GS-35F-598GA-001.pdf

Enterprise Testing Service Support Services

Control Number: TAC-18-51942

LIMITED-SOURCES JUSTIFICATION

1. Contracting Activity: Department of Veterans Affairs (VA) Office of Procurement, Acquisition and Logistics Technology Acquisition Center 23 Christopher Way Eatontown, NJ 07724

2. Description of Action: The proposed action is for a Firm-Fixed-Price order to provide continued Enterprise Testing Service (ETS) Support Services (ETSSS). This effort is being conducted under the authority of the Multiple Award Schedule Program; the proposed effort will be awarded under General Services Administration (GSA) Federal Supply Schedule (FSS), Contract Number GS-35F-598GA to Planned Systems International, Inc. (PSI).

3. Description of the Supplies or Services: ETS services support the Secretary, Veterans Affairs (SECVA) priorities including the Electronic Health Record (EHR) Modernization (EHRM) program and current VA legacy systems that are foundational to EHRM. These initiatives supported by ETS are the SECVA's top two enterprise initiatives under the Modernize Systems and Focus Resources strategic goals. In May 2018, the EHRM contract was awarded which resulted in a gradual but deliberate shift from a legacy application focus to a modernization effort focus using current contract resources. At the time the current contract vehicle was awarded in 2014, EHRM was not anticipated. Since award of EHRM, VA has had an increase in testing requirements as part of needed preparation for delivery of EHRM test and evaluation projects described later in this section. There is also an increased emphasis on providing test services for legacy applications related to EHRM. The current ETSSS task order is in option year 3, and the current option year will end on September 14, 2018. Continued support by PSI will allow for continued testing and support of legacy applications and support to EHRM initial operating capability (IOC) program requirements and Legacy foundational/integration systems; enable ETS to provide continuity of Independent Verification and Validation (IV&V) test environments and provide test and evaluation of software that are critical to the success of SECVA's priorities, including EHRM;

and afford VA ETS adequate time to prepare and solicit a follow-on order/contract for the required testing services using competitive procedures. Specifically, a follow on order is needed in lieu of exercising option year 4 as the total contract ceiling has already been consumed due to the increase in required testing in the first four years and additional previously unknown requirements resulting from EHRM. ETS services are key to minimizing the risk of software defects which could adversely affect care and/or services delivered to the Veteran. There are over 20 Test & Evaluation projects anticipated for EHRM to be successfully deployed/implemented in five key EHRM locations (Mann-Grandstaff - Spokane, WA; Puget Sound Health Care System, Seattle - Seattle WA; Puget Sound Health Care System, American Lake - Tacoma, WA; White City- White City OR; and Wainwright - Walla Walla, WA) by March 2020, with critical testing beginning in December 2018. PSI, in support of ETS, is currently providing and will continue to provide Test Environments; Engineering/Configuration; Management and Maintenance; Test Data Services; Test Analysis; Test Evaluation and Execution; Test Management and

Control Number: TAC-18-51942

Schedule Management; and Test Execution Metrics and Measures/Dashboard reporting as detailed in the current Performance Work Statement (PWS), specifically PWS Tasks 5.2, 5.3 and 5.5. To meet the EHRM critical IOC schedule, PSI is the only qualified source to ensure continuity of these complex services considering the critical need for EHRM implementation deadlines to be met. The period of performance is September 15, 2018 through September 14, 2019. This requirement includes three Optional Tasks: Optional Task 1 is for transition out support; Optional Task 2 is for incremental increase in independent test and evaluation support, and;

Optional Task 3 is for incremental increase in test systems engineering and implementation support. The total estimated value of the proposed effort including optional tasks, is .

4. Statutory Authority: This acquisition will be conducted under the authority of the Multiple-Award Schedule Program. The specific authority providing for a limited source award is Federal Acquisition Regulation (FAR) 8.405-6(a)(1)(i)(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."

