For. Planning and Research Related to Procurement of a Systems Integration, Enhancements to a MMIS, New Fiscal Agent, and a Replacement DSS

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1 IMPLEMENTATION ADVANCE PLANNING DOCUMENT - UPDATE For Systems Integrator/ Florida Medicaid Management Information System/ Fiscal Agent Operations/ Decision Support System For Planning and Research Related to Procurement of a Systems Integration, Enhancements to a MMIS, New Fiscal Agent, and a Replacement DSS State of Florida Agency for Health Care Administration Division of Medicaid September 2015

2 Support System Implementation Advance Planning Document:2018 Procurement Table of Contents Section 1 Executive Summary Systems Integrator Role in Operations... 4 Section 2 Project Management Plan Project Scope SI/FMMIS/FA/DSS-DW Project DSS OPERATIONS... 9 Section 3 Proposed Budget and Cost ALlocation Proposed Operations Phase Budget Proposed Operations Phase Cost Allocation MMIS Detailed Budget Template (MDBT) for Operations Phase Section 4 Statements and Assurances ii

3 Support System Implementation Advance Planning Document:2018 Procurement Table of Exhibits Exhibit 1-1: Systems Integrator Scope of Effort Operations... 5 Exhibit 2-1: FMMIS/FA Major Activities... 8 Exhibit 2-2: FMMIS/FA Project Deliverables... 9 Exhibit 2-3: DSS Project Major Activities Exhibit 2-4: DSS Project Deliverables Exhibit 3-1: Operations Phase Budget Detail Exhibit 3-2: Operations Cost Allocation Exhibit 3-3: Cost Allocation MMIS Detailed Budget Template (MDBT) Exhibit 4-1: CMS Seven Conditions and Standards Compliance Matrix Exhibit 4-2: Procurement Assurances iii

4 SECTION 1 EECUTIVE SUMMARY This document is an update to the Design, Development, and Implementation (DDI) Implementation Advance Planning Document (IAPD) created by the Florida Agency for Health Care Administration (AHCA or Agency) for the procurement of a systems integrator (SI), new fiscal agent (FA) contract and enhancements to, or development of, the Florida Medicaid Management Information System (FMMIS) and Decision Support System (DSS). This project, related to the procurement, is referred to as the SI/FMMIS/FA/DSS-DW Project (the Project). This update to the DDI IAPD (IAPDU) is submitted per CMS written request dated August 12, 2015, 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. This IAPDU should be considered as an addendum to the DDI IAPD submitted to the Centers for Medicare & Medicaid Services (CMS) on August 24, 2015 and should be reviewed in conjunction with the DDI IAPD. This IAPDU provides budget and cost allocation information related to the Operations of the FMMIS and DSS. The five year Operations Phase is scheduled to begin on July 1, 2018 and end on June 30, Current total estimates for the Project indicate the five year Operations period to cost $263,360, SYSTEMS INTEGRATOR ROLE IN OPERATIONS The primary vendor of the SI/FMMIS/FA/DSS-DW Project will serve as systems integrator during the Operations phase of the Project. The scope of effort for this role is summarized in Exhibit 1-1: Systems Integrator Scope of Effort Operations. 4

5 Exhibit 1-1: Systems Integrator Scope of Effort Operations For the duration of the Operations phase, the systems integrator will be required to: Ensure that all systems required to be interoperable with Medicaid function together appropriately and have the ability to share and receive data Deploy the activities, architecture, and tools necessary for achieving consistent access to data across the Medicaid enterprise in order to meet the data needs of Florida Medicaid and its business processes Be uniquely accountable for the interoperability of the MMIS and DSS with other Medicaid support systems Deliver business results through effective and efficient business processes Leverage Code and Technology reuse Support interoperability between systems inside and outside the Agency, continuing to incorporate industry standards (e.g. HIPAA) 5

