P03 - Consolidation DnF DSS Final Redacted.pdf

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Brand Name Document Storage Systems, Inc. (DSS) Software Licenses and Ancillary Services National Oncology Program

36C10B-26-AP-0782

FINDINGS

I. INTRODUCTION.

The Department of Veterans Affairs (VA), Office of Procurement, Acquisition, and Logistics—Technology Acquisition Center plans to solicit offers for brand name (DSS Infusion Therapy Manager (ITM) software licenses and ancillary services (maintenance, installation, testing, implementation, and training), and has conducted market research that demonstrates consolidation of this procurement to be both necessary and justified.

II. BACKGROUND

A. Requirement. VA, Veterans Health Administration (VHA), National Oncology Program, has a need to procure annual limited licenses of brand name DSS ITM software and ancillary services to include maintenance, delivery, installation, testing, implementation, and training. The DSS ITM software is for use with the Veterans Health Information Systems and Technology Architecture (VistA) and the Computerized Patient Record System (CPRS) which is a graphical user interface for the VistA Electronic Health Record (EHR) system. VA requires brand name DSS ITM for sites with Vista Chemotherapy Manager (VCM), which is a legacy version of DSS ITM, along with other sites that have not transitioned to Oracle to have the ability to utilize the national contract for DSS ITM software. DSS is retiring the pre-existing contracted VCM software for ordering antineoplastic and other infusion therapy in VistA/CPRS and is replacing VCM with its next-generation solution, ITM, which is also compatible with VistA/CPRS. It has been determined that a Firm-Fixed-Price (FFP) single award Indefinite Delivery/Indefinite Quantity (ID/IQ) contract is appropriate.

This requirement will be solicited as an unrestricted brand name requirement through open market under North American Industry Classification System (NAICS) code 513210 Software Publishers with a size standard of $47 million. In addition, this action cannot be set aside for small business due to the Limitations on Subcontracting Clause which impacts small businesses since the resellers cannot perform at least 50% of the work in accordance with 13 CFR 125.6, as confirmed by DSS. In accordance with Revolutionary Federal Acquisition Regulation (FAR) Overhaul (RFO) FAR 19.104, solicitations may not be set aside for small businesses unless small businesses can perform at least 50% of the work. The five ordering periods—Fiscal Year 2026 through Fiscal Year 2031—aligned to the schedule for full Oracle EHR implementation across VA; when a site transitions, it no longer uses this software.

Program market research demonstrates that consolidating previously separate Veterans Integrated Service Network (VISN)/ VA Medical Centers (VAMC) actions into one

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VA’s technical experts conducted web-based research in February 2026, to determine if there are other relevant electronic chemotherapy software products that are available commercially that interface with VistA/CPRS. Examples of required interfaces with VistA/CPRS include patient specific information which includes labs, age, height, to calculate patient specific doses, allergy alerts, and dose alerts. In addition, a requirement of the system is to document in VistA/CPRS detailing the patient specific chemotherapy regimen including doses and dates. Another required functional capability of the system is placing the medication orders directly into VistA with minimal editing.

There are other electronic chemotherapy software platforms reviewed include:

OncoEMR by Flatiron Health (originally Altos Solutions); ARIA Oncology Information System by Varian Medical Systems / Siemens Healthineers; MOSAIQ (Plaza, Medical Oncology) by Elekta; iKnowMed by McKesson; Epic Beacon by Epic Systems Corporation; Cerner Oncology by Oracle Health (Cerner); EndoVault Oncology by EndoSoft; CellmaEHR Oncology by Riomed; CureMD Oncology by CureMD; Oncology-Cloud by WRS Health / Oncology-Cloud. These systems do not meet the required interface to work with VistA/CPRS, which is a critical requirement as described above. Once a VAMC goes live with the new Oracle EHR, they will utilize the Oracle imbedded chemotherapy ordering module and will transition away from ITM/VCM. Based on these market research efforts, the Government’s technical experts have determined that only brand name DSS ITM can meet all of VA’s needs.

The Contract Specialist also performed additional market research in January 2026, by searching the NASA SEWP Provider Look Up for key word “Document Storage Systems.” The search revealed that there are five companies that are resellers of this product, all of which are small businesses, which includes one of those being a Historically Underutilized Business Zone Small Business and one Service-Disabled Veteran Owned Small Business (SDVOSB). On February 2, 2026, the Contract Specialist emailed DSS to determine whether DSS Inc’s ITM software annual limited licenses and ancillary services can be procured through NASA SEWP. DSS responded on February 4, 2026, and stated that ITM resellers exist on NASA SEWP and are able to provide licenses. However, DSS performs the services work, including training and installation. Although brand name DSS is available on NASA SEWP, this requirement is for an ID/IQ contract which cannot be awarded under NASA SEWP, an IDIQ. An ID/IQ contract is required since there are 170 VAMC's in the process of or have already transitioned over to the Oracle EHR which is scheduled for completion in 2031. Both the quantity and timing of the required brand-name DSS licenses and ancillary services remain variable, and the VA requires flexibility to order these licenses and services as needs arise.

In addition, the Contract Specialist conducted market research on the GSA eLibrary and found that DSS has a Federal Supply Schedule/Multiple Award Schedule contract 47QTCA23D005Q where the required software, annual limited licenses and ancillary services can be procured. However, on March 3, 2026, DSS confirmed with

VAAM M807-C Page C-4 the Contract Specialist that although DSS products are available on GSA, not all products needed in this requirement are sold through GSA. Based on the above, the Government is unable to use an existing contract in accordance with RFO FAR 8.104(a).

