SSJ_signed_Redacted.pdf

Rev. 5/14/19

D. Justification:

1. The justification for this non-competitive action is:

☒ In accordance with FAR 13.106-1(b)(1), “only one source [is] reasonably available” which states that, “For purchases not exceeding the simplified acquisition threshold. (i) Contracting officers may solicit from one source if the contracting officer determines that the circumstances of the contract action deem only one source reasonably available (e.g., urgency, exclusive licensing agreements, brand-name or industrial mobilization). (ii) Where a single source is identified to provide a portion of a purchase because that portion of the purchase specifies a particular brand-name item, the documentation in paragraph (b)(1)(i) of this section only applies to the portion of the purchase requiring brand-name item. The documentation should state it is covering only the portion of the acquisition which is brand- name.”

☐ Urgency ☐ Exclusive licensing agreements/Proprietary data ☐ Brand name required ☐ Industrial mobilization ☒ Other (e.g., compatibility, space issues, continuity, compatibility, etc.)

☐ In accordance with FAR 8.405-6 “Limiting Sources” which states that, “the only circumstances that may justify the action are – (A) An urgent and compelling need exists, and following the procedures would result in unacceptable delays; (B) Only one source is capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized; or (C) In the interest of economy and efficiency, the new work is a logical follow-up to an original Federal Supply Schedule order provided that the original order was placed in accordance with the applicable Federal Supply Schedule ordering procedures. The original BPA must not have been previously issued under sole-source or limited-sources procedures.”

☐ Urgency ☐ Only One Source ☐ Logical Follow Up ☐ Brand name required

2. Other facts supporting sole source procurement:

a. What can this product/service do that other products/services cannot do?

This contract requires a highly skilled terminologist versed in health Information Technology (IT) interoperability standards and strong familiarity with standards development organizations (SDOs). Historical and longitudinal knowledge of the ODH vocabulary, and its nuances are a requirement. The contractor’s SME has worked with NIOSH to complete an extensive review of the ODH vocabulary / terminology in 2021, investigating all representations of the terminology within HL7 interoperability standards and terminology resources, identifying issues that are present, and offering reasonable solutions to resolve them. The report includes preferred methods to update the ODH vocabulary and the pros and cons to each method. This foundational understanding is paramount to successfully complete the vocabulary update.

Rev. 5/14/19

In early 2024 the Office of the National Coordinator (ONC) for Health IT adopted the Health Data, Technology, and Interoperability: Certification Program Updates, Algorithm Transparency, and Information Sharing (HTI-1) Final Rule which established a minimum data set for certified health IT vendors to accommodate within their product(s) to maintain or obtain certification (CMS payment). Of the 94 data elements identified to make up the minimum data set, ODH data elements industry and occupation, and their associated value sets were included as a requirement of the HTI-1 Final Rule. The deadline for certified health IT vendors to accommodate the minimum data set is January 1, 2026.

As a result, certified Health IT vendors are committed to modify their products to accommodate the minimum data set, including the ODH vocabulary, as early as February 2025. The HTI-1 Final Rule and early certified Health IT adopters place a significant time constraint to complete the vocabulary update as soon as possible to allow adequate time for certified health IT vendors to implement the ODH value sets within their product(s) to allow conformance testing to demonstrate compliance in capturing, transmitting, and receiving industry and occupation data elements.

The ODH vocabulary will need to be updated as soon as possible to allow time for certified health IT vendors to integrate the value sets into their products and test their conformance via interoperability standards; demonstrating compliance in capturing industry and occupation using the identified ODH value sets. This work is highly specialized and will require a terminology SME with extensive ODH historical knowledge to complete the vocabulary update in a timely manner.

b. What other products/services were considered and why did they not meet the need?

Other service providers were considered however due to the specificity and constraints associated with the ODH vocabulary, along with the time constraint imposed by the HTI-1 Final Rule to complete the vocabulary update, they did not meet the critical need to update the ODH vocabulary in a concise manner to allow the industry ample time to uptake and test the value sets via existing interoperability standards. It is a requirement for the contractor to have extensive historical knowledge of the ODH vocabulary and its nuances to efficiently accomplish the work.

3. Program Office efforts to seek potential offerors:

The historical knowledge of the ODH framework and its development including data elements, vocabulary value sets, interoperability standards, as well as a sound terminology background are paramount to the vocabulary update success. Having extensive background knowledge in ODH will allow for the identification of any constraints resulting from any modifications made to the ODH vocabulary, and how these modifications will impact associated interoperability standards and resources. An understanding of the health IT policy landscape outlined by the ONC regulation(s) and SDOs are also a requirement to efficiently accomplish this work.

Four of the contractors described above provide health IT services under GSA’s MAS IT, a mandatory use vehicle, under Special Item Number 54151HEAL:

• A1M Solutions 47QTCA21D006V Contract End Date: 3/18/2041

• Carradora Health Inc. 47QTCA19D0013 Contract End Date: 10/23/2028

• Octave Technologies Corp. 47QTCA21D0088 Contract End Date: 04/12/2041

• MicroHealth LLC. GS-35F-413BA Contact End Date: 6/18/2034

Review of publicly available information for the four contractors show they are not capable of meeting the contract needs.