6 All other information related to the SI/FMMIS/FA/DSS-DW Project can be found in the DDI IAPD, which includes: Summary of Planning Activities Statement of Needs and Objectives Requirements and Alternatives Analysis Proposed Budget and Cost Allocation (Design, Development, and Implementation (DDI) period only) Attachments SECTION 2 PROJECT MANAGEMENT PLAN The basis for developing the Agency s FMMIS/FA/DSS Project Management Plan is centered on the preparation, maintenance, and use of quality deliverables to meet the requirements and expectations of the project s strategies and plans. The project will follow a well-structured, clearly defined project plan applied in a disciplined manner. A project team consisting of state and contract staff will employ industry standards and best practices for project management throughout the project life cycle. 2.1 SI/FMMIS/FA/DSS-DW PROJECT SCOPE SI/FMMIS/FA PROJECT The SI/FMMIS/FA/DSS-DW Project will be conducted in the following phases, which may be adjusted based on the successful Vendor s approved plan for these phases. Even though the Agency has combined the MMIS and DSS in one contract, it is recognized that the solutions offered will most likely result in a prime MMIS vendor and separate DSS subcontract in order to meet the needs of Florida Medicaid contained in the solicitation requirements. This document separates the two systems to illustrate the diverse activities and deliverables. Operations The Operations Phase constitutes all operations or production processing work required of the Vendor, and begins at the set point in time when the Vendor receives the first claim for production processing. Operations includes, but is not limited to, the processing of claims and encounters for payment, maintenance and/or upgrading of all components of the claims process system, support of all elements of recipient file maintenance operations, document imaging, mailroom activities, training activities, and support of all elements of the provider relations operations. The Operations Phase is anticipated to run from July 1, 2018 through the end of the contract on June 30, Federal Certification Federal certification of the FMMIS using the CMS MECT criteria is a mandated requirement. The Vendor, for the purpose of obtaining federal certification, must plan to cooperate fully with 6

7 the Agency and its stakeholders, including all Medicaid Enterprise Vendors and sub- Contractors whose products and/or ancillary services interface with the FMMIS. Upon the contract effective date, the Vendor will be provided with updated information regarding the MITA SS-A, the Medicaid Enterprise Toolkit Checklists, and the MITA Traceability Matrix. These documents, all of which have been developed to reflect Floridaspecific business processes, mapped to specific solicitation document requirements, and included on the MITA Traceability Matrix for measurement and reporting purposes, will provide the information and tools necessary for the Vendor s development of processes to achieve CMS certification. While some certification activities will occur directly after the contract is signed, the primary tasks for the Federal Certification Phase are anticipated to run from January 1, 2018 through March, Turnover The Vendor must prepare for turning over responsibilities and operations at the end of the contract. The Vendor must cooperate with the successor fiscal agent, other Vendors, and the Agency in the planning and transfer of operations. The Vendor must dedicate special additional resources to this phase. This phase will begin about twelve months before the end of the contract period and end about six months after the end of the contract period, or as extended by the exercise of contract provisions or amendments to the contract. Turnover will consist of three sub-phases: Turnover Preparation Post-Turnover Support Transfer of Vendor Operations The Turnover Phase is anticipated to run from July 1, 2022 through December 31, Major Activities The Vendor shall set the schedule of major activities for Agency review during each phase in the work plan. All key dates are contingent upon Agency approval. All deliverables dates and key dates are contingent upon State approval. Exhibit 2-1: FMMIS/FA Major Activities below contains a general overview of the major activities to occur during each FMMIS/FA Project phase. PHASE MAJOR ACTIVITY Submission of Pre-Operations Deliverables Operations Operations Start Up Deliver Updated Communication Plan for Review and Approval 7

8 PHASE MAJOR ACTIVITY Deliver Operational Training Plan for Review and Approval Deliver Data and Document Management Plan for Review and Approval Deliver System Modification Plan for Review and Approval Execute Initial Weekly Reports for Review and Approval Delivery of CMS Certification Management Plan, including Schedule of Activities Delivery of the completed MECT checklists and supporting documentation. Delivery of CMS Certification Readiness Testing Results Federal Certification Delivery of the Certification Readiness Letter to Agency Pre-Certification meeting with CMS Completion of the CMS Certification Review Vendor completion of any remediation activities Final Certification of the FMMIS Agency approval of Turnover Plan Turnover Agency approval of FMMIS requirement statement Completion of Turnover training Completion of Turnover phase Exhibit 2-1: FMMIS/FA Major Activities Deliverables The Vendor shall set the schedule of dates for submittal of major deliverables for Agency review during each phase in the work plan. All deliverables dates and key dates are contingent upon Agency approval. Exhibit 2-2: FMMIS/FA Project Deliverables below contains a general overview of the deliverables associated with each FMMIS/FA Project phase. PHASE DELIVERABLE Quality Assurance Procedures and Standards Manual Communications Plan Weekly Status Reporting Operations Training Plan Staffing Management Plan Documentation Management Plan Monthly Report Card Federal Certification CMS Certification Management Plan CMS Certification Readiness Plan 8