5. Rationale Supporting Use of Authority Cited Above: The proposed source is PSI, 10632 Little Patuxent Parkway, Suite 200, Columbia Maryland 21044-6250. The SECVA issued the Determination and Findings for the EHR system in June 2017 with nine findings related to the criticality of EHRM within VA and the critical need for an EHR solution that enables seamless healthcare to Veterans and qualified beneficiaries. At the time of the ETSSS contract award in September 2014, the EHRM program did not exist, as the Secretary's decision regarding a commercial EHR solution was not known until June 2017 and the EHRM indefinite delivery/indefinite quantity contract and the first three task orders were not awarded until May 2018. Therefore, the anticipated test and evaluation workload for the resulting EHRM program, with associated resource requirements was unknown and not included in the ETSSS' Independent Government Estimate to set the price ceiling at a level that supported the EHRM program during the period of performance. A modification to the current order cannot be issued as the underlying GSA contract has since expired. The timely execution of the test services outlined in Section 3 of this document is critical for successful implementation of the three IOC sites and test analysis and preparation for the next two sites after IOC. PSI is uniquely qualified to perform this testing in time for the IOC sites, which is critical to the success of the EHRM program. PSI has a testing process/environment and team in place with the necessary expertise to perform and complete the required testing without causing delays.

Another source would require significant ramp-up time to provide the aforementioned ETSSS services including IV&V which would result in delays in critical EHRM implementation deadlines and duplication of effort and cost.

Specifically, any other source would have to replicate the existing process/environment that PSI has established or develop its own process/environment in order to provide the current level of required services, resulting in substantial duplication of cost and effort, as well as a break in ETS test

Enterprise Testing SeNice Support SeNices

Control Number: TAC-18-51942 seNices. This is a detailed and complex process that requires any other source to examine the entire EHRM Program, legacy systems, and completion of ongoing tasks. VA anticipates that this would take a minimum of nine months to re-create and result in extensive and unacceptable delays and duplicated costs mostly related to the analysis and duplication of effort associated with the completion of ongoing tasks.

Additionally, any other source would need an estimated nine months to onboard, obtain clearances and access, and learn what is required for this effort. This estimate is based on previous efforts to establish a testing environment and onboard and train resources. Furthermore, the work is increasingly more complex with the inclusion of the EHRM support. Bringing on a new vendor would result in a break in ETS seNices until the vendor is trained and at operating capacity. This could have a direct negative impact to Veterans' health as Patient Safety Issue patches described later in this section are required to be tested. A break in seNice would jeopardize ETS's ability to meet this and other critical testing requirement.

Utilizing a new vendor would result in a significant amount of duplicative effort and repetitive analysis with respect to legacy-supporting activities and EHRM activities.

A new vendor cannot rely on the current vendor's analysis to determine risk-based seNices nor can it execute plans generated by the previous vendor without thorough review and analysis of its own which would require duplicative review, analysis and testing. Thus, a significant percentage of work must be duplicated to ensure that contractual requirements are met, resulting in duplicative costs to VA Also, a new vendor would have to perform this duplicative work while concurrently meeting ongoing contractual requirements which in effect doubles the workload for a new vendor until the previous vendor's methodology, analysis and work products are analyzed and validated. With respect to Legacy, there is a continuous flow of ETS actions currently being performed that are in various stages of completion. For example: to date in fiscal year (FY) 2018, PSI has performed Do No Harm testing on 43 Patient Safety Issue patches; delivered 16 Risk Analysis Summaries, 11 of which recommended ETS seNices; PSI is currently tracking 187 active Legacy projects and created 23 Build Assessment Summary (BAS) records; PSI is monitoring 91 BAS, and Legacy projects and estimate 12 Builds will start during September 2018; and there are also 14 new Project Analysis Summary records pending start. Many of these activities are ongoing and would require duplicative review, analysis and testing if the ongoing tasks are transitioned to a new vendor. In addition to legacy support, thus far in FY 2018, over 32,000 contract resource manhours have been invested in support of EHRM activities. Activities such as - EHRM program analysis, discovery and engineering have cons·umed the bulk of resource hours. A new vendor would need to validate the methodology used for information analysis to ensure that contract requirements were being met which will result in unacceptable delays. Risk Assessments have been delivered on two of the three EHRM task orders awarded to date. Each Risk Assessment has taken an average of 4.5 months to complete. The third Risk Assessment is ongoing. PSI has developed an Integrated Master Schedule (IMS) that supports EHRM and is the result of 2,000 total contractor manhours invested. The IMS contract lead invested

Control Number: TAC-18-51942

981 manhours alone, with the remainder coming from multiple contract resources who contributed to the effort. Additionally, PSI developed a Test and Evaluation Program Plan which is regularly reviewed and refined. 150 EHRM action items tracked via SharePoint have been accomplished to date, with a large percentage of these action items resulting in the creation, monthly review, and update of Program wide documentation such as the Data Migration Plan. Again, a new vendor would devote significant resources to analyze and validate and modify these critical products resulting in significant duplication of cost and effort. Finally, EHRM is facing a Congressional deliverable of an IOC Program Baseline Review which is due mid-September. Support of this baseline review cannot be accomplished by a new vendor as timelines prevent it. Failure to meet these timelines would result in degradation of the EHRM effort directly, adversely impacting Veterans' level of care.

