Updated September 21, 2021
Notice ID: 211920
Contract Award Number: HHSM500201600015I
Task/Delivery Order Number: 75FCMC20F0004
CMS previously approved a justification to provide out of scope CAA work and CMS added CAA integration support, however, circumstances have changed the estimate of the scope and the time frame required for support. As mentioned, the CAA had several provisions which are going through regulatory development, and the process of discovery has uncovered additional system integration which makes it more difficult to separate the system needs of the CAA from the ACA. Three examples pointing to this increased need follow.
First, while the expanded number and type of insurance entities were considered, CMS now recognizes that there will be expanded responsibilities for enforcement of provisions as they affect healthcare providers. This requirement is mainly the result of the provision that prohibits balance billing (sending bills to consumers for remainder of costs for services provided) under any but the most circumscribed conditions. This new set of work has resulted in requirements to update the software used for enforcement action to allow for automated integration with our customer relations management solutions, and must be implemented by the first quarter of CY2022.
Second, under the CAA, there are conditions which consumers may call in to file a complaint about particular healthcare provider billing practices. This provision is narrow, and CMS anticipated that it could incorporate those consumer calls into the service desk. This would have allowed the use of a single infrastructure. However, discovery led to an approach which addresses broader complaints and requires routing complaints to appropriate help desks across different government agencies. This approach requires a more extensive type of longterm integration…
With this modification to the task order we expect to have the systems updated and the operations in place during option period 1, then evaluate operations and adjust during option period 2. As a result, the period of performance to support the services required by the Act is anticipated to begin on September 17, 2021 and continue through option periods 1 and 2 of the MSI award ending on July 22, 2023. After option period 2, CMS anticipates it will award a separate contract for a CAA System Integrator should additional integration services be necessary.
The total estimated value of the proposed sole source action (for modifications only): $13,840,525.
Posted July 30, 2021
Notice ID: 210474
Award Number: HHSM-500-2016-00015I
“The Consolidated Appropriations Act (CAA) of 2021 became Public Law No: 116-260 on December 27, 2020. CAA is a $1.4 trillion omnibus spending agreement that encompasses many different provisions. Two acts within the law apply to The Centers for Medicare and Medicaid Services (CMS) Center for Consumer Information and Insurance Oversight (CCIIO): Division BB, Title I, “No Surprises Act.” and Title II, “Transparency.” The No Surprises Act (the Act) requires work to support healthcare provided to all commercially insured patients that provides much broader coverage and IT needs than just healthcare provided by the Affordable Care Act (ACA). The Act contains a large number of disparate requirements for insurance reporting, process attestation, and federal operations.”
“Booz Allen Hamilton (BAH) provides Information Technology (IT) operational support and oversight of the Exchange systems’ components through monitoring, coordination, collaboration, and communication in coordination with the eXchange Operations Center and business stakeholders, security, and program operations through the scope of the MSI task order. It also includes integration work for the Marketplace Exchange, which supports healthcare provided by ACA.”
“CMS did not contemplate that the MSI would be responsible for integrating the IT supporting healthcare for all commercially insured patients therefore this work is out of scope and requires a justification. The work required by the Act is similar in nature to the work currently performed by the MSI and given the short time frames to implement the Act mandates over the new few months, the MSI is best positioned to help CMS meet its legislative mandates to have the IT systems in place within the next 8-9 months.”
‘BAH already facilitates integration tasks that the bill requires to stand up new the IT infrastructure; therefore, the MSI is best positioned to support the establishment of the shared services platform and defining operations such as system monitoring and hosting. The MSI contract provides a firm foundation of planning and process implementation that is critical to ensure development efforts operate smoothly as CCIIO adapts to engagement with development contractors.”
“The 8-9 month delivery timeline is the current delivery goal. CCIIO will need the MSI team available to support these development integration activities, plus any delays or contingency planning within their option year period…”
“The total estimated value of the proposed sole source action (for modifications only): $2,242,663…”
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