1.5.1-For SAM Post-Sole-Source-Determination-Not-Exceeding-SAT Emergency Medical-Wilderness Training-Redacted_Redacted.pdf
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- Solicitation number
- 70B06C26F00001266
About this file
This is a Sole Source Determination for Actions Not Exceeding the Simplified Acquisition Threshold (SAT), dated September 17, 2026, for the Department of Homeland Security's Office of the Chief Medical Officer on behalf of U.S. Customs and Border Protection (CBP). The procurement is for six five-day Wilderness Upgrade for Medical Professionals training courses to be provided exclusively by the National Outdoor Leadership School (NOLS), located in Lander, Wyoming (Unique Entity ID: WK2SKL9CMXN6, CAGE Code: 1TAX2). The training is designed for licensed healthcare providers employed by CBP, including Medical Doctors, Physician Assistants, Registered Nurses, and Emergency Medical Technicians, to adapt their emergency care skills for use in remote and austere environments. The contract will be structured as Firm-Fixed Unit Price (FFUP) per student, with instructor travel reimbursed separately on a not-to-exceed basis. The 12-month period of performance is funded through the Treasury Asset Forfeiture Fund for Fiscal Year 2026, with funding support sourced from the General Services Administration contract.
The sole source justification is based on NOLS being the only vendor capable of providing the required comprehensive five-day curriculum that meets CBP's operational emergency medical requirements and ACCME accreditation standards. Market research, comparison with prior purchases, and review of published commercial pricing confirmed the fairness and reasonableness of the anticipated pricing. CBP determined that shorter courses or multiple providers cannot deliver the integrated curriculum, consistent instruction, required certifications, and hands-on practical application necessary to ensure personnel can improvise equipment, manage challenging field conditions, and deliver effective emergency care when conventional medical resources are unavailable. The Contracting Officer certified on September 17, 2026, that the procurement circumstances justify the sole source award under RFO Subpart 8.4/GSAR 538.7104-3(a) based on only one source being reasonably available.
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Attachment 1 U.S. Customs and Border Protection
Sole Source Determination For Actions Not Exceeding the SAT
March 2026
Date: _____09/17/2026__ PR Number: 20159350________________
1. Identification of the agency and the contracting activity:
The Department of Homeland Security, Office of the Chief Medical Officer, proposes to enter into a contract on a basis other than full and open competition for emergency wilderness medical training services in support of U.S. Customs and Border Protection medical personnel.
2. Nature and/or description of the item/service being procured and anticipated cost:
The requirement is for six (6) five-day Wilderness Upgrade for Medical Professionals training courses to be provided by the National Outdoor Leadership School (NOLS). The training shall include all instruction, teaching materials, equipment, course supplies, and certifications necessary to deliver the training and certify CBP’s Emergency Medical Personnel.
The course is tailored for licensed healthcare providers employed by CBP, including Medical Doctors (MDs), Physician Assistants (Pas), Registered Nurses (RNs), and Emergency Medical Technicians (EMTs), to adapt their emergency care skills for use in remote and austere environments. The training is required to ensure CBP medical professionals are prepared to improvise equipment, manage challenging field conditions, and deliver effective care when conventional medical resources are unavailable.
The anticipated contract type is Firm-Fixed Unit Price (FFUP) per student for the training.
Instructor travel, if required, will be reimbursed under a separate travel line item on a not-to-exceed basis. The estimated total value for the 12-month period of performance, including training and authorized travel, is $
Contractor:
National Outdoor Leadership School (NOLS) Unique Entity ID: WK2SKL9CMXN6 CAGE Code: 1TAX2 284 Lincoln St Lander, WY 82520-2848
Funding type: Treasury Asset Forfeiture Fund Fiscal Year: FY 2026
3. Authority to award a sole source order:1
1 In this document, citations to RFO Parts 8, 12, 13, and 16 are citations specifically to Federal Acquisition Regulation (FAR) Class Deviation 25-20 for FAR Part 8, FAR Class Deviation 25-21 R1 for FAR Part 12, FAR Class Deviation 26-01 R1 for FAR Part 13, and FAR Class Deviation 26-04 R1 for FAR Part 16, which were issued
Sole Source Determination For Actions Not Exceeding the SAT
March 2026
(Check the authority below based on the procurement procedures being followed)
____X_____ RFO Subpart 8.4/GSAR 538.7104-3(a) _________ RFO 12.102(a) _________ RFO 13.101(b)
________ RFO 16.507-6
4. Sole Source Determination Rationale: (Check one and explain below):
For RFO Subpart 8.4, Part 12 and Part 13 procurements, check one of the following:
