2020.09.14 DMLSS-W FY20 Product Data Subscription JA_responses_DMLSS-W (002).docx -CA 9 17_DMLSS- FINAL for redact_Redacted.pdf

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DDEFENSE LOGISTICS AGENCY

DLA CONTRACTING SERVICES OFFICE - PHILADELPHIA

700 ROBBINS AVENUE

PHILADELPHIA, PENNSYLVANIA 19111-5092

JUSTIFICATION AND APPROVAL

FOR OTHER THAN FULL AND OPEN COMPETITION

Upon the basis of the following justification, I hereby approve the issuance of the contractual action described below using other than full and open competition, pursuant to the authority cited herein.

1. IDENTIFICATION OF THE AGENCY AND CONTRACTING ACTIVITY.

Agency Requiring Activity Defense Logistics Agency (DLA) Medical Directorate 700 Robbins Avenue Philadelphia, PA 19111

Contracting Activity DLA Contracting Services Office at Philadelphia (DCSO-P) 700 Robbins Avenue Philadelphia, PA 19111

2. NATURE AND/OR DESCRIPTION OF THE ACTION BEING APPROVED.

Pursuant to 10 U.S.C. 2304(c)(1) and Federal Acquisition Regulation (FAR) 6.302- 1(a)(2)(iii)(A), this justification for other than full and open competition authorizes and approves the procurement of a sole-source/brand-name medical/surgical product data subscription necessary to improve quality of product data to support authoritative product, pricing and sourcing capabilities presenting customers with opportunities for cost savings.

The required subscription is the Global Healthcare Exchange (GHX) Product Data Subscription for a period of 12 months plus two 12-month option terms under a Firm Fixed Price contract.

SOURCE SELECTION INFORMATION – SEE 2.101 AND 3.104

Justification and Approval for Other than Full and Open Competition Title of Acquisition

3. DESCRIPTION OF THE SUPPLIES OR SERVICES REQUIRED TO MEET

THE AGENCY’S NEEDS (INCLUDING THE ESTIMATED VALUE).

The DLA Troop Support Medical Directorate has a requirement to renew its GHX Product Data Subscription to provide medical/surgical product data which is necessary for the DMLSS-W suite of information technology (IT) applications in support of Defense Medical Logistics Enterprise System- Defense Logistics Agency (DMLES- DLA) operations and support.

The estimated dollar value for this procurement is $ and includes a base year data subscription with two 12-month option terms.

Contract Year Period of Performance Contract Cost

Base Year 09/30/2020 - 09/29/2021

Option Year 1 09/30/2021 - 09/29/2022

Option Year 2 09/30/2022 - 09/29/2023

Total

4. IDENTIFICATION OF THE STATUTORY AUTHORITY PERMITTING

OTHER THAN FULL AND OPEN COMPETITION.

The statutory authorities permitting other than full and open competition are 10 U.S.C.

2304(c)(1) and FAR 6.302-1(a)(2)(iii)(A). The supplies or services required by the requiring agency are available from only one or a limited number of responsible sources, and no other type of supplies or services will satisfy agency requirements. The services required are deemed to be available only from the original source in the case of this follow-on medical/surgical product data subscription contract for the continued provision of highly specialized data feeds based on unique processes and rules highlighted in Section 5 below. An award to any other source will result in substantial duplication of cost to the Government that cannot be expected to be recovered through competition due to higher reprogramming labor costs, as well as the potential for higher data subscription costs.

5. DEMONSTRATION THAT THE PROPOSED CONTRACTOR’S UNIQUE

QUALIFICATIONS OR THE NATURE OF THE ACQUISITION REQUIRES

USE OF THE AUTHORITY CITED.

The DLA Troop Support Medical Directorate requires the ability to procure standardized product data in the medical supply chain to improve the quality of data in the DMLES- DLA medical master item system.

The GHX Product Data Subscription is uniquely qualified to satisfy the specialized aspects of this requirement by providing a monthly data feed that can be aggregated, clinically vetted, and synchronized while including the following medical/surgical product data attributes:

Item Classification: The government requires all items to be classified using industry standard classification schema, such as United Nations Standard Products and Services Code® (UNSPSC®). UNSPSC codes need to be validated by data provider and applied to all items sourced by the data provider. Appropriate data governance structure should be in place to ensure consistency of classification.

Billing Codes: The government requires all items to be coded with Healthcare Common Procedure Coding System (HPCPS) codes, as defined by the Centers for Medicare and Medicaid Services (CMS). HCPCS codes need to be applied and validated by the data provider in accordance with regulatory guidelines.

