Redacted JA - Medicom VISN 12.pdf

Medicom Software & Support – VISN 12 CONTROL NUMBER

JUSTIFICATION FOR OTHER THAN FULL AND OPEN

COMPETITION

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 sole source firm-fixed price (FFP) contract for the renewal of Medicom Technologies, Inc.’s (Medicom) bi-directional medical imaging exchange software and maintenance with Medicom Technologies, 555 Fayetteville Street, Suite 300, Raleigh, NC 27601.

3. Description of Supplies or Services: VA, Veterans Health Administration (VHA), Veteran Integrated Service Network (VISN) 12 has a requirement to renew its brand name Medicom diagnostic imaging system for point-to-point bi-directional electronic exchange platform for the secure transmission of Digital Imaging and Communications in Medicine (DICOM) imaging examinations and radiology reports between all VINS 12 facilities and VA-approved community care providers. VA requires a solution that meets HL7 standards and IHE profiles ensuring the platform can integrate well with VA and other community care systems. The solution shall include a smart search, an automated federated search which prefetches images from the community care into VA PACS system, once the order is placed. It must not store VA images within the cloud, or any other third-party storage servers. It only transfers images between community care and VA. This solution must accommodate VA Great Lakes Health Care Networks, Jesse Brown VAMC, Edwards Hines Jr. VAMC, Clement J. Zablocki VAMC, William S.

Middleton Memorial VAMC, Oscar G. Johnson VAMC, Toma VAMC, Lovell Federal Health Care Center and VA Illiana VAMC. The primary use of the system will be to provide bi-directional medical imaging exchange services and electronic transmission of medical imaging over a secure, point-to-point DICOM gateway connection between VA facilities and VA-approved community care providers. Services include federated search and retrieval of medical images and diagnostic reports from private sector facilities, automated patient matching, outside order generation in VistA, automated prefetch of prior images in advance of appointments, and electronic request functionality for non-networked facilities. Further, support services, maintenance, and training are required as part of the software subscription.

The period of performance shall be a 12-month base period with two 12-month option periods. The total estimated value of the proposed action is , inclusive of all options.

4. Statutory Authority: The statutory authority permitting other than full and open competition is 41 U.S.C. 3304(a)(1) as implemented by the Revolutionary Federal Acquisition Regulation Overhaul (RFO) VA Deviation 6.103-1 entitled, “Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.”

5. Rationale Supporting Use of Authority Cited Above: Based on market research, as described in Section 8 of this justification, it was determined that no competition is available for this procurement. The Medicom Imagex is already in place across 91 Veterans Administration Health Care Systems and VA Medical Centers across 46 states for clinical image data exchange, including 8 sites within VISN 12. Medicom software solution meets all the following technical and functional requirements and seamlessly integrate with this existing network. The solution is DICOM capable, HL7 standards and IHE profiles ensuring the platform can integrate well with VA and other community care systems. The solution features a smart search feature, an automated federated search which prefetches images from the community care into VA PACS system, once the order is placed. Does not store VA images within the cloud, or any other third-party storage servers. It only transfers images between community care and VA. Images are transferred not only for Radiology but also Dental, Radiation Oncology, Ophthalmology, Cardiology and Neurology.

Brand Name Medicom Imagex’s unique technical capability allows VA to search commercial imaging providers to locate and retrieve prior medical images and reports for storage within VA systems. Further, the brand name Medicom Imagex solution deploys a proprietary peer-to-peer network which communicates via a propriety software code and enables the seamless and secure sharing of radiology information, including reports and images through encrypted conduits between providers on the fully federated health information network. No other solution has access to, nor can seamlessly interoperate with the brand name Medicom Imagex software solution.

The absence of this capability to seamlessly communicate internally and externally to VA impacts VA’s ability to support congressionally mandated requirements, such as the Mission Act, which has enabled Veterans to seek diagnostic imaging services outside of VA. If VA is unable to secure this solution, digital image transmission and sharing would not be possible. VA would have to use compact disks (CDs) and digital video disks (DVDs) that are hand-carried or mailed to and from VA facilities at the completion of a diagnostic test, ultimately creating bottlenecks and delays in the continuity of Veteran care. Additionally, delays in archiving images can also cause misplaced CDs or DVDs, repeated examinations, and “unreadable” images that are incompatible with some software in VA. All adverse factors add to unnecessary health risks of Veterans and additional costs to VA.

Even if VA were able to identify a software solution that could meet all the unique functional and technical requirements, there would be a significant impact and duplicative cost to VA to switch. Specifically, if VA were to switch vendors from brand name Medicom Imagex, VA facilities would have to remove the imaging solution from existing sites and engage with service providers and their unique/varied brand imaging solution to create a capability to share images seamlessly. As part of its commercial offering, Medicom coordinates these activities with the service providers to ensure compliance with VA security and privacy requirements, as outlined in its Business Associate Agreements (BAAs). The BAAs specify procedures for the secure handling of Personally Identifiable Information (PII), outline security requirements, and set expectations for reporting any violations related to HIPAA, the Privacy Act, or other concerns that may arise concerning the transmission of images or other patient medical

9. Other Facts: N/A

10. Technical/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.

11. Fair and Reasonable Cost Determination: I hereby determine that the anticipated price to the Government for this contract action will be fair and reasonable based on historical prices and a comparison to the Independent Government Cost Estimate.

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

Approval

In my role as procuring activity Advocate for Competition, based on the foregoing justification, I hereby approve the acquisition of Medicom bi-directional medical imaging exchange software and supporting services, maintenance, and training on an other than full and open competition basis pursuant to the authority cited in Section 4 above, subject to availability of funds, and provided that the property and services herein described have otherwise been authorized for acquisition.