2.05 - JA - STR - redacted_Redacted.pdf

J&A 22-026

SOLE SOURCE JUSTIFICATION

1. Identification of Agency and Contracting Activity.

The requiring activity is the Bureau of Medicine and Surgery, Falls Church, VA; the contracting activity is NAVSUP Fleet Logistics Center (FLC) Norfolk, Contracting Dept., Philadelphia Office, 700 Robbins Ave, Bldg.

2B, Philadelphia, PA.

2. Description of the Action Being Approved.

This is a sole source action for the provision of Digitalization of Service Treatment Record (STR) services that are currently performed under Purchase Order N0018921PZ118. This firm, fixed-price order for commercial services was awarded on a sole source basis to Anacomp, Inc., a small business. This order was a follow on to N0018916CZ025, which was also awarded to Anacomp, Inc on 18 February 2016. This contract was anticipated to be competitive; however, while multiple proposals were received under that solicitation, Anacomp was ultimately determined to be the only offeror capable of providing the requisite facilities, equipment, personnel, expertise and capacity.

The existing order expires on 28 February 2022. The instant requirement will serve as a follow-on to the above referenced purchase order. This is a sole source action, which is anticipated to be awarded as a one-year firm fixed-price contract with one (1) 12-month option period consecutively following the base period.

The purpose of this action is to provide continued digitalization support in support of the Naval Medical Records Activity, located in St. Louis, Missouri while the future state of STR digitization services remains under review due to the ongoing DHA transition and relocation of the St. Louis Program Management Office.

3. Description of Services.

This follow-on requirement will serve as a continuation of the services provided under N0018921PZ118; it will provide for the receiving, inventory, processing, tracking, and final disposition of medical records, dental records, and loose medical treatment documentation for Navy Service Members (SMs) who have separated or retired from the Total Force (i.e. Active Duty, Reserve, and separating members with a remaining Inactive Service Obligation).

Under the follow-on requirement, the contractor will continue to be responsible for providing conversion, and programmatic Support Services for the Department of the Navy Bureau of Medicine and Surgery (BUMED) in support of an estimated maximum total of 50,000 Service Treatment Records annually or 8,500,000 deliverable scanned STR images per year. The contractor will provide technical and administrative services to receive and process incoming Service Treatment Records (STRs) for members who have separated or retired from Active Duty, and separating members with a remaining Inactive Service Obligation. The contractor shall provide conversion services of paper STRs (Medical, Dental, ALHTA Web Print (AWP), and DD-2963 processing) and loose medical documentation); document preparation to include validation of scanning, indexing, reassembly of folders, and confirmation of delivery of images in a searchable electronic format to the HAIMS repository system; and program level support services. This includes scanning and uploading all received records and all loose flowing documents.

The contractor is required to have a secure database structure. It must ensure technical implementation to handle the volume of the records; it must also ensure all software and technical support complies with applicable regulations and requirements. This includes creating a secure database structure to facilitate reporting of scanning utilization volume by Unit Identification Code (UIC) compliant with DoD guidance, instructions, and directives that are aligned with the required directives. The provision of the required services will result in access to Personally Identifiable Information (PII)/Protected Health Information (PHI). The contractor must ensure the AWP report and STR are digitized and uploaded in accordance with AWP User Guide and DoD “HAIMS INTERIM GUDIANCE – STR,” document dated 07/24/2013.

While some of the program level support services are provided onsite at Navy Medicine Record Activity (NMRA) satellite Program Management Office facility, the Government facility was determined to be insufficient to support the magnitude of the STR records that need to be processed and stored; therefore, since 2014, the PWS has required that the majority of the STR services be performed at a contractor operated facility within a 30 mile radius of BUMED’s NMRA satellite Program Management Office (PMO) in St. Louis, MO. Services must be performed within this vicinity in efforts to facilitate the receipt and outgoing shipment of the paper records before and after scanning.

The estimated total value of this action is . The resultant contract will be funded with FY22 Navy Operations & Maintenance (O&MN) appropriations. These funds are currently available. The option will be funded utilizing appropriations O&MN appropriations of the fiscal year in which the option year is exercised.

4. Statutory Authority Permitting Other Than Full and Open Competition.

The statutory authority permitting this sole source action is 41 U.S.C. 1901, Simplified acquisition procedures - a sole source acquisition using simplified acquisition procedures for the acquisition of commercial items, as implemented by FAR 13.501(a).

