders that are cleared; have current CAC ID cards and only require CHCS and CCE access when other facilities in process these coders with in two weeks.

Reference PWS 1.6 for Trusted Associated Sponsorship System (TASS)) for instructions regarding CAC issuance and PWS 1.5.3.2, "The MTF-specific COR shall coordinate the review/approval of the SAAR for contractor access for all requested hosted applications."

And, PWS 1.7.2.1 "...At the discretion of the sponsoring activity, an initial CAC may be issued based on a favorable review of the FBI fingerprint check and a successfully scheduled Tier 1 at the Office of Personnel Management."

Draft W81K04- 17-R-0001 67 4.3.4.1

Can the AAPC CIC (certified inpatient coder) be considered as an acceptable cert? 4.3.4.1 The required credentials for medical coding professionals performing the coding services of this contract will be either by the American Health Information Management Association (AHIMA) as a Registered Health Information Administrator (RHIA); or Registered Health Information Technician (RHIT); or Certified Coding Specialist (CCS); or Certified Coding Specialist-Physician Based (CCS-P); or certified by the American Academy of Professional Coders (AAPC) as a Certified Professional Coder (CPC) or Certified Outpatient Coder (COC). Annual coding credentials shall be maintained.

No. The PWS credentialing requirements will be followed.

17-R-0001 48 1.5.2.1 All CSPs are required to have a SAAR- DD Form 2875. Are all CSPs required to acquire a Level 3 IT SAAR?

Yes. Per PWS 1.5.2.1.1, "Per the National Industrial Security Program Operating Manual (NISPOM) and AR 25-2, in order to gain access to and fully utilize the Army Medical Department (AMEDD) electronic network and to gain access to patient data as protected by the Health Insurance Portability and Accountability Act (HIPAA), all contract personnel must have an IT-III (formerly ADP-III) Clearance."

Draft W81K04- 17-R-0001 48 1.5.2.1.1 Will CSPs be required to have an IT-Level III Security

Clearance? Yes. Per PWS 1.5.2.1.1

Draft W81K04- 17-R-0001 51 1.7.21.1

The CSP is required to have a Tier 1 (T1) Adjudicated BI to access the DoD computer network. Page 48 Para# 1.5.2.1 &

1.5.2.1.1 state CSPs need IT-III to access systems too, please explain the Government's rationale for having both Level 3 and T1?

Tier 1 is the investigation for positions designated as low-risk, non-sensitive. It is also the minimum level of investigation for a final credentialing determination for physical and logical access. IT-3 refers to general users of systems. There are not multiple investigations, these are only designations.

Draft W81K04- 17-R-0001 51 1.7.3 Can CSPs obtain Level 1 OPSEC training online?

No. However, the MEDCOM Security Office is attempting to put together an OPSEC training program online that will meet the requirement of this annual training. This is tentative and not policy.

Draft W81K04- 17-R-0001 72 6.1.9 Does the Government anticipate backlog of case workload for any three regional health commands?

Fluctuations occur for many reasons with records that are coded or not coded. The Government does not currently anticipate a backlog in outpatient records.

17-R-0001 83 (3) c.

Are both the Prime Contractor and/or Sub/Teaming Partner required to provide 3 separate recency and relevancy incumbent references or a total of three to satisfy PWS Past and Present Experience?

If the subcontractor is performing greater than 25% of work then prime and subcontractor shall each provide three separate recency and relevant past performance information.

Draft W81K04-

17-R-0001 NA NA

It was referenced in the MEDCOM Coding industry day that this contract could be funded up to $100M. How will the small business contractor, with the associated NAICS of $20.5M, be evaluated on Fiscal solvency/ability to fund a contract of this magnitude? The final solicitation will include a determination of responsibility regarding financial resources.

Draft W81K04-

17-R-0001 NA NA

What events occurred since the Industry Day that shifted a contract of this magnitude to WOSB (from Full & Open) and LPTA (from Best Value)?

No events have occurred; Industry Day did not provide an assurance of a unrestricted, full and open competition. Industry Day was a component of the indepth market research conducted for this requirement.

The subsequent approved acquisition strategy for a WOSB setaside is in compliance with Federal Acquisition Regulations. The LPTA source selection method is a "Best Value" under FAR 15.101-2.

17-R-0001 NA NA

Medical coding accuracy can be very subjective. Interpretation of the documentation has a cascading effect on the following areas: Patient Safety/Clinical Accuracy, Budget/Forecasts, Billing Fraud, Medical Malpractice, and Data Quality Scores.

