Modification to Marketplace System Integrator (MSI) Contract

The MSI contractor provides Information Technology (IT) operational support and supports CMS with oversight of the Exchange systems' components through monitoring, coordination, collaboration, and communication in coordination with the eXchange Operations Center (XOC), business stakeholders, security, and program operations through the scope of the MSI task order. It also includes integration work for the Marketplace Exchange, which supports healthcare provided by Affordable Care Act (ACA).
The Consolidated Appropriations Act (CAA, the Act) of 2021 became Public Law No: 116-260 on December 27, 2020. CAA is a $1.4 trillion omnibus spending agreement that encompasses many different provisions. Two acts within the law apply to CMS' Center for Consumer Information and Insurance Oversight (CCIIO): Division BB, Title I, "No Surprises Act"; and Title II, "Transparency." These two provisions require work to support healthcare provided to all commercially insured patients that provides much broader coverage and Information Technology (IT) needs than just healthcare obtained through the health insurance exchanges. The Act contains a large number of disparate requirements for insurance reporting, process attestation, and federal operations which are undergoing regulatory development.

In 2021, CMS lacked sufficient information regarding how MSI would be responsible for integrating the IT supporting the CAA. CMS determined that adding CAA related work to the MSI order was necessary to help CMS meet the implementation dates set in the CAA. Since this was determined as out of scope, CMS executed a Justification and Approval (J&A) on September 3, 2021 approving the addition of the CAA work to Option Period I and II of the order. Previously, CMS stated the CAA has a number of provisions which are going through regulatory development, and the process of discovery has uncovered additional system integration which makes it more difficult to separate the system integration needs of the CAA from the ACA at this time. CMS
continues to identify significant overlaps regarding the integration support MSI provides to CAA and Marketplace Exchange, and the CAA ruling is now understood to be an amendment to the ACA provisions that govern CCIIO's systems. CMS believes these overlaps will persist for the remainder the MSI order. CMS now understands there are many interdependencies and mutual effects between the CAA and ACA and Marketplace work. CMS desires to roll the CAA work into the overall Marketplace services integration for the remainder of the task order.