9 PHASE DELIVERABLE Completed MECT Checklists and Supporting Documentation CMS Certification Readiness Testing Results CMS Certification Readiness Letter Turnover Plan FMMIS requirement statement Turnover Financial Reconciliation Report FMMIS software, files, and system, and user and operations documentation in hard and soft copy format Turnover Results Report Exhibit 2-2: FMMIS/FA Project Deliverables DSS/DW PROJECT Overview The DSSDW Project will be conducted in the following phases: Operations The Vendor must host, operate, maintain, and enhance the DSS and execute all responsibilities described in the procurement until each function is turned over to the successor Vendor at the end of the contract, including any optional additional periods or extensions. The Agency requires that the Vendor provide suitably qualified personnel resources and any software necessary to support the production and operation of the DSS and also meet performance requirements and performance standards described in the ITN. The Operations Phase is anticipated to run from July 1, 2018 through the end of the contract on June 30, Federal Certification Federal Certification of the DSS using the CMS MECT criteria is a mandated requirement. Federal Certification of the DSS will be conducted as a single operation, as a series of computing platforms operating seamlessly within the Agency s designated computing environments. The Vendor, for the purpose of obtaining Federal Certification, will cooperate fully with the Agency and its stakeholders, including all Medicaid Enterprise Vendors and sub- Vendors whose products and/or ancillary services interface with the DSS. The Federal Certification Phase is anticipated to run from January 1, 2018 through March,

10 Turnover The Vendor will prepare for turning over responsibilities and operations at the end of the contract. The Vendor will cooperate with the successor Vendor, other Vendors, and the Agency in the planning and transfer of operations. The Vendor will dedicate special additional resources to this phase. This phase will begin twelve (12) months before the end of the contract period and end six (6) months after the end of the contract period, or as extended by the exercise of contract provisions or amendments to the contract. The Turnover Phase is anticipated to run from July 1, 2022 through December 31, Major Activities The Vendor shall set the schedule of major activities for Agency review during each phase in the work plan. All key dates and deliverables are contingent upon Agency approval. Exhibit 2-3: DSS Project Major Activities below contains a general overview of the major activities to occur during each DSS Project phase. PHASE Operations Start Up MAJOR ACTIVITY Deliver Updated Communication Plan for Review and Approval Deliver Operational Training Plan for Review and Approval Operations Deliver Data and Document Management Plan for Review and Approval Deliver System Modification Plan for Review and Approval Execute Initial Weekly Reports for Review and Approval Deliver Annual White-Paper for Review and Approval Delivery of CMS Certification Management Plan, including Schedule of Activities Day One (1) of Operations Delivery of the completed MECT checklists and supporting documentation Delivery of CMS Certification Readiness Testing Results Federal Certification Delivery of the Certification Readiness Letter to Agency Pre-Federal Certification meeting with CMS Completion of the CMS Certification review Vendor completion of any remediation activities Final Certification of the DSS Agency approval of Turnover Plan Turnover Agency approval of DSS Resource Requirement Statement Completion of Turnover training Completion of Turnover Exhibit 2-3: DSS Project Major Activities 10

11 Deliverables The Vendor shall set the schedule of dates for submittal of major deliverables for Agency review and approval during each phase in the work plan. Exhibit 2-4: DSS Project Deliverables below contains a general overview of the deliverables associated with each DSS Project phase. PHASE Communication Plan DELIVERABLE Operations Training Plan Data and Document Management Plan System Modification Plan CMS Certification Management Plan CMS Certification Readiness Plan Federal Certification Completed MECT Checklists and Supporting Documentation CMS Certification Readiness Testing Results CMS Certification Readiness Letter Turnover Plan DSS Resource Requirement Statement Turnover Financial Reconciliation Report DSS software, files, and system, and user and operations documentation in hard and soft copy format Turnover Results Report Exhibit 2-4: DSS Project Deliverables 11