A historical example of these risk factors occurred with Brooke Army Medical Center (BAMC), which was cited for Medical Upcoding/Billing Fraud. (Reference: Roser, M.A.

(2001, May 27). Army hospital accused of improper billing practice. Longview News-Journal, p. 8a.)

Given these potential impacts and risks to the Army MEDCOM and MTFs, would the Government be open to recognizing these high visibility/high risk factors and changing the strategy to the more applicable Best Value evaluation?

No.

Draft W81K04-

17-R-0001 NA

Pre- Solicitation

Notice

(FBO)

1) Can one contractor be awarded all three regions?

2) If so, has the government prepared to assume the risk of having all three regions assigned to one contractor?

Yes; the Government acknowledges related risks on all contracts.

17-R-0001 31-35 252.204-

Should the contractor expect that interim access will be granted to the coders? How many days of non-access should the contractor assume, once the necessary security paperwork has been processed?

Reference PWS 1.6 for Trusted Associated Sponsorship System (TASS)) for instructions regarding CAC issuance and PWS 1.5.3.2, "The MTF-specific COR shall coordinate the review/approval of the SAAR for contractor access for all requested hosted applications."

And, PWS 1.7.2.1 "...At the discretion of the sponsoring activity, an initial CAC may be issued based on a favorable review of the FBI fingerprint check and a successfully scheduled Tier 1 at the Office of Personnel Management."

Draft W81K04- 17-R-0001

32-33 and 91-

252.204-

Is the government requiring the prime and all subs to obtain the NIST Moderate certification or only the prime contractor?

Per 252.204-7012(c)(3),"…the Contractor or subcontractor shall have or acquire a DoD-approved medium assurance certificate to report cyber incidents."

Draft W81K04- 17-R-0001 46-47

1.1.

Backgroun d

1) How does the Government intend to handle the additional contractor costs for implementation and training of Genesis?

2) Do contractors need to provide estimates for these costs for this bid, or does the Government intend to allow contractors to submit modifications upon implementation.

The training requirements for MHS Genesis is not clear at this time reference coding procedures. The Government will consider modifications if it is necessary in the future.

Draft W81K04- 17-R-0001 49

1.5.2.3, 1/.5.3.2, 1.7.2.1

How long does the Government anticipate for the length of time to receive a CAC card and gain network access to a given application (list application)? This process varies depending on the individual and the clearance

17-R-0001 49 1.5.2.3

1) How does the government intend to issue the required

CAC?

2) Do the coders need to travel to a near by Army installation or is any DOD Facility an option?

Once all documentation is complete, the individual will make an appointment through the online Real-Time Automated Personnel Identification System (RAPIDS) website. Locations are available throughout the U.S.

and an Army facility is not required.

Draft W81K04- 17-R-0001 51 1.7.2.1

The RFP states that:

"Before CAC issuance, the contractor employee requires, at a minimum, a favorably adjudicated Tier 1 investigation in accordance with Army Directive 2014-05. [...] At the discretion of the sponsoring activity, an initial CAC may be issued based on a favorable review of the FBI fingerprint check and a successfully scheduled Tier 1 at the Office of Personnel Management."

Should we build our pricing model assuming that interim access will be granted for qualified coders?

The contractor's cost of doing business would include risks associated with unknown events. Contractor's direct and indirect costs (to include risks associated with not meeting standards) shall be included in price per record; it is a contractors business decision on how to price risk.

Draft W81K04- 17-R-0001 52 1.9.1

The listed standards in the RFP state that the "contractor shall maintain an Industry quality standard-compliant process for quality control such as ISO 9000 or equivalent." ISO 9000 or equivalent standards are complex and expensive.

Did the Government validate in their market research that sufficient small businesses had or were capable of affording the ISO 9000 or equivalent standard?

The approved acquisition strategy is based upon market research conducted.

Draft W81K04- 17-R-0001 52 1.9.1 Will the Government clarify what it considers an equivalent standard for quality control processes? Per PWS 1.9.1, "The contractor shall maintain an Industry quality standard-compliant process for quality control such as ISO 9000 or equivalent."

17-R-0001 52 1.9.1

Since contractors will be using Government systems, will the Government verify that this ISO 9000 or equivalent standard is required?

Reference PWS 1.9, Quality Control for requirements related to quality control. The Contractors will not be using Government systems; they will be given permissions to enter Government platforms (AVHE) to access hosted applications.

