PNAP v. PA DOS

CourtCommonwealth Court of Pennsylvania
DecidedJune 16, 2025
Docket1450 C.D. 2023
StatusUnpublished

This text of PNAP v. PA DOS (PNAP v. PA DOS) is published on Counsel Stack Legal Research, covering Commonwealth Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
PNAP v. PA DOS, (Pa. Ct. App. 2025).

Opinion

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

Pennsylvania Nurse Peer Assistance : Program, : Petitioner : : v. : No. 1450 C.D. 2023 : Submitted: May 6, 2025 Pennsylvania Department of State, : Respondent :

BEFORE: HONORABLE RENÉE COHN JUBELIRER, President Judge HONORABLE PATRICIA A. McCULLOUGH, Judge HONORABLE ANNE E. COVEY, Judge

OPINION NOT REPORTED

MEMORANDUM OPINION BY PRESIDENT JUDGE COHN JUBELIRER FILED: June 16, 2025

Pennsylvania Nurse Peer Assistance Program (PNAP) petitions for review of a Final Determination by the Secretary of the Commonwealth (Secretary) denying PNAP’s bid protest. PNAP argues it was error to conclude the bid protest was untimely and to award the subject contract to the Foundation of the Pennsylvania Medical Society (Foundation). Upon review, we affirm. I. BACKGROUND On May 4, 2023, the Pennsylvania Department of State (Department) released a Request for Proposal (RFP) for the Nurse Peer Assistance Monitoring Program. (Reproduced Record (R.R.) at 42a.) The objective of the RFP was to obtain “the services of a contractor who is qualified, experienced, credible, unbiased and able to administer all aspects of a peer monitoring program [] to Pennsylvania licensed nurses, licensed dietitian-nutritionists, temporary practice permit holders or licensure candidates.” (Id. at 107a.) The nature and scope of the project further stated the Department was “seeking proposals from contractors who are qualified to provide peer assistance services to impaired healthcare professions,” and this particular RFP was “in relation to the licensees under the State Board of Nursing.” (Id. at 109a.) The RFP defined “[p]eer assistance program” as “a program whereby members of a particular profession suffering from a physical or mental impairment, such as substance abuse or dependency, which may interfere with their job performance can obtain assistance, support, monitoring, prevention and intervention services from members of their own profession.” (Id. at 108a.) The RFP set forth various qualifications, including that “[t]he contractor [] have specialized knowledge and experience in providing peer assistance and monitoring services to health care professionals” and “a working knowledge of the Professional Nursing Law, [Act of May 22, 1951, P.L. 317, as amended,] 63 P.S. §§ 211-225.5, and the Practical Nurs[e] Law, [Act of March 2, 1956, P.L. (1955) 1211, as amended,] 63 P.S. §§ 651-667.8.” (Id. at 110a.) In addition, there were certain staffing requirements, such as the “contractor’s proposed staff shall include at least one individual with . . . [a]n active Pennsylvania nursing license.” (Id. at 110a-11a.) Contractors were also to have “experience in peer monitoring program to licensed health care professionals,” among other things. (Id. at 111a.) Among the listed tasks was a requirement that the contractor “attempt to develop a statewide network of peer monitors in an effort to assign each participant enrolled in the program to a peer assistance monitor, preferably who is a licensed PA nurse.” (Id. at 116a.)

2 Questions related to the RFP were accepted until May 18, 2023. (Id. at 42a.) PNAP submitted questions seeking clarification as to cost submittal. (Id. at 105a.) The RFP was scheduled to close June 7, 2023. (Id. at 42a.) PNAP and the Foundation, along with one other entity, submitted proposals. (Id. at 470a.) The Foundation was recommended for selection, and on August 9, 2023, a Notice of Award was sent to the Foundation. (Id. at 468a, 473a.) PNAP was sent a Notice of Non-Award on October 20, 2023. (Id. at 475a.) On October 26, 2023, PNAP filed its bid protest. (R.R. at 2a-35a.) Therein, PNAP asserted the following:

Based upon reasonable belief, this RFP was improperly awarded to [the Foundation] based upon (1) fraud and collusion between the [Foundation] and government entities or persons, possibly the [Professional Health Monitoring Program (]PHMP[)] itself, and (2) a scoring system that rewarded the [Foundation] for agreeing to monitor nurses who receive medication assistance therapy (MAT) in violation of the Americans with Disabilities Act (ADA)[, 42 U.S.C. §§ 12101- 12213]. We contend that the contract was inappropriately awarded to a non-nursing organization. We believe that the competitor was given proprietary information and given prompts to answer the RFP in the expected manner that would increase [its] score and give [it] an unfair advantage over PNAP. We believe that sections of the RFP were changed to specifically meet the qualifications of the competitor. We also contend that sections of the RFP that were answered appropriately by our agency were scored in such a way that would require our agency to act in violation of the ADA should we have been awarded the contract.

We believe that the contract was awarded fraudulently, and that the committee was not given all the necessary facts to make an informed decision. We also contend that our organization was set up to answer questions from the proposal inappropriately. We assert the proposal was specifically written with the new organization in mind. . . .

3 (Id. at 2a.) PNAP proceeded to go into detail as to why it alleged fraud and collusion, such as changes in the language of this RFP for “healthcare professionals” from prior ones that specified nurses and the Foundation’s knowledge since August of the award. (Id. at 2a-3a.) PNAP then explained in detail why it believed the scoring system “rewarded” the Foundation agreeing to monitor nurses in MAT, which it alleged violated the ADA. (Id. at 4a-5a.) PNAP, which provided these services since 2009, stated it is an agency “managed by nurses, for nurses,” and “[n]urses need extensive guidance and compassionate care from individuals well versed in the nursing profession to navigate the monitoring program and be successful in their recovery efforts,” which was “unlikely to occur with an agency used to dealing with physicians which is willing to violate the ADA in order to receive the nurse monitoring contract.” (Id. at 5a.) On November 6, 2023, the Foundation responded to the bid protest. It first argued PNAP’s bid protest challenging the phrasing of the RFP was untimely, having been filed almost five months after the close date. (Id. at 477a.) The Foundation also argued PNAP’s bid protest challenging the Foundation’s selection was untimely. (Id. at 478a.) According to the Foundation, it was publicly announced that the Foundation was selected for contract negotiations on August 2, 2023, which PNAP recognized, but PNAP did not file its bid protest until October 2023. (Id. at 478a-79a.) Next, the Foundation argued the bid protest was meritless, stating PNAP’s claims of fraud and collusion are unsupported by any evidence and were “bare accusations.” (Id. at 480a-81a.) Moreover, the Foundation argued the facts asserted in the bid protest were not accurate. (Id. at 481a-83a.) On November 9, 2023, the Department also responded to the bid protest. First, the Department asserted the bid protest, to the extent it challenged the contents

4 of the RFP and the scoring system, was untimely as it should have been filed before the RFP closed. (Id. at 37a.) The Department further asserted the entire bid protest was untimely on the basis PNAP alleged it learned that the Foundation was awarded this contract at the same time it was awarded a similar contract for pharmacists in August 2023. (Id. at 37a-38a.) Notwithstanding the timeliness of the bid protest, the Department alleged the bid protest was without merit. It denied the RFP was modified to favor any vendor and instead was aimed at soliciting the best proposals from any entity that could provide the requested services, “not limit what types of organizations could apply.” (Id. at 38a.) The Department stated:

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Bluebook (online)
PNAP v. PA DOS, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pnap-v-pa-dos-pacommwct-2025.