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DEPARTMENT OF VETERANS AFFAIRS SOLE SOURCE JUSTIFICATION UNDER SIMPLIFIED PROCEDURES FOR CERTAIN COMMERCIAL ITEMS IN ACCORDANCE WITH FAR 13.5 Acquisition Plan Action ID: 36C776-22-AP-1319 Contracting ... DEPARTMENT OF VETERANS AFFAIRS SOLE SOURCE JUSTIFICATION UNDER SIMPLIFIED PROCEDURES FOR CERTAIN COMMERCIAL ITEMS IN ACCORDANCE WITH FAR 13.5 Acquisition Plan Action ID: 36C776-22-AP-1319 Contracting Activity: Department of Veterans Affairs  Veterans Health Administration  Program Contracting Activity Central - St. Louis 1 Jefferson Barracks Dr., Bldg 56  St. Louis, MO 63123 Nature and/or Description of the Action Being Processed: This procurement is for Revenue Operations Payer Relations Analytical Support in accordance with FAR 13.5 Simplified Procedures for Certain Commercial Items and specifically FAR 13.501 Special Documentation Requirements, where acquisitions conducted under Simplified Acquisition Procedures are exempt from the requirements of FAR Part 6, but still require a justification using the format of FAR 6.303-2. This Action is for a solicitation to a single source, anticipated to be awarded as a new firm fixed price, contract, to fill a short-term gap in services. Description of Supplies/Services Required to Meet the Agency s Needs: Description The Contractor shall provide and maintain a detailed, product based, resource loaded, project management plan/schedule (PMP) compliant with Project Management Body of Knowledge (PMBOK) guidance in MS Project format. Contractor shall be responsible to maintain and revise the PMP and provide version controlled revisions. The Contractor shall conduct large database extracts (up to 100,000,000 rows or lines of data), provide secure data transfer capabilities to receive or transmit large database extracts (up to 100,000,000 rows or lines data) of sensitive information in accordance with FISMA from both the VA and external sources, perform rate verifications, and provide analytical support for OCC to determine if reimbursement rates paid or proposed by third party payers (TPP) or Pharmacy Benefit Managers (PBM) meet federal payment requirements by processing the extracted data into a standardized data set that can be used in conducting multiple analyses. The deliverables listed below shall be assigned by the COR as units and may include up to 8 units per deliverable per contract year. A unit can be described as: 1) all VAMC markets within the geographic territory of a regional TPP (such as CareFirst BCBS), or 2) a regional or national Pharmacy Benefit Managers (PBM). The Contractor shall provide an analysis of Annual Charge Master Updates that analyzes impact of variances in charge amounts, unit dosage changes, and VA Utilization changes from the previous year. Preliminary data review-Identify variances plus or minus 25% for all codes. Review all codes and identify unit dose changes and VA Utilization changes per code using knowledge of conversion from Milliliters to Milligrams to properly set charge rates for prescriptions. Review nationwide charge changes and identify variances for each code from year to year and provide summary of changes. Review nationwide Geographical Area Adjustment Factors (GAAF) changes and identify variances for each zip code from year to year and provide summary of changes. Perform analysis of Inpatient (MS-DRG) and Outpatient (CPT and HCPCS) annual charge updates per code and additional analysis as needed and provide a summary of changes. Perform analysis on National Interim Charge updates per code and additional analysis as needed and provide summary of changes. Review code tables as needed to coincide with yearly review of inpatient, outpatient, professional, and administrative charges for wide discrepancies in rates, units billed, and charges and provide summary of findings. Once the analysis is completed, provide a roll up summary of all codes affected by changes in unit dosage, new codes, replacement codes and those that have substantial increases/decreases in revenue based on a set threshold. The Contractor shall provide an analysis of the effect of alternative payment methodologies and the financial impact of emerging payment methodologies in the insurance industry. Analysis shall be detailed down to the station and bill type level and procedure code level if applicable. Preliminary data review Determine most recent VA financial data by bill type at the station level and by payment processing methodology (To include, at a minimum, Claim Count, Billed Charges, Allowed Amounts, Amounts Paid, and Patient Responsibility). Project future VA utilization, billing projections, and payment methodology at the encounter and station level for 3 succeeding years based on past billing trends, changes in VA demographics, insurance reimbursement trends, etc. Using demonstrated knowledge and understanding of emerging and alternative payment methodologies (APR-DRG, EAPG, etc.) utilized by Third Party Payers in the individual VA markets provide an estimate of the financial impact of any usual VA services/codes that would be not covered, grouped, or otherwise not reimbursed by station for 3 succeeding years based on the projections in 4.5.2. For those emerging and alternative payment methodologies (APR-DRG, EAPG, etc.) provide an estimate of the necessary base rates by station that would