Draft W81K04- 17-R-0001 54 1.16 Travel How many trips should contractors plan and include in their price?

The offerors should include costs of 5-day training (paid status) for each coder it includes in its price per record.

For example, if a contractor determines that it would take 30 coders to complete the annual workload of Central Region, each of the 30 coders will need to attend a training session at the applicable MTF; the government has determined that 5-days is the average number of days to attend training. As such, the coders attending training would be paid by the contractor as the cost is included in the price per record. The travel costs are reimbursable and will be billed/reimbursed after training is completed. Contractors overhead (direct and indirect) costs of doing business to meet the PWS shall be included in price per record.

Draft W81K04- 17-R-0001 54 1.16 Travel Does the Government intend to include travel CLINs with the final RFP? Yes

Draft W81K04- 17-R-0001 64 2.1.15 -

1) What is the ramp-up time for each region?

2) Are contractors expected to ramp-up and implement all MTFs within a region upon award, or will the MTFs will be phased-in?

Reference PWS 1.15 Phase In/Phase Out Period. Task Orders will be issued on a MTF-basis; the number and roll-out of task orders will be determined by regions after contract award.

17-R-0001 64 2.1.15 -

The timeline for ramp-up and implementation directly impacts pricing. If the Government plans on a ramp-up approach, will the Government please provide a timeline?

Reference PWS 1.15 Phase In/Phase Out Period.

Draft W81K04- 17-R-0001 65-66 3.2, 3.2.1

The RFP requires the following:

"The government may elect to provide unique government training to contract CSPs who are performing services under this contract. If the government elects to provide such training, the government will provide such training at no additional expense to the contractor or to the CSP. When directed by the KO, CSPs shall complete all such training in a paid status as part of the normal services required and billed under the contract. The contractor shall be responsible for contractor travel to MTF locations for unique training (e.g., Essentris, AHLTA, CHCS, CCE, and MHS Genesis) on a firm fixed price basis."

How will the Government pay for training if the training as listed on the CLIN is per unit, not per hour?

The offerors should include costs of 5-day training (paid status) for each coder it includes in its price per record.

For example, if a contractor determines that it would take 30 coders to complete the annual workload of Central Region, each of the 30 coders will need to attend a training session at the applicable MTF; the government has determined that 5-days is the average number of days to attend training. As such, the coders attending training would be paid by the contractor as the cost is included in the price per record. The travel costs are reimbursable and will be billed/reimbursed after training is completed. Contractors overhead (direct and indirect) costs of doing business to meet the PWS shall be included in price per record.

17-R-0001 65-66 3.2, 3.2.1 Will the Government clarify the statement so contractors understand how contractors should include this training cost?

The offerors should include costs of 5-day training (paid status) for each coder it includes in its price per record.

For example, if a contractor determines that it would take 30 coders to complete the annual workload of Central Region, each of the 30 coders will need to attend a training session at the applicable MTF; the government has determined that 5-days is the average number of days to attend training. As such, the coders attending training would be paid by the contractor as the cost is included in the price per record. The travel costs are reimbursable and will be billed/reimbursed after training is completed. Contractors overhead (direct and indirect) costs of doing business to meet the PWS shall be included in price per record.

Draft W81K04- 17-R-0001 65-66 3.2, 3.2.1 How should contractors include pricing for the associated training travel costs? Final solicitation will include a Travel CLIN. The travel costs are reimbursable and will be billed/reimbursed after training is completed.

17-R-0001 65-66 3.2, 3.2.1

How many days will training last, and how will contractors know to which MTFs contractors' employees will have to travel?

The offerors should include costs of 5-day training (paid status) for each coder it includes in its price per record.

For example, if a contractor determines that it would take 30 coders to complete the annual workload of Central Region, each of the 30 coders will need to attend a training session at the applicable MTF; the government has determined that 5-days is the average number of days to attend training. As such, the coders attending training would be paid by the contractor as the cost is included in the price per record. The travel costs are reimbursable and will be billed/reimbursed after training is completed. Contractors overhead (direct and indirect) costs of doing business to meet the PWS shall be included in price per record.

Draft W81K04- 17-R-0001 66

4.3, 4.3.1, Personnel

Qualificatio ns

Will the Government please clarify if the minimum of five years of coding experience applies to each employee or the company?

PWS 4.3.1, "The contractor shall provide an extensive working knowledge...An extensive working knowledge is defined as a minimum of five years of coding experience." PWS 4.3.2 outlines the qualifications for the Contract Service Personnel (CSPs).