Item Attribution: The government requires key items characteristics, which should include at minimum those listed below. These attributes should be validated against available product literature, i.e. Instructions for Use (IFU), product data, and manufacturer supplied information:

o Noun, Type, Brand name, Composition, Age, Size/Shape, Length/Width/Height, Diameter, Volume, Weight, Properties, Sterility, Latex/Non-Latex, Disposable, Color, Flavor, Hazardous.

Normalized Ordering Information: The government requires validated and normalized core ordering/product information, including vendor name (standardized/normalized), vendor catalog number, manufacturer name (standardized/normalized), and manufacturer item number. Validated unit of measure information (UOM) and pack factor should also be included.

Configurable Item Description: The government requires up to 10 descriptions using a rules-based algorithm that leverages product attributes (as described above) but allows for customization of description length, attribute order, and abbreviations. Descriptions need to be consistent and normalized to ensure like items are described similarly.

Global Data Synchronization Network (GDSN): The government requires source product data from a GDSN-certified data pool on behalf of the DoD, including the key attributes listed below, and correlate it to the product data and information described herein. The GDSN sourced data must be correlated to the correct logical descriptive UOM.

The above Medical/Surgical Data Subscription attributes are necessary to improve quality of product data in the Defense Medical Logistics-Enterprise Solution (DML-ES) to support authoritative product, pricing and sourcing capabilities presenting customers with opportunities for cost savings and to support the Department of Defense (DoD) Electronic Health Record (EHR) system that will provide the mandated integrated medical and dental record that connects patient information across Garrison and Theatre environments. This enriched and more extensive set of data will also promote DLA’s Better Buying Power (BBP) 3.0 goals for technical excellence and quality products to provide our warfighters with superior capabilities.

Other data subscriptions are available, but the fields and formats of these alternate data subscription are substantially different from those currently in use, and therefore would require significant analyst and developer labor costs for feasibility analysis, redesign, and recoding of current system logic and change management processes. In essence, the government would have to reengineer existing logic, design and processes to accommodate a different data feed. Having already implemented schemas and platforms to support GHX data feeds, this reengineering would be a substantially prohibitive effort in our mission to uniquely identify and catalog each medical item in our system and avoid clinically different items to appear as equivalents in our system.

6. DESCRIPTION OF EFFORTS MADE TO ENSURE THAT OFFERS ARE

SOLICITED FROM AS MANY POTENTIAL SOURCES AS IS

PRACTICABLE, INCLUDING WHETHER A NOTICE WAS OR WILL BE

PUBLICIZED AS REQUIRED BY SUBPART 5.2 AND, IF NOT, WHICH

EXCEPTION UNDER 5.202 APPLIES.

A synopsis will be posted to beta.SAM.gov website to provide all commercial entities an opportunity to submit proposals for this requirement.

7. DETERMINATION BY THE CONTRACTING OFFICER THAT THE

ANTICIPATED COST TO THE GOVERNMENT WILL BE FAIR AND

REASONABLE.

As the Contracting Officer, I hereby determine that pricing will be fair and reasonable based on a pricing analysis in accordance with FAR 15.404-1. It is anticipated that the Government will perform a comparison of the proposed price with prices charged to the third party contractor previously responsible for procuring the medical/surgical product data feed as well as a comparison to other raw data subscription providers, less data normalization and/or benchmarking services.

8. DESCRIPTION OF THE MARKET RESEARCH CONDUCTED (SEE PART

10) AND THE RESULTS OR A STATEMENT OF THE REASON MARKET

RESEARCH WAS NOT CONDUCTED.:

The DLA Medical Directorate conducted Market Research in May 2020 to compare service offerings of the incumbent vendor (GHX) with alternative solutions existing in the industry.

Market Research techniques included a review of Acquisition History for contracts used by the directorate to procure similar services and searching the FedBiz and GSA websites for other vendors with similar data service offerings. Primary comparative factors used to analyze alternatives included technical service offerings, functional familiarity, and cost to the Medical Directorate.

Alternative subscription services considered were the 1WorldSync Data Solutions Product and IQVIA (Formerly IMS) Government Solutions, Inc.

1WorldSync

Previous 1WorldSync license agreements with DLA Medical Supply Chain were negotiated for a low cost and without a government mandate for manufacturer registration, they lacked comprehensive medical/surgical product data for the thousands of items purchased by the Department of Defense (DOD). They held product data submitted voluntarily by 15 participating major manufacturers and manufacturer/distributors and only for those items currently mandated to be registered by the FDA (Class III highest risk, medical devices).

Although the 1WorldSync data feed provides GDSN government required data, it does not satisfy the newer, more comprehensive revised product data attributes necessary to support mission critical DML-ES data standardization requirements. The fifteen (15) participating manufacturers represent only a small percentage of the commercial marketplace with whom the government contracts. This falls far short of meeting the DML-ES need to get to one product ID for the 217 individual DMLSS retail catalogs in order to support the

EHR.