____X____ Only one source reasonably available.
_________ Urgent and compelling circumstances exist.
_________ Exclusive licensing agreement exists.
_________ Item peculiar to one manufacturer. If this requirement applies to a portion of the procurement, please identify that portion.
_________ Industrial Mobilization _________ Other. Explain:
For RFO Subpart 16.5 procurements, refer to the exceptions to fair opportunity at RFO 16.507- 6(b) and check one of the following:
_________ The agency need for the supplies or services is so urgent that providing a fair opportunity would result in unacceptable delays.
____X____ Only one awardee is capable of providing the supplies or services required at the level of quality required because the supplies or services ordered are unique or highly specialized.
_________ The order must be issued on a sole-source basis in the interest of economy and efficiency because it is a logical follow-on to an order already issued under the contract, provided that all awardees were given a fair opportunity to be considered for the original order. If the contracting officer uses the logical follow-on exception, the rationale must describe why the relationship between the initial order and the follow-on is logical (e.g., in terms of scope, period of performance, or value).
_________ It is necessary to place an order to satisfy a minimum guarantee.
_________ Item peculiar to one manufacturer. If this justification applies to a portion of the procurement, please identify that portion. For an order in excess of $40,000, CBP as part of the Revolutionary FAR Overhaul (RFO), which was implemented in response to Executive Order 14275, Restoring Common Sense to Federal Procurement, signed April 15, 2025.
Sole Source Determination For Actions Not Exceeding the SAT
March 2026 intends to provide this justification and supporting documentation along with the solicitation to all contract awardees pursuant to RFO 16.507-7(c). (*Rename this document a “Justification for Brand Name Exception to Fair Opportunity” if RFO 16.507-7 applies.)
Explanation of the rationale cited:
Market research indicates that NOLS is the only source capable of providing the required five-day Wilderness Upgrade for Medical Professionals training that meets CBP’s operational emergency medical requirements. The required course must be specifically designed for licensed medical professionals, including MDs, PAs, RNs, and EMTs, and must provide instruction that adapts urban emergency medical skills to remote and austere environments. This course meets accreditation requirements and policies of the Accreditation Council for Continuing Medical Education (ACCME).
CBP requires six (6) sessions of a five-day training format because the curriculum must provide sufficient depth, hands-on instruction, and practical application in wilderness medicine for CBP emergency medical personnel. The training must include in-depth coverage of topics such as patient assessment in remote environments, improvisation of equipment, management of challenging conditions, and delivery of emergency medical care when conventional resources are unavailable. These topics must be integrated into a course that results in required certifications for CBP personnel.
NOLS is the only vendor offering the required five-day course and the certifications that CBP requires.
Shorter courses or combining multiple courses from different providers is not acceptable because these options cannot provide a comprehensive, integrated curriculum and will result in inconsistent instruction, gaps in required competencies, additional logistical burden, and training that does not meet CBP’s mission needs. CBP’s Emergency Medical Personnel must be properly trained and certified or else hey jeopardize the health and safety of other CBP employees and those receiving emergency medical services from CBP employees.
If this requirement is not awarded to NOLS, CBP medical personnel will not receive the specialized preparation needed to provide emergency medical care in remote and austere environments. This will negatively affect CBP’s ability to respond to medical emergencies in the field and increase operational risk to CBP personnel and individuals in CBP custody.
5. The anticipated price will be determined fair and reasonable based on one or more of the price analysis techniques described below. (Check one and provide short explanation or description of action taken):
____X___ Market Research.
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