Draft W81K04- 17-R-0001 66 4.3.3.1., 4.3.3.1.1

The requirements for this section are restrictive, making it difficult for small businesses to recruit candidates with the required skills, certifications, and experience. Did the Government's research validate that sufficient small businesses were able to meet this requirement?

The approved acquisition strategy for a WOSB setaside is in compliance with Federal Acquisition Regulations.

17-R-0001 67 4.3.4

How will the Government validate the credentials and experience of the contractor's staff to meet the presented requirements?

The requirement is for the contractor to provide qualified personnel IAW the PWS; it is the contractor's responsibility to provide qualified personnel IAW PWS requirements and, if requested by COR or KO, provide the Government with the proof of qualifications.

Draft W81K04- 17-R-0001 68 5.1

In this requirement, the Government references that the work will be performed using MHS Genesis. Is the Government's intent for the contractor to begin work at a site only after Genesis has been implemented at that site?

This requirement will commence at MTFs regardless of which electronic health record is in use.

Draft W81K04- 17-R-0001 68 5.1.3

The RFP requirement lists multiple functions: "The contractor shall maintain program management approaches that include corporate infrastructure resources to support functions, including performance management, account management, contract administration, finance and accounting, quality assurance, security management, Information Technology (IT), and human resources."

Are these functions required to be performed by the prime?

This a performance- based requirement; it is the contractor's discretion on how to meet the requirement as described in its technical approach.

Draft W81K04- 17-R-0001 69 5.2.4.3, 5.2.9.1.3

Typically, in a FFP contract, the Government cannot mandate production standards as long as the contractor meets the quality standards. The additional reporting requirements also increase contracting costs. Will the Government clarify the standards?

Productivity levels in the PWS will be re-assessed.

However, the contractor will be held to 5.2.7.

17-R-0001 69 5.2.7

Previously, OP records were required to be processed and coded within seven (7) business days. Will the Government please clarify that OP records are to be processed and coded within two (2) business days from date of assignment and all other records are to be processed and coded within seven (7) business days from date of assignment?

This contract requires Outpatient Clinic (OP) Records within two (2) business days from the date of assignment and Emergency Department (ED), Ambulatory Procedure Visits (APVs), and Inpatient Professional Service Rounds (IPSR) within seven (7) business days from date of assignment per 5.2.7. This requirement does not reference previous contracts.

Draft W81K04- 17-R-0001 70 5.2.8

The recent Medical Records Coding RFQ, RFQ 1171597, for Landstuhl Regional Medical Center (LRMC) lists the following standards:

"5.3.1 Standards shall be: To code 100% of records assigned within 7 business days with a 95% coding accuracy rate in each of the following areas:

ICD-10-CM

E&M (modifier utilization will impact accuracy rate) CPT (modifier and unit of service utilization will impact accuracy rate)."

Does the 97% accuracy standard apply to all MTFs, or are there variations at different MTFs?

Per 5.2.8., The contractor shall code 100% of records assigned at a 97% coding accuracy rate. This contract does not reference other contracts. The DHA and Army coding accuracy rate is 97% and apply to all MTFs.

The RFP lists the following requirement: "The contractor shall code 100% of records assigned at a 97% coding accuracy rate in each of the following areas:

ICD-10-CM

E&M (modifier utilization will impact accuracy rate) CPT (modifier and unit of service utilization will impact accuracy rate)."

Will the Government clarify that 97% applies to each listed area (ICD-10-CM, E&M, and CPT) or is 97% an overall average for all areas?

Each listed category.

Draft W81K04- 17-R-0001 70 5.2.8

Defining a clear methodology will assure contractors understand how the Government will audit, score accuracy, and apply penalties.

1) It's critical that the Government audits a statistically valid sample size to get an accurate quality score. For example, the volume for Ft. Wainwright would require a larger audit sample to produce the same statistically valid sample size as Madigan.

Please provide the sample size methodology the Government will use for CARA audits by MTF, by chart type, and by specialty.

2) Is the contractor's 97% accuracy score determined by MTF or by the overall average of all MTFs?

Contractor participation to the CARA mediation process will be decided by the local COR. By MTF.

Medical coding, especially E&M leveling, can be subjective.

1) What is the rebuttal process for the contractor to the CARA auditor(s)?

2) What is the timeframe for the contractor to review and rebut audit results?

3) Will the contractor receive access to the CARA audit tool to review?

4) Since the Government is tying a penalty to the results of the CARA audits, there needs to be a clear and consistent escalation and resolution process for when the CARA auditor(s) and contractor do not agree. Will the Government please define the escalation and resolution process?

Contractor participation to the CARA mediation process will be decided by the local COR.

Draft W81K04- 17-R-0001 70 5.2.9.1.2

The RFP requirement is that the "accuracy rate of each coder by type (gathered through contractor self-auditing)."

Please clarify what is "by type"? Is this record type or by areas (ICD-10, E&M, and CPT)?

By ICD-10, E&M, and CPT.

Draft W81K04- 17-R-0001 94

Commercia l

Evaluation Factors

According to acquisition guidelines/specialist, LPTA in not normally associated with contract penalties. How should the contractor take penalties into account for pricing purposes?

The contractor's cost of doing business for quality control would include risks associated with not meeting quality standards. Contractor's direct and indirect costs (to include risks associated with not meeting standards) shall be included in price per record.

Draft W81K04- 17-R-0001 94, 99

Commercia l

Evaluation Factors

Does this acquisition strategy follow the LPTA usage guidelines identified In the 2017 NDAA?

2017 NDAA has not been incorporated into Federal Acquisition Regulations at this time.

17-R-0001 96

C.

Evaluation Approach, 1.a and 1.b

The Government requires that:

"a) Recent and Relevant: Past and/or current performance within the last 24 of the previous 36 months (from the date established for submission of proposals) performing remote medical coding services of same scope and complexity to this solicitation. Periods of creditable performance may have been incurred at more than one site for at least 12 consecutive months at each site and cannot be gained at more than two more sites concurrently.

b) Not Recent and Relevant: Past and/or current performance not within the last 24 of the previous 36 months (from the date established for submission of proposals) performing remote medical coding services of same scope and complexity to this solicitation."

The evaluation requirement is highly restrictive. Typically, a past performance evaluation considers recent and relevant to be within the last five years. Will the Government consider revising the evaluation to include the last five years?

No.

Draft W81K04- 17-R-0001 70 5.2.8 and

5.2.9.1

IAW the PWS, coders are required to maintain a 97% accuracy level for each code type and record type. Since there are 4 record types and 3 code types this equates to potentially 12 quality scores for each coder every month. Will the CARA audit assess coder performance across all record types and code types every month similar to the MSR enhanced data requirements?

By ICD-10, E&M, and CPT.

Does the government want coding accuracy rates based on self-audits to be a composite of all codes audited within a record or reported by individual code types?

All codes within the record.

Draft W81K04- 17-R-0001 70 5.2.8

What is the government CARA audit statistical sampling methodology including sample size(s) and statistical margin of error? Will penalties be assessed if a vendor is within the statistical sampling margin of error but below 97%?

The Government is revising the PWS, removing the penalties related to the CARA audit findings.

Draft W81K04- 17-R-0001 70 5.2.8 How will differences between contractor and CARA audit findings be remediated? What is the rebuttal process? The Government is revising the PWS, removing the penalties related to the CARA audit findings.

Draft W81K04- 17-R-0001 70 5.2.8

How will MTF level CARA audit findings be assembled to provide a performance measure capable of affecting the overall MTF invoice? The Government is revising the PWS, removing the penalties related to the CARA audit findings.

Draft W81K04- 17-R-0001 94 A

Medical coding by its nature is subjective and based on skilled/experienced coders interpreting clinical documentation.

Incorrect/improper coding can have serious MTF implications, including clinical (e.g. patient safety), financial (e.g. billing fraud and budget justification), and public perception (e.g.

hospital quality scores) to name a few. These are not low risk issues. This seems like work best suited for Best Value and not LPTA. Would the government reconsider their acquisition strategy and change to Best Value?

The WOSB setaside is in compliance with Federal Acquisition Regulations.

17-R-0001 94 A Why does the government believe, as expressed in other answers, that the “performance risk is low” in this contract?

Government's determination through market research of commercial, remote medical coding services being performed at multiple MEDCOM MTFs.

Draft W81K04- 17-R-0001 48 1.5.1.1

The government is stating that AVHE uptime is 99.6%. If the uptime is actually less, how will the government reimburse vendors for coder productivity lost due to system non-availability?

AVHE scheduled and unscheduled outages are reported through the DHAGSC outage notification process and will be used to monitor outages. Outage rates are less than 1%.

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