12 SECTION 3 PROPOSED BUDGET AND COST ALLOCATION This section presents the proposed budget and cost distribution across funding sources for the Operations Phase of the Project. Detail budget information for the Operations Phase of the project is presented by quarter in Exhibit 3-1: Operations Phase Budget Detail. Calculations of federal and state shares are provided in Exhibit 3-2: Operations Cost Allocation. Cost allocation details are provided in the CMS-required format in Exhibit 3-3: Cost Allocation MMIS Detailed Budget Template (MDBT). 3.1 PROPOSED OPERATIONS PHASE BUDGET This sub-section includes a summary of the proposed Operations Phase budget by State and Federal fiscal years. The following table contains a summary of the estimated budget for the overall Operations effort. Current estimates indicate the five year Operations Phase to cost $263,360,

13 Support System Implementation Advance Planning Document-Update:2018 Procurement Project overhead Operations Phase Summary Year 1 Year 2 Year 3 Total State FY Q Q Q Q Q Q Q Q Q Q Federal FY Q Q Q Q Q Q Q Q Q Q State Owned Equipment $7,000,000 $350,000 $350,000 $350,000 $350,000 $350,000 $350,000 $350,000 $350,000 $350,000 $350,000 Postage $12,000,000 $600,000 $600,000 $600,000 $600,000 $600,000 $600,000 $600,000 $600,000 $600,000 $600,000 Printing $2,000,000 $100,000 $100,000 $100,000 $100,000 $100,000 $100,000 $100,000 $100,000 $100,000 $100,000 Subtotal Project Overhead $21,000,000 $1,050,000 $1,050,000 $1,050,000 $1,050,000 $1,050,000 $1,050,000 $1,050,000 $1,050,000 $1,050,000 $1,050,000 Operations Contract SI/FMMIS/FA/DSS-DW Contract $242,360,780 $12,118,039 $12,118,039 $12,118,039 $12,118,039 $12,118,039 $12,118,039 $12,118,039 $12,118,039 $12,118,039 $12,118,039 Subtotal Operations Contract $242,360,780 $12,118,039 $12,118,039 $12,118,039 $12,118,039 $12,118,039 $12,118,039 $12,118,039 $12,118,039 $12,118,039 $12,118,039 Total Operations Period $263,360,780 $13,168,039 $13,168,039 $13,168,039 $13,168,039 $13,168,039 $13,168,039 $13,168,039 $13,168,039 $13,168,039 $13,168,039 Year 3 (cont.) Year 4 Year 5 State FY Q Q Q Q Q Q Q Q Q Q Federal FY Q Q Q Q Q Q Q Q Q Q $350,000 $350,000 $350,000 $350,000 $350,000 $350,000 $350,000 $350,000 $350,000 $350,000 $600,000 $600,000 $600,000 $600,000 $600,000 $600,000 $600,000 $600,000 $600,000 $600,000 $100,000 $100,000 $100,000 $100,000 $100,000 $100,000 $100,000 $100,000 $100,000 $100,000 $1,050,000 $1,050,000 $1,050,000 $1,050,000 $1,050,000 $1,050,000 $1,050,000 $1,050,000 $1,050,000 $1,050,000 $12,118,039 $12,118,039 $12,118,039 $12,118,039 $12,118,039 $12,118,039 $12,118,039 $12,118,039 $12,118,039 $12,118,039 $12,118,039 $12,118,039 $12,118,039 $12,118,039 $12,118,039 $12,118,039 $12,118,039 $12,118,039 $12,118,039 $12,118,039 $13,168,039 $13,168,039 $13,168,039 $13,168,039 $13,168,039 $13,168,039 $13,168,039 $13,168,039 $13,168,039 $13,168,039 Exhibit 3-1: Operations Phase Budget Detail 13

14 3.2 PROPOSED OPERATIONS PHASE COST ALLOCATION This sub-section describes the cost allocation methodology and presents the overall distribution of estimated Operations Phase project costs to various funding sources. The Agency follows the principles and standards described in the OMB Circular A-87 (Revised) in establishing an overview of anticipated costs related to the operations the FMMIS and DSS. Of particular interest to CMS, the Agency presents a cost allocation plan based on the guidelines defined in the State/Local Wide Central Service Cost Allocation Plans. The development of the cost allocation plan followed the following assumption: The Agency expects to close out the DDI period and enter the Operations Phase on July 1, 2018, which will continue through June 30, Shared Costs Benefiting Category Share Amount ($) Operations Phase Match Rate Federal Share ($) ($) SI/FMMIS/FA/DSS-DW Contract $242,360,780 75% $181,770,585 $60,590,195 Operations Phase Overhead (State Owned Equipment) $7,000,000 75% $5,250,000 $1,750,000 Operations Phase Overhead (Postage and Printing) $14,000,000 50% $7,000,000 $7,000,000 TOTAL SHARED COSTS $263,360,780 $194,020,585 $69,340,195 Exhibit 3-2: Operations Cost Allocation 14

