National Student Clearinghouse (NSC) Enrollment Verification Services -Non Competitive (Notice Of Intent) Combined Synopsis/Solicitation

Form / Attachment / Pricing Sheet

This document is Attachment J.2, a template for the Contractor/Offeror Conflict of Interest (COI) Submission. It is provided in accordance with Solicitation/Contract Section H.1 and requires bidders to submit specific information regarding organizational and personal conflicts of interest.

• Organizational Structure: Requires high-level and internal organization charts, including parent and affiliated organizations, with a narrative explanation.
• Actual, Potential, and/or Apparent COIs and Financial Interests/Relationships: Requires disclosure of:
  • COI Oversight Process: Description of how the contractor identifies and resolves COIs.
  • Disclosure of Contracts: Details of current/active and known future non-foreign contracts that may pose a COI, including prime/subcontractor status, customer, contract number, period of performance, total value, type of COI (Actual, Potential, Apparent), and specific COI type (UA, BG, IO).
  • Financial Interests/Relationships: Disclosure of organizational financial interests that cause a COI, including the entity, COI type, and explanation.
  • COI Mitigation: A proposed plan for each identified COI, including description, rationale, mitigation strategy, resolution timeframe, and monitoring plan.
• Personal Conflicts of Interest (PCI): Requires analysis of PCIs for governing body members, principals, managers, and key personnel. Specific financial disclosure details (assets, income, liabilities, reimbursements/gifts) are to be considered but not disclosed to the Government. Mitigation plans for identified PCIs should be provided as per section B.4, omitting individual names.
• Subcontractors: Prime contractors must analyze subcontractor COI submissions, ensuring they meet criteria, have mitigated COIs, and provide an analysis of their mitigation strategies.

Bidders must complete and submit this template (or an equivalent) with their proposal to demonstrate compliance with conflict of interest requirements as outlined in Section H.1. Failure to provide the required information may impact proposal evaluation. A response is required even if no conflict exists.

Solicitation / RFP / RFQ

This is a combined synopsis/solicitation for commercial products or services, prepared in accordance with FAR subpart 12.6. The Centers for Medicare & Medicaid Services (CMS) intends to award a firm-fixed-price delivery order on a sole source basis to National Student Clearinghouse for access to authoritative educational enrollment verification data. This data is required to support Medicaid eligibility and program compliance verification. The procurement is conducted under the authority of 10 U.S.C. 3204(a)(1) or 41 U.S.C. 3304(a)(1), citing "Only one responsible source and no other supplies or services will satisfy agency requirements."

• Access to authoritative educational enrollment verification data via the National Student Clearinghouse (NSC).

• Support for Medicaid eligibility and program compliance verification.

• Compliance with information security standards (FISMA, FedRAMP, HHS policies).

• Requirements for data handling, processing, storing, transporting, and hosting federal information and Personally Identifiable Information (PII).

• Specific requirements for cloud services, including FedRAMP authorization and data jurisdiction.

• Supply chain risk management for ICT cybersecurity, including prohibitions on certain telecommunications equipment.

• Compliance with Section 508 of the Rehabilitation Act for information and communication technology.

• Mandatory Records Management training for contractor employees.

• Requirements for obtaining and managing CMS identification (ID) cards, including background investigations.

• Provisions to prevent and manage organizational and personal conflicts of interest.

• HIPAA Business Associate Clause for handling Protected Health Information (PHI).

• Offerors must submit a Performance Work Statement (PWS).

• Contract Type: Firm-fixed-price delivery order.

• Period of Performance: One base year and two option years.

  • Base Period: May 14, 2026 - May 13, 2027
  • Option Period 1: May 14, 2027 - May 13, 2028
  • Option Period 2: May 14, 2028 - May 13, 2029

• NAICS Code: 541512

• Defense Priorities and Allocations System (DPAS) is not applicable.

• Proposals/quotes must be submitted electronically no later than May 4, 2026, at 10:00 AM EST.

• Submission Address: Aaron.Blackshire@cms.hhs.gov

• Offerors' initial proposals should contain their best terms from a price and technical standpoint.

• The Government reserves the right to conduct exchanges with offerors.

• Questions concerning the solicitation should be submitted via email to Aaron.Blackshire@cms.hhs.gov.

• Offerors must demonstrate understanding of requirements, including technical approach, API integration, data access, onboarding methodology, SLAs, and risks/mitigation.

• Specific representations regarding telecommunications and video surveillance equipment (52.204-24, 52.204-26) and Federal Acquisition Supply Chain Security Act Orders (52.204-29) are required.

• Offerors must complete FAR 52.212-3, "Offeror Representations and Certifications—Commercial Products and Commercial Services," accurately and completely.

• This acquisition is unrestricted.

• No set-aside restrictions are noted.

• The "Offeror Representations and Certifications" provision is crucial for determining eligibility, especially for socioeconomic program requirements.

• The solicitation incorporates by reference FAR 52.212-1, 52.212-4, and 52.212-5.

• Issuance of this solicitation is contingent upon the availability of appropriated funds.

• CMS is not committed to reimburse any costs associated with proposal preparation or submission.

• All responsible sources may submit a capability statement, proposal, or quotation.

• Many representations can be completed electronically via SAM.gov.

Statement of Objectives (SOO)

This Statement of Objectives (SOO) outlines the Centers for Medicare & Medicaid Services (CMS) requirement to integrate National Student Clearinghouse (NSC) enrollment verification services into CMS's API-based ecosystem. The goal is to enable state benefit agencies to securely verify education participation status for applicants and beneficiaries, supporting Medicaid eligibility and program compliance.

• Core Functionality: Provide authoritative educational enrollment verification data for high school, high school equivalent programs, and postsecondary institutions via CMS API platform.
• Data Attributes: Verification data may include School Name, Enrollment Status, Term Dates, Program Graduation Date, and Student Name.
• Integration: Support secure data exchange with CMS API-enabled platforms.
• Reporting: Provide API Access/Integration Documentation, Integration Support Materials, Status Reports, Technical Briefings, Monthly Usage Reports, Weekly Usage Reports, and Monthly Financial Reports.
• Performance: Achieve system availability of at least 99.5% uptime, measured monthly, with defined response times for API requests and incident resolution.

Includes a base period and option periods, with a priority for integration readiness by June 1, 2026, to meet the HR1 effective date of January 2027.

Remote, through secure electronic means. No physical place of performance is required.

• Compliance: Must adhere to federal privacy, security, and education data requirements, including PII protection, FERPA, NIST standards, and cybersecurity controls.
• Extensibility: Integration architecture should allow for future expansion to additional federal benefit programs.
• Cost-Effectiveness: Provide pricing structures to enable centralized agreements for states, reducing individual state burden.
• HR1 Readiness: Prioritize activities to ensure states can operationalize enrollment verification workflows before the January 2027 deadline.

Verification of enrollment at international institutions not participating in NSC data sharing.