Single Source Procurement: Electronic Plan of Correction

Pursuant to New York State Finance Law § 163.10(b), The New York State Department of Health is presenting the following summary of relevant circumstances, and material and substantial reasons why a competitive procurement was not feasible.

The Department of Health requested and received a Contract Reporter Exemption Request for an 8 month contract extension from 9/28/2015 through 5/31/2016 via the Sole Source Contract (#C028237) with Alpine Technology Group (ATG) to convert the Electronic Plan of Correction application to a more standard software framework that can be supported by the Office of Information Technology Services (ITS) and to provide maintenance until the end of the contract period. The Electronic Plan of Correction software was successfully implemented for ten (10) healthcare provider types, displaying both operational and cost efficiencies.

The Department of Health regulate care providers within New York State. This activity includes inspections and investigations which may result in findings of deficiency in the provision of care or noncompliance with conditions of participation in Medicaid and Medicare. Providers are formally notified of such findings and must respond through the Statement of Deficiency (SOD) – Plan of Correction (POC) process. This process has historically been carried out by the exchange of paper documents via the U.S. Postal Service mail.

The Electronic Plan of Correction (EPOC) system provides an application that supports electronic communication of SODs and POCs between certain regulated facilities. These facilities include Acute Care Facilities (hospitals, hospital extension clinics and diagnostic and treatment centers (DATCs), Nursing Homes and Adult Homes and the New York State Department of Health (DOH). The EPOC system provides notification of SODs to providers via e-mail and allows electronic access to SODs via the Department's Health Commerce System (HCS). The EPOC system also allows providers to submit POCs electronically. POCs are reviewed by DOH staff, which makes decisions about whether to accept the POC, reject it, or require further revision. DOH staff is also able to electronically provide feedback to facilities indicating reasons for rejecting an unacceptable POC. The system includes an electronic attestation process which ensures each POC submission has a legally valid electronic signature by tracking the user's HCS account information and through an acceptance of an attestation statement from an authorized signer within the provider organization. The system provides for e-mail notifications to DOH and provider staff as transactions occurs throughout the process to communicate timely POC acceptance and update status to both parties.

The EPOC system is secure and ensures the confidentiality of health related information. The system provides reports to monitor the timeliness of submission POC information to the Department.

The purpose of the EPOC system is to save the high cost of mailing documents, improve efficiency and shorten the length of the SOD-POC process and to support transaction tracking, auditing and management reporting.

All correspondence and paperwork regarding surveys is handled through the HCS portal and via email for those providers participating in the program.

ATG has already developed and tested the EPOC system, which is integrated with the federal ASPEN software within the DOH HCS infrastructure. The EPOC software has been implemented for several provider types. It is estimated that a skilled System Analyst would require 160 – 320 hours to understand the basic ASPEN and EPOC data model alone. The model contains approximately 225 tables associated with four applications: certification surveys, complaint tracking, enforcement and resource scheduling and tracking, as well as the new EPOC application. There are thousands of data fields in the model. Data elements have been added to accommodate individual state's needs and through these changes the system supports non-Federally required (state only) surveillance activity. In addition expired and modified data elements exist in the model. Due to the complexity and nuances of the data model, it is realistic to estimate a skilled System Analyst would require months to gain enough knowledge of ASPEN and EPOC applications to be productive. It would also require extensive mentoring of the vendor by DOH staff during the learning phase. This is simply not feasible as DOH staff resources are not available and the delay and increased cost would then threaten project success. Using ATG for the conversion is highly efficient and cost effective. ATG staff are expect in both the data model for ASPEN and EPOC. No other vendor could provide equivalent conversion of the software without a major investment of a development team of over several thousand man-hours, which is why there is a considerable difference between the Sole Source and HBITS contract amounts. Additionally, it would be impractical to utilize another vendor if that was possible due to time constraints of the available funding discussed above.

Procurement / Program Name Electronic Plan of Correction
Contractor Name(s) Alpine Technology Group
Contract Period 9/28/2015 – 5/31/2016
Contract Number(s) C028237