As outlined above, this would result in extensive delivery delays and duplicated efforts and costs that would not be recovered through competition.

Based on the information presented above, PSI is the only source that can meet ETS requirements. In a seemingly unstable environment, ETS has a mature testing process. An experienced vendor is required that can provide continuity and needed services in support of the Office of Information and Technology (OIT) as it is going through transformation, and supports the Office of EHRM as it executes the EHRM plan. PSI is the only vendor who can provide the required services, without adversely impacting OIT transformation initiatives and EHRM implementation deadlines as it has the resources with the required skillsets in teams organized to meet ETS mission requirements already in place and can ensure continuity, and provide IV&V and other aforementioned services required for EHRM implementation deadlines to be met. Missed EHRM implementation deadlines would create second order effects of increased costs for United States taxpayers and would prevent the VA from supporting the Veteran in the best possible way. Congress has established an oversight sub-committee to monitor progress of the VA EHRM implementation.

Failure or delay during the first release cycle due to contractor transition would negatively impact assessment of this effort, potentially leading to cancellation and loss of related funds. This represents a direct negative impact to Veterans that would otherwise realize an improvement in care through modernization of VA systems as directed by the Secretary of the VA and the President.

6. Efforts to Obtain Competition: Market research was conducted, details of which are in the market research section of this document. This effort did not yield any additional sources that can meet the Government's requirements. There is no competition anticipated for this acquisition. The ordering activity will post this justification along with the request for quote to the GSA E-Buy website in accordance with FAR 8.405-6(b)(3). Additionally, in accordance with FAR 5.301 and FAR 8.405-6(a)(2), notice of award for this action will be synopsized on the Federal Business Opportunities website and this justification will be made publicly available within 14 days of award.

7. Actions to Increase Competition: No barriers to future competition are anticipated. VA was in the process of competing all future testing requirements

Control Number: TAC-18-51942 however there were unanticipated events that occurred that required redefining the future ETSSS requirements. Specifically, in May 2018 the EHRM contract was awarded which resulted in an increased use of this current contract's resources to analyze and prepare for EHRM support and delayed the VA with being able to determine VA EHRM support requirements. Additionally, ETS was recently reorganized and now falls under Enterprise Program Management Division who is undergoing a multi-phased transformation plan and ETS currently does not have transformation details sufficient to capture future requirements into a competitive contract. VA is now finalizing its requirements which is anticipated to be completed in December 2018. A competitive contract vehicle is anticipated to be awarded in the 3rd quarter of fiscal year 2019. All future acquisitions for the aforementioned ETSSS including both legacy systems and EHRM testing will be awarded on a competitive basis.

8. Market Research: Market Research was conducted by Government technical experts in July 2018 by reviewing the capabilities of potential vendors via internet research and researching similar efforts. While other sources, have the general capabilities needed to perform the proposed effort, only PSI can meet VA's needs as outlined in Section 5 of this Justification. The current vendor is the only source that can meet the Governments requirements.

9. Other Facts: None

Control Number: TAC-18-51942

10. Technical and Requirements Certification: I certify that the supporting data under my cognizance, which are included in this justification, are accurate and complete to the best of my knowledge and belief.

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Signature: ________ _

11. Determination of Best Value: I hereby determine that the proposed contract action will represent the best value to the Government consistent with FAR 8.404(d). GSA has already determined that the prices on its GSA FSS contracts are fair and reasonable. Further price analysis, to include an analysis of proposed level of effort and mix of labor, will be conducted and subsequent negotiations held as necessary.

12. Procuring Contracting Officer Certification: I certify that this justification is accurate and complete to the best of my knowledge and belief.

13. Legal Sufficiency Certification: I have reviewed this justification and find it adequate to support a limited source award and deem it legally sufficient.

Approval

Control Number: TAC-18-51942

In my role as Head of the Contracting Activity, based on the foregoing justification, I hereby approve the acquisition for ETSSS, pursuant to the authority cited in Section 4 above, subject to availability of funds, and provided that the services herein described have otherwise been authorized for this acquisition .

Date:

Signature: