Pathology Reference Lab Spokane VA Medcial Center
OFOC SOP Revision 08 Page 2 of 3 Original Date: 03/22/11 Revision 08 Date: 04/18/2018 DEPARTMENT OF VETERANS AFFAIRS Justification and Approval (J & A) For Other Than Full and Open Competition (>SAT) Acquisition Plan Action ID: 36C260-18-AP-2189 Contracting Activity: Department of Veterans Affairs, Network Contracting Office (NCO) VISN 20, The Mann Grandstaff VAMC. Laboratory Purchase Request 668-19-1-139-0009. Nature and/or Description of the Action Being Processed: The proposed contract is for an Open Market single year, firm fixed price contract with estimated quantities to Incyte Pathology, P.S.. The contract is for a Pathology Reference Laboratory Services contract for The Mann Grandstaff VAMC located in Spokane, Washington. The estimated total contract value is $325,000.00. Description of Supplies/Services Required to Meet the Agency s Needs: The proposed action is to provide The Mann Grandstaff VAMC with reference lab services. This requirement for lab services is to include the performance of analytical testing and surgical pathology testing as defined by the Laboratory s reference test manual, the reporting of analytical test results and consultative services are required assimilating the full scope of its laboratory operations to The Mann Granstaff VAMC. The reference Lab must also provide requisition forms, reference ranges, specimen requirements, and an interconnection for data exchange between Vista and the reference lab s Electronic Data Interchange (EDI) system. The Reference Lab shall provide in accordance with all applicable federal, state, and local regulations, laws, and ordinances, and in accordance with the specifications outlined for accreditation certification, patient specimen testing for the specific range of referral testing within their capability. The contract for Reference Lab Services is on an as-needed basis for the Lab Department. The Joint Commission on the Accreditation of Healthcare Organizations (JHACO) requires that reference lab s be certified; VHA labs do not perform this type of lab testing. Statutory Authority Permitting Other than Full and Open Competition: ( X ) (1) Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements per FAR 6.302-1; ( ) (2) Unusual and Compelling Urgency per FAR 6.302-2; ( ) (3) Industrial Mobilization, Engineering, Developmental or Research Capability or Expert Services per FAR 6.302-3; ( ) (4) International Agreement per FAR 6.302-4 ( ) (5) Authorized or Required by Statute FAR 6.302-5; ( ) (6) National Security per FAR 6.302-6; ( ) (7) Public Interest per FAR 6.302-7; Demonstration that the Contractor s Unique Qualifications or Nature of the Acquisition Requires the Use of the Authority Cited Above (applicability of authority): The requirement is to provide The Mann Grandstaff VAMC with reference lab testing with standard case turnaround time of no more than two (2) days. Current Turn-around-Times (TAT) with current BPA holders have not been meet, which put Veteran care at risk. Incyte a local Laboratory Vendor to the area is available to perform the services based on the following. The pickup and processing of specimens collected by the VA within the required turnaround times specific in the statement of work requires a local laboratory presence. Mailing specimens to national laboratories would cause the turnaround time to exceed the Government s minimum requirement and negative impact patients diagnosis and treatment. In order to provide fair opportunity among other potential vendors with a similar TAT, the VA needs to allow time for electronic interface to be established between the VA s Vista system and its own EDI system to deliver lab orders to the reference lab and to deliver results to the VA. This interconnection must be approved by VA IT security and refences ranges loaded into the system. This is a VA administrative burden that will take a minimum of six (6) months to complete for any vendor. Attempting to use a Lab contractor without this task completed would require each test to be manually entered into the vendors system, allowing for the potential for human error and resulting in an unacceptable level of risk to VA patient care. Description of Efforts Made to ensure that offers are solicited from as many potential sources as deemed practicable: Market research was conducted by the Contracting Officer Representative (COR) between May 16th and June 7th 2018. Only one local vendor was noted to be able to meet the minimum requirements. One vendor had signed a non-compete clause with our current contracted vendor. NCO20 has multiple award BPA for refence laboratory testing. However, none of the current BPA holders are able to meet the turnaround requirements for results as their laboratory test processing strategy is to require the specimens to be collected by VA and mailed to the processing location, causing unacceptable delays to the processing time. The incumbent, has been found to not meet the required TAT for this Lab. Determination by the CO that the Anticipated Cost to the Government will be Fair and Reasonable: The Contracting Officer (CO) will use historical pricing, including a comparison of prices paid in other geographical locations under competitive acquisition procedures to determine the unit prices fair and reasonable. Description of the Market Research Conducted and the Results, or a Statement of the Reasons Market Research Was Not Conducted: Extensive market research was conducted included searching; VetBiz, SBA, FPDS, SAM. For a similar requirement for VA Puget Sound Health Care System a sources sought was sent to SDVOSB/VOSB vendors under NAICS code 621511 on 8/30/2018. Two vendors reported interest in that they could provide services. However, neither were loaded into the Vista system. No other positive results were discovered. Any Other Facts Supporting the Use of Other than Full and Open Competition: N/A Listing of Sources that Expressed, in Writing, an Interest in the Acquisition: N/A A Statement of the Actions, if any, the Agency May Take to Remove or Overcome any Barriers to Competition before Making subsequent acquisitions for the supplies or services required: The primary barrier to provide fair opportunity among other potential vendors with a similar TAT, the VA needs to allow time for electronic interface to be established between the VA s Vista system and its own EDI system to deliver lab orders to the reference lab and to deliver results to the VA. Future requirements with a longer lead time may allow potential vendors to gain entry into competition. Longer lead time should allow for greater entry of all MATOC holders for the future long term contract. This J & A will be published to FBO after award to notify future potential vendors of the required electronic interface to be established between the VA s Vista system and its own EDI system. Requirements Certification: I certify that the requirement outlined in this justification is a Bona Fide Need of the Department of Veterans Affairs and that the supporting data under my cognizance, which are included in the justification, are accurate and complete to the best of my knowledge and belief. _____________________________ ________________________ Name: Jeanie Thompson Date Title: Laboratory Manager Facility: Mann Grandstaff VAMC Approvals in accordance with the VHAPM Part 806.3 OFOC SOP: Contracting Officer or Designee s Certification (required): I certify that the foregoing justification is accurate and complete to the best of my knowledge and belief. _____________________________ ________________________ Name: Karen Dailey Date Title: Branch Chief, Services 2 Facility: Network Contracting Office 20 (NCO 20) One Level Above the Contracting Officer (Required over SAT but not exceeding $700K): I certify the justification meets requirements for other than full and open competition. _____________________________ ________________________ Name: Jonathan Jewel Date Title: Acting Chief, Division I Facility: Network Contracting Office 20 (NCO 20). 36C26019P0330 Department of Veterans Affairs Veterans Health Administration Veterans Integrated Service Network 20
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