Archive: Additional Project Information and Previous CMS Guidance

On February 5, 2014, the Centers for Medicare & Medicaid Services (CMS) approved the Florida Medicaid Planning Advance Planning Document (PAPD) for the Agency for Health Care Administration (AHCA or Agency) to contract with consultants to provide research and planning, project management office (PMO), and independent verification and validation (IV&V) services to assist with the procurement of a new fiscal agent contract and enhancements to, or development of, the Florida Medicaid Management Information System (FMMIS) and Decision Support System (DSS)/Data Warehouse (DW).

Initial IAPD for DDI and Operations

On June 24, 2015, the Agency submitted an Implementation Advanced Planning Document (IAPD) to CMS related to procurement of a new fiscal agent, enhancements to the FMMIS and development of a DSS/DW. Florida selected a system takeover with upgrades and major enhancements as its FMMIS solution. This option involves significant modification or replacement of components of the existing FMMIS, and support of the existing solution is assumed or retained by the successful bidding vendor. Additionally, the Agency planned to procure the design, development, and implementation (DDI) of a replacement DSS/DW solution through a separate solicitation. At the time, the Agency anticipated at that time there would be two separate solicitations and awards – one for the FMMIS/FA and one for the DSS/DW.

The Agency anticipated both implementations to complete by July 2018. The total estimates for the overall cost, including the remaining planning and project management costs, projected for the 18 month DDI period was $54,592,185 and the five-year period that the vendors will maintain and operate the systems was $263,360,780; total estimated project cost of $317,952,965.

Implementation Advance Planning Document for Florida Medicaid Management Information System/Fiscal Agent Operations/Decision Support System/Data Warehouse, June 2015 [1.48MB PDF]

On August 12, 2015, CMS sent Florida a Request for Additional Information (RAI) letter to the Agency to separate the funding request by period into two separate documents: one for the DDI period of the project, and one for the Operations phase.

CMS Response Florida’s Implementation Advanced Planning Document, August 12, 2015 [88KB PDF]

Revised IAPD for DDI Only

On August 24 2015, the Agency submitted a revised Implementation Advanced Planning Document (IAPD) to CMS.  This IAPD was submitted per CMS’ written request dated August 12, 2015, to separate the funding request into two separate documents for the DDI and Operations periods. This IAPD related only to DDI phase of a new fiscal agent, FMMIS and DSS/DW contract. The Agency determined it would be beneficial to enlist the services of a systems integrator (SI) to ensure that both systems and any additional modular components function together appropriately. The Agency proposed that the successful vendor would serve in the important role of systems integrator for the project, responsible for bringing together the FMMIS, DSS/DW, and any additional systems supporting the Medicaid program at their appropriate integration points. The Agency also planned to solicit, via Invitation to Negotiate (ITN), a vendor or vendors to conduct a takeover of the Agency’s MMIS/FA operations, and design, develop, and implement the desired enhancements. In the same ITN, the Agency planned to seek a vendor or vendors to implement a replacement DSS/DW solution for Florida. ITNs meet Florida’s procurement regulations and are similar to a Requests for Proposals (RFPs), but allow the state to negotiate certain terms of the contract in order to receive the best products for the best price.

The Agency continued to anticipate implementation of the Fiscal Agent, FMMIS/DSS/DW solution to complete by July 1, 2018. The total estimates for the overall costs projected for the 18 month DDI period, including the remaining planning and project management costs, was $60,078,154.

Implementation Advance Planning Document for Florida Medicaid Management Information System/Fiscal Agent Operations/Decision Support System/Data Warehouse, June 2015, Revised 9/10/2015 [1.62MB PDF]

On September 23, 2015, the Centers for Medicare & Medicaid Services (CMS) approved Florida's Implementation Advance Planning Document (IAPD FL-15-008) in response to the revised IAPD submitted for the DDI phase of a new fiscal agent, FMMIS and DSS/DW contract. CMS’ approval specifically noted “Florida will require the selected Fiscal Agent to fulfill a systems integrator function to bring together the MMIS, DSS, and additional Medicaid systems at their appropriate integration points…As described in the IAPD, Florida will contract with one vendor for MMIS enhancements and Fiscal Agent services, as well as for replacement of the DSS and systems integrator services.”