15 Support System Implementation Advance Planning Document-Update:2018 Procurement 3.3 MMIS DETAILED BUDGET TEMPLATE (MDBT) FOR OPERATIONS PHASE This sub-section presents the cost allocation methodology in the CMS-required MDBT format, which breaks the funding request out by FFY, FFP rate, and Medicaid Budget and Expenditure System (MBES) line item. M&O Equip. Overhead CMS Share (75% FFP) (25%) MMIS CMS Share (75% FFP) (25%) 4A - 4B - MMIS Enhanced Funding 75% FFP Total Total FY2018, Q4 $262,500 $87,500 $9,088,529 $3,029,510 $9,351,029 $3,117,010 FY2019 $1,050,000 $350,000 $36,354,117 $12,118,039 $37,404,117 $12,468,039 FY2020 $1,050,000 $350,000 $36,354,117 $12,118,039 $37,404,117 $12,468,039 FY2021 $1,050,000 $350,000 $36,354,117 $12,118,039 $37,404,117 $12,468,039 FY2022 $1,050,000 $350,000 $36,354,117 $12,118,039 $37,404,117 $12,468,039 FY2023, Q1-Q3 $787,500 $262,500 $27,265,588 $9,088,529 $28,053,088 $9,351,029 TOTAL for FFY M&O (Mechanized Systems) $5,250,000 $1,750,000 $181,770,585 $60,590,195 $187,020,585 $62,340,195 Equip. Overhead CMS Share (50% FFP) (50%) MMIS CMS Share (50% FFP) (50%) MMIS CMS Share (50% FFP) (50%) 5A - 5B - 5C - Print/Post Overhead Funding 50% FFP Total Total FY2018, Q4 $350,000 $350,000 $350,000 $350,000 FY2019 $1,400,000 $1,400,000 $1,400,000 $1,400,000 FY2020 $1,400,000 $1,400,000 $1,400,000 $1,400,000 FY2021 $1,400,000 $1,400,000 $1,400,000 $1,400,000 FY2022 $1,400,000 $1,400,000 $1,400,000 $1,400,000 FY2023, Q1-Q3 $1,050,000 $1,050,000 $1,050,000 $1,050,000 TOTAL for FFY $7,000,000 $7,000,000 $0 $0 $0 $0 $7,000,000 $7,000,000 15

16 Support System Implementation Advance Planning Document-Update:2018 Procurement MMIS CMS Share MMIS CMS Share MMIS CMS Share 2A&B+ - 4A&B+ - 5A,B&C+ - TOTAL FFP STATE SHARE TOTAL APD TOTAL (TOTAL COMPUTABLE) FY2017, Q2-Q4 $0 $0 $0 FY2018 $9,351,029 $3,117,010 $350,000 $350,000 $9,701,029 $3,467,010 $13,168,039 FY2019 $37,404,117 $12,468,039 $1,400,000 $1,400,000 $38,804,117 $13,868,039 $52,672,156 FY2020 $37,404,117 $12,468,039 $1,400,000 $1,400,000 $38,804,117 $13,868,039 $52,672,156 FY2021 $37,404,117 $12,468,039 $1,400,000 $1,400,000 $38,804,117 $13,868,039 $52,672,156 FY2022 $37,404,117 $12,468,039 $1,400,000 $1,400,000 $38,804,117 $13,868,039 $52,672,156 FY2023, Q1-Q3 $28,053,088 $9,351,029 $1,050,000 $1,050,000 $29,103,088 $10,401,029 $39,504,117 TOTAL for FFY $0 $0 $187,020,585 $62,340,195 $7,000,000 $7,000,000 $194,020,585 $69,340,195 $263,360,780 Exhibit 3-3: Cost Allocation MMIS Detailed Budget Template (MDBT) 16

