Indeed the FFM requirements evolved over the two years since award as regulations implementing the Patient Protection and Affordable Care Act were issued by CMS
This is where it gets tricky. With the evolution of the PPACA’s legislative requirements, it is unclear whether the existing IDIQ for Enterprise Systems Development (awarded two years prior to the legislation as annotated above) was appropriate for the work required to build the FFMs.
Nevertheless, when the Task Order Proposal Request was issued to the 16 IDIQ holders in 2011, it should have described the work needed to support or deliver the FFM requirements specified in the PPACA legislation and implementing procedures as interpreted by CMS.
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