Inactive

Limited Sources Justification >SAT Page 1 of 6 LIMITED SOURCES JUSTIFICATION ORDER >SAT FAR PART 8.405-6 Acquisition Plan Action ID: Not required for actions under 1 Million (Ref: https://vaww.pclo.in... Limited Sources Justification >SAT Page 1 of 6 LIMITED SOURCES JUSTIFICATION ORDER >SAT FAR PART 8.405-6 Acquisition Plan Action ID: Not required for actions under 1 Million (Ref: https://vaww.pclo.infoshare.va.gov/PCLO/PMWeb/VHAPM_Part_807.1.aspx ) Contracting Activity: Department of Veterans Affairs (VA), Veterans Health Administration (VHA), Procurement Contracting Activity Central (PCAC) St. Louis. Description of Action: This acquisition is conducted under the authority of the Multiple-Award Schedule Program (41 U.S.C. 152(3) and 40 U.S.C. 501). This proposed action is for a firm-fixed priced (FFP) bridge contract to a single source, CHANGE HEALTHCARE OPERATIONS, LLC to provide Health Care Clearing House (HCCH) services and support. The period of performance is 26 Sept 2020 through 16 Jan 2021. eBusiness Solutions Office is requesting for a bridge contract to be awarded to the incumbent Health Care Clearing House (HCCH) contractor. Although there is no definition in the FAR for bridge contract , it is axiomatic that a bridge contract is understood to mean a non-competitive contract/order or contract/order extension with an existing contractor to bridge the time between the original end of that contractor s contract/order (following exercise of all options or extension provisions meeting the requirements of FAR 17.207) and the competitive award of a follow-on contract/order. This is a short-term solution to ensure a continuation of Healthcare Clearing House Services and support for VHA s eBusiness Solutions Office until a competitive award is achieved. The bridge contract shall be awarded via the contractors current Federal Supply Schedule. The bridge contract will allow work to continue so there are no breaks in service while the Government works to award a new contract under full and open competition. The Contractor shall provide support for all of VHA s current electronic transactions across the United States and its territories. The Contractor shall assist the VHA in continuing its mission to implement electronic transactions and to support printing of standard claim forms in certain situations where electronic transmission is not feasible. The VHA currently utilizes the incumbent contractor to transmit the majority of its incoming and outgoing electronic transactions to and from the national Payer community. VHA routes these transactions through the Department of Veterans Affairs (VA) Financial Services Center (FSC) or other datacenters as specified by the VA prior to transfer to or from the Health Care Clearing House (HCCH). Order against: FSS Contract Number: GS-35F-0176X Name of Proposed Contractor: CHANGE HEALTHCARE OPERATIONS, LLC Street Address: 3055 LEBANON PIKE STE 1000 City, State, Zip: NASHVILLE, TN 37214-2239 Limited Sources Justification >SAT Phone: 240-676-7938 Description of Supplies or Services: The estimated value of the proposed action is: Period of performance: 26 Sept 2020 through 16 Jan 2021. The U.S. Department of Veterans Affairs, Veterans Health Administration, eBusiness Solutions Office requires Healthcare Clearing House Services and Support to be provided. The Contractor shall provide all management, supervision, labor, training, equipment, and supplies necessary to provide HCCH services and support as described herein. *Note: Please see the attached PWS for full details on the tasks and deliverables that are required to support this bridge effort. A high-level overview of the tasks is provided below. The Contractor shall: Transmit HIPAA compliant X12 and NCPDP transactions via batch and real-time transfer and translate proprietary formats to and from HIPAA compliant transactions on behalf of VHA. And support any future industry standards that may be released (i.e. such as HL7) Provide connectivity to health care Payers or their authorized agents. Support VHA current and future electronic transaction volumes by providing access to Payers with whom it currently conducts electronic healthcare revenue transactions. Ensure connection to a wide variety of Payers by date of award for any respondent to maintain the current level of business. Expand access to additional Payers, as new Payers are established or identified. Assist VHA in its effort to submit electronic secondary claims to Payers(s) according to the Payer model of Coordination of Benefits(COB). Provide services to print and mail compliant Institutional National Uniform Billing Claim Form (NUBC)/(UB04), National Uniform Claim Committee (NUCC) form CMS 1500 Professional Provider Forms and as well as a paper representation of the Medicare- equivalent Remittance Advice when applicable. Assist VHA in transitioning to future HIPAA regulations including implementation of legislative mandates and requirements. Assist VHA in identifying and implementing additional transactions and process improvements. Identify the Authority and Supporting Rationale (see below and if applicable, a demonstration of the proposed contractor s unique qualifications to provide the required supply or service. FAR 8.405-6(a)(1)(A): An urgent and compelling need exists and following the ordering procedures would result in unacceptable delays: Change Healthcare is the incumbent Healthcare Clearing House (HCCH) contractor who is currently processing all our healthcare transaction services. Change Healthcare is a commercial clearinghouse who is able to receive, process, and transmit health care transactions in HIPAA X12 and NCPDP formats, VHA approved formats, or any formats specifically acceptable for electronically enabled Payers and agreed upon by VHA and the contractor without delays. They are currently positioned to be able to continue to process VA s proprietary formatted transactions without experiencing a break in service or service delay during the full and open competition period of a new contract solicitation. Delay in award of a contract would result in serious injury, financial or otherwise to the government. Therefore, Change Healthcare is already uniquely positioned to meet the governments requirements through its developed communication and data transfer platform that s already in place. A new vendor would take approximately take 30 90 days to set up. A stop work and/or lapse in service without replacement would result in the current electronic transactions being reverted back to telephone and paper, which negatively affects time frames, potentially creating a backlog of actions before billing could occur. A stop work and/or lapse in service without replacement also negatively impact VA s Revenue Collections process mandated by Congress and United States Code. Without these collections, VA could be in danger of falling short in providing medical services to our Nation s Veteran population as this contract brings in revenue to support that mission. Describe Why You Believe the Order Represents the Best Value consistent with FAR 8.404(d) to aid the contracting officer in making this best value determination: These services are currently provided to the VA under contract VA777-17-D-0006 by Change Healthcare Operations, LLC. The previous solicitation was competed, and pricing received was determined fair and reasonable by comparison of offeror s prices received. The prices provided by the Contractor will be compared to historical pricing and compared with prices on the Federal Supply Schedule (FSS) that were previously negotiated by GSA and are considered fair and reasonable. Based on information stated in the Contractors GSA Schedule Contract, prices listed in the Contractors GSA Schedule under SIN number 132-51, for services herein described, are negotiated at the order level which would also provide an opportunity for the Government to obtain a better schedule contract pricing when applicable and available. Although the incumbent s pricing is known and has already been determined to be fair and reasonable, the possibility of a de minimis pricing increase exists. There would be a substantial duplication of cost and unacceptable delays if competition is sought for this short-term solution. The quote from the contractor will be reviewed through a technical evaluation to ensure that they meet the requirements of the contract. Describe the Market Research Conducted among schedule holders and the results or a statement of the reason market research was not conducted. Market Research was not conducted for this bridge sole source requirement. However, market research has been conducted regarding the long-term follow-on contract for this requirement and indicates that the VHA can expect to receive several responses to the solicitation of contractors capable of fulfilling this requirement on a long-term contract. Page 3 of 6 Limited Sources Justification >SAT Page 4 of 6 This award is being made under FAR 8.405-6(a)(1)(A) where an urgent and compelling need exists and following the ordering procedures would result in unacceptable delays until the agency can enter into another contract for required services through the use of competitive procedures. It is also recognized that by continuing with a bridge contract it is in the best interest of the Government to re-coupe essential revenue needed for VA programs while a new contract is being established. For the purpose and use of the bridge contract it is also recognized that by continuing with a bridge contract it is the best alternative while the new contract is being established so that the Government does not experience a lapse in revenue collections for VHA. Any Other Facts Supporting the Justification: The current contract expires September 25, 2020 and all extensions have been exhausted. A stop work and/or lapse in service without replacement would result in the current electronic transactions being reverted back to telephone and paper, which negatively affects time frames, potentially creating a backlog of actions before billing could occur. A stop-work and lapse in service without replacement negatively impact VA s Revenue Collections process mandated by Congress and United States Code. Without these collections, VA would be in danger of falling short in providing medical services to our Nation s Veteran population as this contract brings in revenue to support that mission. Title 38 United States Code (U.S.C.) Section 1729 authorizes VA to recover or collect for care or services, reasonable charges, as determined by the Secretary of Veterans Affairs, for care and services, provided for a non-service connected disability in or through a VA medical facility to a Veteran who is also a beneficiary under a third-party payer s insurance plan. VA s right to recover or collect is limited to the extent that the Veteran or a Community care provider of the care or services would be eligible to receive reimbursement or indemnification from the third-party payer, if the care or services had not been furnished by a department or agency of the United States. VA implements this authority under Title 38 CFR Section 17.101 and 17.106. A Statement of the Actions, if any, the agency may take to remove or overcome any barriers that led to the restricted consideration before any subsequent acquisition for the supplies or services is made: Document development and the required internal compliance reviews does not afford the time to proceed with the planned solicitation before year end, resulting in a need for a bridge contract to avoid a gap the services. A new contract will be solicited with full and open competition with anticipated award prior to the January 17, 2021 effective date which eliminates any barriers to future planned acquisitions. Page 6 of 6 Requirements Certification: I certify that the requirement outlined in this justification is a Bona Fide Need of the Department of Veterans Affairs and that the supporting data under my cognizance, which are included in the justification, are accurate and complete to the best of my knowledge. I understand that processing of this limited sources justification restricts consideration of Federal Supply Schedule contractors to fewer than the number required by FAR Subpart 8.4. (This signature is the requestor s supervisor, fund control point official, chief of service or someone with responsibility and accountability.) Approvals in accordance with the VHAPM Part 806.3 OFOC SOP: Contracting Officer s Certification (required): I certify that the foregoing justification is accurate and complete to the best of my knowledge and belief. Constance F. Williams Contracting Officer Programing Contracting Activity Central St. Louis_