17 SECTION 4 STATEMENTS AND ASSURANCES This section includes the following statements and assurances: Security/Interface and Disaster Recovery/Business Continuity Requirements Statement. Required assurances of compliance with cited Code of Federal Regulations (CFR) and CMS Seven Conditions and Standards attestation (CMS Expedited Eligibility and Enrollment Advance Planning Document Checklist). The Agency will comply with all security and interface requirements relevant for the design, development, and implementation of the next MMIS. Specifically, the Agency will comply with the following Federal Regulations: 42 CFR 431, Subpart F (Safeguarding Information on Applicants and Beneficiaries) 42 CFR (Standardized formats for furnishing and obtaining information to verifying income and eligibility) 45 CFR (Software and Ownership Rights in Specific Conditions for FFP); 45 CFR (Scope and Applicability) 45 CFR (Safeguarding Information for the Financial Assistance Programs) 45 CFR (Safeguarding and disclosure of Confidential Information) Current state disaster recovery procedures and guidelines will be revised and updated appropriately to ensure security and business continuity. All MMIS, DSS, and ancillary contractors will be required to comply with these procedures and guidelines. In its Medicaid IT Supplement (MITS v1.0) Enhanced Funding Requirements: Seven Conditions and Standards, CMS issued conditions and standards to be met by states to be eligible for enhanced match funding. As indicated in Exhibit 4-1: CMS Seven Conditions and Standards Compliance Matrix below, the State of Florida Agency for Health Care Administration attests that the project will comply with the CMS Seven Conditions and Standards. # CONDITION NAME AND DESCRIPTION 1 2 Modularity Standard Use a modular, flexible approach to systems development, including the use of open interfaces and exposed application programming interfaces (API); the separation of business rules from core programming; and the availability of business rules in both human and machine-readable formats. MITA Condition Align to and advance increasingly in MITA maturity for business, architecture, and data. Complete and continue to make measurable progress in implementing MITA roadmaps. COMPLIANCE YES NO 17

18 # CONDITION NAME AND DESCRIPTION Industry Standards Condition Ensure alignment with, and incorporation of, industry standards: the Health Insurance Portability and Accountability Act of 1996 (HIPAA) security, privacy, and transaction standards; accessibility standards established under section 508 of the Rehabilitation Act, or standards that provide greater accessibility for individuals with disabilities, and compliance with federal civil rights law; standards adopted by the Secretary under section 1104 of the Affordable Care Act; and standards and protocols adopted by the Secretary under section 1561 of the Affordable Care Act. Leverage Condition Promote sharing, leverage, and reuse of Medicaid technologies and systems within and among states. Business Results Condition Support accurate and timely processing of claims (including claims of eligibility), adjudications, and effective communications with providers, beneficiaries, and the public. Reporting Condition Produce transaction data, reports, and performance information that would contribute to program evaluation, continuous improvement in business operations, and transparency and accountability. Interoperability Condition Ensure seamless coordination and integration with the Exchange (whether run by the state or federal government, and allow interoperability with health information exchanges, public health agencies, human services programs, and community organizations providing outreach and enrollment assistance services. Exhibit 4-1: CMS Seven Conditions and Standards Compliance Matrix COMPLIANCE The Agency plans to use open and competitive procurements for all contracted work related to the design, development, and implementation of enhancements to the FMMIS, and the procurement of the DSS. The procurement process will be in compliance with all applicable federal regulations and provisions as indicated in Exhibit 4-2: Procurement Assurances. YES NO PROCUREMENT STANDARDS 45 CFR Part Procurement Standards 45 CFR Part 92 Uniform Administrative Requirements for Grants and Cooperative Agreements to State, Local, and Tribal Governments SMM Section Required Assurances SMD Letter of 12/04/1995 ACCESS TO RECORDS Letter to State Medicaid Directors regarding the policy on sole source procurements and prior approval requirements for certain procurements. 45 CFR Part Access to Systems and Records SMM Section Required Assurances COMPLIANCE YES NO COMPLIANCE YES NO 18

19 SOFTWARE & OWNERSHIP RIGHTS, FEDERAL LICENSES, INFORMATION SAFEGUARDING, HIPAA COMPLIANCE AND PROGRESS REPORTS 42 CFR Part 431 Safeguarding Information on Applicants and Beneficiaries 42 CFR Part FFP for Design, Development, Installation or Enhancement of (b) (5)-(9) Mechanized Claims Processing and Information Retrieval Systems 45 CFR Part Software and Ownership Rights 45 CFR Part 164 Security and Privacy SMM Section IV&V Required Assurances 45 CFR Part Independent Verification and Validation COMPLIANCE YES NO COMPLIANCE YES NO Exhibit 4-2: Procurement Assurances 19

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