RECOVERY/HITECH Train the Trainer For ARRA Related Services

Background: CMS currently obtains services from Palmetto GBA to support the, Medicare Fee-for-Service (FFS) Train the Trainer program under contract HHSM-500-2008-00015C which was competitively awarded. The Center for Medicare (CM), Division of Provider Information Planning and Development (DPIPD), is responsible for providing Medicare Fee-for-Service providers with the education and information they need to file claims correctly and provide quality health care services to Medicare beneficiaries. DPIPD's mission is to ensure that health care professionals receive timely, accurate and relevant Medicare coverage and payment information. Contractor support is utilized to ensure that the providers and all applicable parties have a consistent understanding of the Medicare Program and how it works, including coverage, payment systems, and program changes due to new legislation or policy initiatives. Determination of Acquisition Strategy: The ARRA legislation requires changes to Medicare coverage and/or payment requirements. It was determined to be in the best interest of the Government to obtain the services to educate providers and Medicare contractors on ARRA specific changes from the Palmetto GBA via a modification to the existing contract (HHSM-500-2008-00015C) based on the following: 1) the services required are essentially the same as the services currently obtained under the current contract; 2) the additional funding required for the ARRA change orders (CRs) is proportionate to the estimated cost of the original task order; 3) there are no changes to the SOW in terms of the general scope of the services. However, there are changes that merely specify that there will be ARRA specific changes requiring the production of ARRA specific training. 4) it is reasonable that both parties would have contemplated the need to specify requirements regarding legislatively mandated changes , thus it is reasonable that this type of modification would normally be expected for this kind of requirement; 5) additionally, this is the only viable option for maintaining the continuity of services. Determination of Contract Type: This contract action cannot be completed on a firm fixed price (FFP) basis. The contract being modified is a Cost plus Fixed Fee type contract because prior to award it was determined the nature of work is unpredictable and therefore, the price/cost could not be estimated with a reasonable degree of certainty. The requirements as modified continue to be unpredictable in nature because the amount of time required to develop the training, videos, presentations, printed materials, teleconference and other supporting material will vary greatly depending on the complexity of the policy changes, subsequent clearance process, and iterations. Due to the fact that the requirement remains unpredictable the Contracting Officer (CO) determined it in the best interest of the Government to continue to obtain these services on a cost reimbursable basis as a Cost plus Fixed Fee (CPFF) type modification.