Description
JUSTIFICATION AND APPROVALFOR OTHER THAN FULL AND OPEN COMPETITION Upon the basis of the following justification, I hereby approve the issuance of the contractual action described below using other than full and open competition, pursuant to the authority cited herein. 1. Contracting Activity Department of Veterans Affairs Office of Acquisition and Logistics Center for Acquisition Innovation (049A1) Washington, DC 20420 2. Nature and/or description of the action being approved: This justification and approval sets forth the facts and requests approval for the issuance of a Firm Fixed Price Indefinite Delivery Indefinite Quantity emergency bridge contract to Envoy LLC dba Emdeon Business Services LLC, VHA's current EDI Health Care Clearinghouse (HCCH) vendor to maintain all current operational levels until a follow-on contract can be finalized. The current contract for these services is set to expire March 31, 2009. All available options have been exercised and the contract can no longer be extended. This emergency bridge contract is for 6 months, effective April 1, 2009, through September 30, 2009. This contract also includes a 6 month option period. The estimated cost for the base and option periods is $5,852,155.00. 3. Description of supplies or services required to meet the agency's needs: The purpose of this contract is for Emdeon to continue providing critical Electronic Data Interchange (EDI) Health Care Clearinghouse (HCCH) services to VHA for third-party reimbursement for veterans' nonservice-connected health care and for payment of health care services provided to veterans and eligible family members by health care practitioners in the community under the programs where VHA function as a payer. The following services are required for the base and option period: GENERAL SUPPORT: CLIN 0001 Operational Support CLIN 0002 Project Manager CLIN 0003 Labor Categories: Business Analyst Healthcare EDI Analyst Technical Solutions Specialist Programmer/Analyst/Systems Engineer Implementation Analyst/Account Manager PROVIDER TASKS: CLIN 0004 Operations Maintenance - Provider CLIN 0005 Batch Transactions: 837 Health Care Claims (Participating Payers) 837 Health Care Claims (non-Participating Payers) 837 Health Care Claims (Industry Standard Print to Paper) 837 Health Care Claims ( w/MRA Attached Print to Paper) 835 Health Care Claim Payment/Advice (Participating) 835 Health Care Claim Payment/Advice (non-Par) 277 Health Care Claim Status Response CLIN 0006 Real-time Transactions: 270 Health Care Eligibility Request 271 Health Care Eligibility Response NCPDP B1 Rx Billing/B3 Rx Rebill NCPDP B2 Rx Reversal NCPDP E1 Eligibility Verification PAYER TASKS: CLIN 0007 Operations Maintenance - Payer CLIN 0008 Batch Transactions: 837 Health Care Claims 835 Health Care Claim Payment/Advice CLIN 0009 Real-time Transactions: 270/271 Health Care Eligibility Benefit Inq. and Response 276/277 Health Care Claim Status and Response 278 Health Care Services Review and Response 4. Identification of the statutory authority permitting other than full and open competition: The statutory authority of this justification is FAR 6.302-2, Unusual and Compelling Urgency. 5. Demonstration that the proposed contractor's unique qualifications or the nature of the acquisition requires use of the authority cited: This contract is required to avoid a catastrophic failure of third party health care revenue streams inherent to the daily operational activities of VHA as a provider and payer of heath care services. VHA as a provider collects over $2.4 billion in third-party reimbursement revenues directly supporting patient care activities and as a payer VHA pays over $4 billion in payments to community health care practitioners in support of care provided to eligible veterans and their dependents. In addition to the financial losses, disruption of these critical EDI HCCH services would be the cause of: " Revenue disruptions to community health care practitioners providing critical health care to veterans and their dependents where VHA functions as a health care payer, " Interruption of legally mandated submission of claims for Medicare equivalent remittance information, " Non-compliance with the electronic transaction standards and national provider identifier provisions of HIPAA (Health Insurance Portability and Accountability Act). 6. Description of efforts made to ensure that offers are solicited from as many potential sources as is practicable, including whether a notice was or will be publicized as required by Subpart 5.2 and, if not, which exception under 5.202 applies: The proposed contract action is made under the conditions described in FAR 6.302-2 and the Government would be seriously injured if the agency complies with the time periods specified in 5.203. A full and open competition is currently in progress for global EDI service capabilities. While the initial target for contract award was prior to the end of calendar 2008, it was anticipated that the timeline might be longer. In fact, a number of factors are impacting the proposal evaluation process: the number and complexity of the proposals received, the formal Technical Evaluation process reviews and need for technical and legal guidance, the need to enter into discussions with vendors, and finalization of the award process. Thus, a reasonable timeline for contract award is early or mid April 2009. Further, contract award, especially if it is to a new vendor, will need to be followed by a start-up period as an orderly transition is planned and implemented in order to avoid disruption of VHA revenue. This may well involve a phased cut-over of certain EDI transactions until all transactions are successfully migrated to the new vendor. For these reasons-anticipated date of contract award plus the need for orderly transition to selected vendor-a bridge contract is needed with the current vendor. The period of performance for the bridge contract allows for overlap with the period of performance for any new vendor selected. The current contract for EDI HCCH services expires on March 31, 2009, and VHA must ensure continuity of VHA EDI revenue processes. 7. Determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable: The contracting officer will conduct a price analysis to ensure prices proposed are both fair and reasonable. 8. Description of the market research conducted and the results or a statement of the reason market research was not conducted: See Paragraph 6 above. 9. Any other facts supporting the use of other than full and open competition: Emdeon is currently providing EDI HCCH services under contract V101-(93)P-2125 which expires March 31, 2009 and currently processes over 23 million VHA EDI transactions per year. 10. A listing of the sources, if any, that expressed, in writing, an interest in the acquisition: Due to the nature (complexity, scope, operational integration) of the current work it is not feasible for anyone other than the current vendor to maintain current capabilities while VA pursues another contract for these services. 11. A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition for the supplies or services required: There are no barriers to competition as evidenced by the Department's issuance of an unrestricted solicitation (VA-101-08-RP-0260) in September 2008 for a five year contract for comprehensive clearing house services. Technical proposals for this solicitation are under evaluation and an award is anticipated in April of this year.