IQVIA

IQVIA Health Hospital Supply Index provides product data from more than 500 indirect and direct sales data sources and specializes in pharmaceutical prescription data collection. The Index also reports on the sales of 550,000 medical/surgical supply products via a database analysis tool with 6 years of trending information.

DLA Troop Support Medical Directorate currently receives IQVIA Pharmaceutical Sales Data, Relational Data Models for Pharmaceutical Sales Data and for Medical/Surgical Sales Data, Medical/Surgical Synonym Files, and Package Allocations for Medical/Surgical Data, on a quarterly basis and a Comprehensive Data Dictionary on an annual basis under its current annual subscription. Current costs are:

Although the IQVIA tool provides a number of valuable components of Pharmaceutical/Medical Surgical data, it does not offer the specific data attributes that are necessary by the MMC and PDB to meet the government’s requirement for data associations, classifications and synchronizations that are clinically vetted. The IQVA data set is focused to identify commercial sales of medical items and provides only the attributes for identification at the time the item was purchased. In fact, we use GHX data set along with Supply Line classification to identify clinically equivalency, to extract transform and load the IQVA dataset in our system thus achieving a synchronized unique identification and avoid clinically different items to appear as equivalents in our system. Thus, the IQVA subscription is complementary to GHX dataset towards our effort to uniquely identify each medical item and the commercial sales associated with that item.

Market Research Recommendation

Due to the complex and sophisticated nature of this particular Medical Surgical data requirement, the government feels confident in asserting and justifying that GHX is the only vendor that can provide the required product data to improve data quality (accurate, current, and standardized data) in the DMLES - DLA Medical systems. This Data enriched by clinically trained analysts and aggregated spend enables better business intelligence for strategic acquisition planning as well as logistics missions. This solution will provide twenty-one (21) additional attributes for 130,000 item records that will improve the quality of product data in the DMLES for comparison and incorporation into the system’s databases, interfaced applications, and ultimately the DOD EHR, to exploit the available commercial data descriptors for data standardization and spend aggregation.

The GHX services supports a data management strategy that can drive significant savings from data standardization, reduced errors, and lower costs from better contract alignment.

This strategy uses the largest, most comprehensive content management platform to ensure the maximum opportunity to reduce costs and support data management initiatives for the Medical Supply Chain.

While the other sources reviewed can satisfy parts of the government requirement, there is only one responsible source and no other supplies or services that will satisfy all of the program requirements.

9. ANY OTHER FACTS SUPPORTING THE USE OF OTHER THAN FULL

AND OPEN COMPETITION.

Because the GHX data feed is already programmed into the MMC monthly build process and algorithms, it is more economical to continue operations with existing code than to reprogram for a different data source. There is no approved budget or justifiable business need for reengineering the current data feed from GHX to accommodate that of an alternative subscription service. Based on standard DCSO Independent Government Cost Estimate (IGCE) development guidelines, estimated costs for feasibility analysis, redesign, and recoding are at least $101,727,

10. LISTING OF THE SOURCES, IF ANY, THAT EXPRESSED, IN WRITING,

AN INTEREST IN THE ACQUISITION.

GHX.

11. STATEMENT OF THE ACTIONS, IF ANY, THE AGENCY MAY TAKE TO

REMOVE OR OVERCOME ANY BARRIERS TO COMPETITION BEFORE

ANY SUBSEQUENT ACQUISITION FOR THE SUPPLIES OR SERVICES

REQUIRED.

At this time, GHX Product Data Subscription is the only services that will support DLA’s requirements and meet the Government’s needs. However, DLA has exercised, and continues to exercise, competition as often as possible and is required to conduct ongoing reviews to keep abreast of new technology, both in industry and the Government. As a continuing effort, DLA utilizes a variety of vendors, manufacturers, and contracts to fulfill its requirements and will continue the practice of surveying the market to ensure full and open competition to the maximum extent practicable.

12. CONTRACTING OFFICER CERTIFICATION THAT THE JUSTIFICATION

IS ACCURATE AND COMPLETE TO THE BEST OF THE CONTRACTING

OFFICER’S KNOWLEDGE AND BELIEF.

Technical and Requirements Certification I hereby certify that the supporting data provided for which I am responsible, and which form a basis for this justification are complete and accurate:

DATE

I hereby certify that the information contained in this justification is accurate and complete to the best of my knowledge and belief.

Division Chief’s Certification and Approval

I hereby certify that this justification is accurate and complete to the best of my knowledge and belief.

DLA Contracting Services Office – Philadelphia

Competition Advocate Certification and Approval

I have reviewed and concur with this justification.

DLA Contracting Services Office