FL-15-008 Implementation Advance Planning Document MMIS-DSS Approval Letter from CMS, September 23, 2015 [510KB PDF]

Revised IAPD Update for Operations Only

On September 30, 2015, the Agency submitted an Implementation Advanced Planning Document Update (IAPDU) to CMS related to Operations phase for a new fiscal agent, FMMIS and DSS/DW contract. This IAPDU is considered as an addendum to the DDI IAPD submitted to CMS on August 24, 2015 and should be reviewed in conjunction with that DDI IAPD.  This IAPDU provides budget and cost allocation information related to the Operations of the FMMIS and DSS.
The five year Operations Phase was scheduled to begin on July 1, 2018 and end on June 30, 2023. The total estimates for overall costs projected for the five year Operations period remained at $263,360,780. Consistent with the previously approved IAPD, the prime vendor selected through the competitive procurement was expected to serve as systems integrator during the Operations phase of the project.

Implementation Advance Planning Document Update for Florida Medicaid Management Information System/Fiscal Agent Operations/Decision Support System/Data Warehouse, September 30, 2015 [450KB PDF]

On November 24, 2015, CMS conditionally approved Florida’s IAPD-U for a five-year operations phase following the takeover and enhancement of the state’s MMIS by a fiscal agent procured through a competitive process, and the replacement of the state’s current DSS.  As a condition of this approval, CMS required that “Florida must remove systems integrator activities from the proposed fiscal agent responsibilities, and contract with a separate vendor for systems integration.” This conditional approval noted that “CMS had already issued an approval letter on September 23, 2015 in response to Florida’s initial IAPD for the DDI phase of the state’s MMIS and DSS re-procurement project…Under that IAPD, Florida articulated a procurement strategy whereby the selected fiscal agent would also fulfill a systems integrator function, connecting the MMIS, DSS, and additional Medicaid systems at the appropriate integration points…Based on further consideration of this project and other states’ MMIS re-procurement projects, CMS requires that the fiscal agent and systems integrator be different contractors.” 

Furthermore, CMS articulated another new position, stating “Florida is initially planning for major enhancement or replacement of the PBM, provider enrollment and management, and encounter processing subsystems, as well as upgrades to or alternative solutions for several MMIS support systems and applications.  We expect Florida to issue RFPs for these modules, informed by the interoperability standards established by the systems integrator such that there will be a takeover contractor/fiscal agent, a systems integrator, and other vendors supporting particular modules as MMIS subsystems are replaced.”

FL-16-001 Implementation Advance Planning Document Update MMIS-DSS Conditional Approval Letter form CMS, November 24, 2015 [148KB PDF]

On November 30, 2015, CMS reiterated these new positions in response to the draft ITN submitted by AHCA to CMS on October 7, 2015. CMS also indicated a need for additional clarification based on “review of the [draft] ITN, and in light of additional guidance CMS has developed pertaining to states’ procurement strategies for MMIS re-procurement projects.”

FL-16-002 CMS Response Florida’s Draft Procurement Document, November 30, 2015 [234KB PDF]

With respect to “additional guidance CMS has developed,” the Agency is only aware of the new requirements articulated in CMS’ communication to Florida. Although a modular design approach is integral to the Mechanized Claims Processing and Information Retrieval Systems (90/10) Final Rule (CMS 2392-F) published December 3, 2015, specific contracting requirements were not explicit in this Final Rule. This new “guidance” raises significant issues and questions that must be resolved. Florida has not yet fully assessed the impact of any new requirements on the projects’ schedule, costs, and associated risks. The Agency will continue to work with federal CMS to assess the most efficient path forward for a new fiscal agent, FMMIS and DSS/DW contract. However, a delay in Florida’s planned scheduled for this anticipated procurement is now unavoidable. The Agency expects to issue a new Procurement Strategy within the next 60 days.