5. Rationale Justifying Use of Cited Statutory Authority.

The proposed requirement is to issue a 12-month contract with one (1) 12-month option period consecutively following the base period on a sole source basis to Anacomp, Inc., a small business, which is currently providing the services under purchase order N0018921PZ118. It is anticipated that Anacomp will continue to provide the STR support services described above for the period of 01 March 2022 through 28 February 2024, if the option is exercised.

The current purchase order was issued with only a 12-month period of performance in anticipation of Navy Medicine moving the NMRA office due to the anticipated closure of the current Government facility by the General Services Administration (GSA) due to environmental concerns in FY22. However, it has been determined that the offices will be relocated to the federal building in downtown St. Louis. Also, Navy Medicine is continuously reviewing its STR requirements to align with the other services and Defense Health Agency (DHA) standards and is anticipating aligning the Navy’s STR process and location to that of the other agencies in the coming fiscal years.

At the moment, Anacomp is the only known company within the required vicinity that is capable of providing these services.

Through market research, including a sources sought and review of the prior procurement history, there are no known companies with the requisite facilities, equipment, personnel, expertise and capacity capable of providing these services within the 30 mile radius of the NMRA PMO. The contractor performing these services is required to create a secure database structure to facilitate reporting of scanning utilization volume by UIC and in compliance with DoD guidance, instructions, and directives that are aligned with the required directives. The provision of the required services will result in access to PII/PHI. Any facility utilized by the contractor must be National Archives and Records Administrative (NARA) compliant. In addition, the software program must align with OSD security requirements. Anacomp Inc. complies with all of the above-referenced directives and facility requirements.

Anacomp, Inc. maintains the required Interconnection Security Agreement (ISA) between DHA Information Operations (J-6) and U. S. Navy BUMED concerning Healthcare Artifact and Information Management Solution (HAIMS) and Navy Publishing. Anacomp, Inc. also possesses the required Authorization to Operate (ATO). Anacomp, Inc. is located in a secured, standalone building that has a warehouse that is NARA compliant.

The Anacomp Inc. facility is located in the required 30-mile radius of the NMRA PMO. Anacomp, Inc. employees under this contract already possess the required access to PII or PHA with the required IT-II public trust level of responsibility and trustworthiness.

Finally, although market research and procurement history demonstrate that Anacomp Inc. is the only company capable of fulfilling the Government’s needs, even if another company were capable, the amount of time and resources required to ensure compliance with the relevant directives and facilities requirements would result in a significant increase in cost to the Government.

6. Description of Efforts Made to Solicit Offers from as Many Offerors as Practicable, including a

Description of Market Research, if applicable, and a List of Interested Sources, if any.

A sources sought was posted to the Government-wide point of entry. A total of five (5) prospective small business quoters responded. BUMED reviewed all provided information to ascertain whether any of the respondents were capable of meeting the Government’s minimum need for this procurement. Based on that review, a determination was made that none of the respondents possessed the technical capability, specifically a NARA compliant building within the previously stated radius, to perform the required tasks and meet the Government’s minimum need.

Therefore, market research indicates that Anacomp is the only vendor capable of meeting the requirements.

However, one of the respondents stated that while they do not have a NARA compliant facility available currently, they should have one completed by December 2022. Therefore, it is anticipated that a competitive acquisition may be processed for the follow-on to this requirement.

7. Determination of Fair and Reasonable Cost.

The Contracting Officer has determined that the anticipated cost to the Government of the services will be fair and reasonable.

8. Actions to Remove Barriers to Future Competition.

Competition of this requirement may be possible in the future. As discussed in paragraph 5, there may be a vendor within the 30-mile radius of the PMO office in St. Louis capable of performing the requirements after December 2022. In accordance with DFARS 206.303-2(b)(i) and PGI 206.304(a)(S-70)), a sources sought notice was issued on 03 December 2021. The results of the sources sought notice are addressed in Section 6.

In addition, and IAW DFARS 213.501(a)(i), a copy of the previous justification was included in the review package to assist the approval authority in determining whether the planned actions to remove any barriers to competition cited on the previous justification were completed. The circumstances requiring the acquisition being conducted pursuant to FAR 13.501(a) remain unchanged. Any subsequent follow-on requirements will be handled on a case-by-case basis. Market Research will be conducted for any future requirements to determine if there are any potential sources for competition.

9. Contracting Point of Contact

The point of contact at NAVSUP Fleet Logistics Center Norfolk, Contracting Department, Philadelphia Office is Ms. Helen Tyson, Code 270.1A who can be contacted by telephone at (215) 697-9653 or by email at helen.m.tyson.civ@us navy mil.