Page 28 - FCW, August 2019

Acquisition
time, the CMS Office of IT was using a large single-award indefinite-delivery, indefinite-quantity approach and tried to stop ADELE-QRI. However, Levenson received support from senior manag- ers at the Center for Clinical Standards and Quality, the intended owner of the BPA, and they wanted to try something new after the repeated failures of the agency’s traditional approach.
“The memory of HealthCare.gov was pretty fresh at the time, which acted as an incentive to try something differ- ent,” he said. USDS provided top cover to experiment. Levenson reached a compromise with the Office of IT that allowed him to compete the BPA for a more limited scope.
Before issuing the procurement, Lev- enson did significant market research, mainly involving the General Services Administration, to learn about nontra- ditional contractors in the marketplace. CMS then invited 12 contractors to bid, although others could also submit bids. Without Levenson’s efforts, an award to five nontraditional contractors would have been unlikely.
A few years later, ADELE-QRI had come to be regarded as a big success. Many customers outside the BPA’s home brought in work. The Government Accountability Office was so impressed with the speed and quality of the work under the BPA that it asked CMS to explain the secrets of its success.
Narrowing the field of bidders
For the MPSM BPA, the Office of IT moved from critic to champion and would take on the role of sponsoring and funding the BPA. When the solici- tation seeking expressions of interest was released, 73 contractors signed up to compete.
CMS used GSA Schedule 70 for the competition, which is the vehicle most open to new, small vendors. It doesn’t require bidders to be awardees on any existing IDIQ contract. The highlight of the procurement was a tech demo in which bidders worked on a design
challenge in real time and submitted what they developed.
The procurement used an advisory down-select, which was authorized in one of the last regulatory changes I made in 1997 before returning to Har- vard University from the Office of Fed- eral Procurement Policy. In stage one, bidders provide references and informa- tion about relevant experience, limited to 10 pages. That information forms the basis for the down-select. Companies can give commercial references as rel- evant experience, which makes it easier
there are other parts of the agency that are involved in experimental payment workflows that traditionally operated outside of the legacy payment system. We want those experimental workflows incorporated into this mod- ernization effort. This will require the integration of two very different work streams, development processes and development life cycles.”
The request for quotations specified no requirements but included “criteria” that would be used to evaluate compa- nies’ submissions:
• Sustainability — “The system, resources and processes must main- tain their current levels of service dur- ing modernization efforts.”
• Agility — “The system needs to evolve, sustainably, at the same speed as the business.”
• Integration — “Systems involved in making payments, and other CMS business functions, need the option to use modern technology to interact with the current state of the legacy system.”
• Usability —“Users interacting with the legacy system need to easily identify and extract the exact data they need, when they need it.”
• Robustness and safety — “The government will evaluate the robustness and safety of the system, noting how it responds to errors and the safety of modifying the system.”
• Security — “The government will methodically evaluate the security of the system, as well as looking at ways the system might be extended or upgraded and how that may impact the security of the system.”
• Code quality and maintainabil- ity — “The government will evaluate the solution on the quality of the code, how easy it is to understand, update, extend and maintain.”
At the end of the tech demos, there would also be a “prototyping exercise to demonstrate how the \\\[bidder\\\] would start to solve a set of system and busi- ness owner needs related to users of the system.” The RFQ also states that
CMS used GSA Schedule 70 for
the competition, which is the vehicle most open to new, small vendors.
24 August 2019 FCW.COM
for new vendors to participate. Many agency solicitation documents do not allow the practice, though it is becom- ing more common.
Of the 73 companies that entered stage one, only eight were invited to participate in stage two. The rules allow those not down-selected to bid anyway in stage two, and apparently two did so. The aggressive down-select allowed CMS to avoid the near-chaos at the Department of Homeland Security when it opened its first tech demo to every interested company and received 114 bids.
The basic problem presented in the MPSM tech demo was: “Imagine that you have come upon the large mono- lithic legacy system responsible for executing and maintaining the work- flow that processes Medicare claims in order to make payments to service providers. The maintenance of the sys- tem is proving to be unsustainable as time continues. We want you to mod- ernize this system. In addition to the existing payment processing system,