be required to maintain a revenue neutral status for the VA for 3 succeeding years based on the projections in 4.5.2 and 4.5.3. Determine, by station, current VA coding levels, any deviations from industry norms, and make recommendations to changes in coding practices required to maximize revenue. Utilize commercial benchmarking data to provide comparisons between existing VA data and VA data projections utilizing alternative payment methodologies and provide recommendations for VA to achieve optimal reimbursement compared to the commercial market, including any suggested revisions to Federal Register Regulations in 38 CFR 17.101. Estimated Amount: $249,650 Base  $709,848 Total (Base 83 days + 5 One Month Option Periods) The goal is to use 0 option periods, they have been included to avoid any potential gap in service if the New Contract is not awarded by the target date. Period of Performance is March 24, 2022 June 14, 2022 (Base) + 5 One Month Option Periods Statutory Authority Permitting Restricted Competition: FAR 13.5 Simplified Procedures for Certain Commercial Items. The statutory authority for applying the Simplified Procedures for Commercial Items of FAR 13.5 is 41 U.S.C. § 1901 and is implemented by FAR 13.106-1(b)(2) for restricting competition on this procurement.  Competition is restricted on this procurement for the reason below:        ( x ) Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements        ( ) Unusual and Compelling Urgency        ( )  Industrial Mobilization, Engineering, Developmental or Research Capability or Expert Services        ( ) International Agreement        ( ) Authorized or Required by Statute        ( ) National Security        ( ) Public Interest Demonstration that the Contractor s Unique Qualifications or Nature of the Acquisition Requires the Use of the Authority Cited Above (applicability of authority): Many healthcare consulting and data analytic firms exist in the commercial marketplace. The Government requires a vendor with Actuarial certification and knowledge and experience with 38 CFR 17.100, 17.101, and 17.106 in order for the vendor to be successful in meeting the need. These sections of the Code of Federal Regulations provide specialized procedures regarding the requirements of VA s charge structure and payment requirements that are specific to VA medical facilities and/or VA medical services. There are very few vendors in the commercial marketplace that have this capability. Most have experience in Medicare billing/payment, however VA is very different than Medicare and specialization is necessary. Accordingly, Best Practice Associates d/b/a Federal Advisory Partners (current contract VA777-17-C-0007 expires March 23, 2022) is the only firm capable of providing the services described in Section 3 above without the Veteran s Health Administration experiencing substantial impact to the Payer Relation s program due to the time it would take to onboard a new vendor. The services performed under this contract are considered mission critical. Description of Efforts Made to ensure that offers are solicited from as many potential sources as deemed practicable: A synopsis will be made publicly available within 14 days after contract award in accordance with FAR 13.501(a)(iii). Determination by the CO that the Anticipated Cost to the Government will be Fair and Reasonable: The costs for this requirement are anticipated to be considered fair and reasonable based on the contractor s historical 2% annual increases. After pricing is received, it will be compared to current contract pricing as well as the pricing for similar contracts in FPDS. If determined to be fair and reasonable, as anticipated, this will be documented in a Price Reasonable Determination. Description of the Market Research Conducted and the Results, or a Statement of the Reasons Market Research Was Not Conducted: Market research was not conducted for this requirement as switching to a different vendor/onboarding wouldn t be accomplished in time to avoid a lapse in service. Any Other Facts Supporting the Use of Other than Full and Open Competition: This contract is not suitable for competition for the reasons stated in section 5 above. Listing of Sources that Expressed, in Writing, an Interest in the Acquisition: N/A A Statement of the Actions, if any, the Agency May Take to Remove or Overcome any Barriers to Competition before Making subsequent acquisitions for the supplies or services required: This contract and the tasks within will be obsolete following its expiration. A follow on contract is not anticipated. 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 and belief. _____________________________ ________________________ Date Payer Relations Manager VHA Office of Finance-Revenue Operations Approvals in accordance with the VHAPM Part 806.3 OFOC SOP: Contracting Officer or Designee s Certification (required): I certify that the foregoing justification is accurate and complete to the best of my knowledge and belief. _____________________________ ________________________ Date Contracting Officer PCAC St. Louis One Level Above the Contracting Officer (Required over SAT but not exceeding $750K): I certify the justification meets requirements for other than full and open competition. _____________________________ ________________________ Date Supervisory Contract Specialist PCAC St. Louis