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Government Remains Silent on Emergency, No-Bid Obamacare Financial Management Contract

12:40 PM, Nov 21, 2013 • By JERYL BIER
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Since enactment of the Affordable Care Act and establishment of the new Marketplace, CMS has been actively developing and refining new and existing procedures and requirements to ensure the successful implementation and operation of the new, complex Marketplace. Throughout every phase of implementing such a large and dynamic program of a kind that has never been done before and as requirements and procedures are being developed and are emerging, CMS continues to learn, evolve and gain insight. As the deadline for implementing the new Marketplace nears, the Agency has been assessing and testing its plan and solution for implementing the new Marketplace. With every unknown and variable encountered, CMS has been leveraging resources and changing, refining and retesting its solution, to not only ensure that the Marketplace is operational on January 1, 20l4, but to ensure that this vital part of the Affordable Care Act is operating effectively and efficiently with as little complication as possible. CMS has recently learned that specialized financial management services and expertise are needed beyond what was initially anticipated and beyond CMS' currently available resources... 

With the impending and mandated October 1, 20l3 Marketplace enrollment and January 1, 2014 go-live deadlines nearing, CMS' need for contractor-provided financial management services has reached an unusual and compelling level of urgency. The prospect of a delay in implementing the Marketplace by the operational date of January 1, 2014, even for a few days, would result in severe consequences, financial and other. The effect of those consequences would most importantly be measured by the impact to the estimated millions of Americans and small businesses that have no health care today or access to affordable health care. Furthermore, if payments are not made and debts are not collected, with critical consideration given to timeliness, accuracy and integrity, the Agency's implementation and operation of the Marketplace and the Affordable Care Act will certainly be jeopardized.

In addition to the urgent and compelling nature of this requirement and the potential for financial and other harm to the Government if the Marketplace is delayed, regrettably CMS does not have enough time to conduct a full and open or limited competition. Acquiring contractor financial services to assist CMS in developing and testing its Marketplace financial activity implementation solution is already minimally two months overdue; therefore, the contractor will be working under an accelerated and fast-tracked schedule...

The document goes on to describe how CMS arrived at the decision to award the no-bid contract to Novitas, a contractor that already does a considerable amount of work for CMS. The approval was signed by no fewer than nine CMS officials, up to and including Chief Operating Officer A. Michelle Snyder.

The type of work to be done by Novitas is quite extensive and is itemized in the project description:

The contractor shall provide financial management, accounting and reporting services in support of CMS' administration and oversight of the Marketplace financial activities and functions using CMS' accounting system, the Healthcare Integrated General Ledger Accounting System (HIGLAS) to include: accounting, printing and mailing, tracking of accounts receivable and accounts payable, documenting funds collected by CMS, data validation, activity reporting, debt management functions, application of receipts to appropriate transactions, referral of debt to the Department of the Treasury (Treasury), specified batch payment functions in HIGLAS, and systems interface testing and support for HIGLAS functionality.

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