In accordance with VA Acquisition Regulation 810.001-70 (deviation), market research was conducted via the Small Business Administration’s Small Business Search (by way of the Veteran Small Business Search website) for a list of SDVOSBs and Veteran-Owned Small Businesses (VOSBs) under the NAICS code 513210, Software Publishers. The results of the Small Business Search found a total of 7,064 SDVOSBs and VOSBs under the NAICS code 513210. Despite the number of matches, the requirement discussed herein is more specialized than a simple NAICS code search; therefore, more specific market research was necessary. The result of this market research (discussed above) was the primary market research considered for this procurement.

The market research conducted led to the decision that this acquisition shall be solicited under full and open competition via System for Award Management (SAM.gov) Contracting Opportunities. Small business participation will be encouraged.

On February 13, 2026, DSS confirmed that there are no subcontracting opportunities possible for this requirement since the services component is only able to be performed by DSS, a large business. However, small business resellers will be able to participate in the competition and the resellers could subcontract with the Original Equipment Manufacturer, therefore, an unrestricted competition would allow opportunity for small business participation.

Notifications (see RFO FAR 7.107-3.

VA Small Business Specialist and local Small Business Administration (SBA) as well as the Office of Small and Disadvantaged Business Utilization (OSDBU) and procurement center representative (PCR).

The Technology Acquisition Center Small Business Liaison and local SBA PCR have been consulted on May 11, 2026.

Affected incumbent small business concerns.

Small Businesses were notified of the Government’s intent to consolidate the requirement and provided the SBA Office of Government Contracting Office serving area on May 11, 2026.

VAAM M807-C Page C-8 and accelerates deployment sequencing across geographically diverse VAMCs.

This reduction in procurement administrative lead time aligns with RFO FAR 7.107-2(c)(2)(iv) as a non-dollar benefit supporting consolidation.

Consolidation promotes enterprise-level consistency by establishing common terms and conditions for licensing, maintenance, testing, and upgrades;

standardized interfaces, configurations, and implementation protocols; uniform training materials and deployment methodologies; a single, controlled defect-tracking and patching workflow; and predictable governance and project management oversight. This standardization is not achievable through multiple decentralized actions and directly enhances performance, aligns with VA modernization priorities, and reduces downstream operational risk.

A2. Mission success.

Even absent the quantified threshold, consolidation is critical to mission success:

without the integrated solution, sites would revert to manual processes for complex infusions, elevating patient safety, operational, and compliance risks (particularly for chemotherapeutic and biologic agents). Amidst the Oracle EHR rollout, a contract vehicle in place for VA facilities to perform infusion therapy management using VCM/ITM while working with the preexisting VistA/CPRS EHR ensures continuity of care in addition to safety of handling such complex treatments. In accordance with VHA Directive 1415 and the American Society of Clinical Oncology and Oncology Nursing Society Antineoplastic Therapy Administration Safety Standards, use of infusion therapy management software in VistA/CPRS improves safety by reducing transcription errors through electronic ordering when available as well as through ordering whole treatment regimens together (e.g., medications to be given pre- and post- treatment in addition to primary treatment medication).

B. Procurement strategy.

The strategy uses a single-award, FFP IDIQ procurement approach that incorporates with early and continuous engagement with the VA Small Business Specialist and the agency Office of Small and Disadvantaged Business Utilization, Small Business Administration Procurement Center Representative in accordance with RFO FAR 7.104(b)(5). This ensures that small-business participation opportunities are maximized, that the planned consolidation has received proper review and coordination, and that VA’s statutory obligations under the Veterans First Contracting Program are fully observed.

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C. Alternative approaches.

In evaluating alternatives, VA considered several contracting approaches involving lesser degrees of consolidation. Each was determined to be infeasible, inefficient, or contrary to VA’s operational and mission requirements. These alternatives included: separate regional or VISN-specific contracts and full competition for alternative commercial platforms requiring new VistA/CPRS integrations. All alternative approaches involving lesser consolidation were found to either fail to meet VA’s technical and clinical requirements, introduce unacceptable cost, schedule, and patient-safety risks, delay Oracle EHR transition readiness, or result in duplicative and unrecoverable expenditures. The consolidated approach is therefore the only viable option that aligns with RFO FAR 7.107-1(a)(2), minimizes burden, and supports VA’s mission needs.

Regional or VISN-level acquisitions. The VA assessed whether individual VISNs or local VAMCs could procure DSS ITM licenses and services independently.

This approach was rejected because it would create significant inconsistency in terms, interfaces, configuration standards, deployment schedules, and training models across the enterprise. Each VISN would need to conduct its own acquisition, increasing workload, administrative lead time, and cost while undermining the uniformity required for specialty-care infusion therapy operations. With more than 50 VAMCs still requiring ITM prior to Oracle migration, decentralized contracting would also fragment implementation support, making efficient sequencing impossible and increasing the risk of deployment delays.

Competing alternative commercial solutions and building new VistA/CPRS integrations. The VA evaluated whether other oncology/infusion therapy software (e.g., OncoEMR, ARIA, MOSAIQ, iKnowMed, Epic Beacon, Cerner Oncology, EndoVault, CureMD, and Oncology-Cloud) could serve as replacements. Market research demonstrated that no alternative solution integrates with VistA/CPRS, a mandatory requirement until the Oracle EHR migration is complete. Attempting to adopt another vendor’s system would require full system re-implementation, including interface development, custom integration, data migration, workflow redesign, and multi-wave training across 2,000 personnel. Estimated timelines ranged from 12–24 months, with costs exceeding $10 million, including over $1 million in interface development and over $6 million in replacement licenses and infrastructure. These costs would be duplicative and unrecoverable, given that all affected sites will transition off VistA/CPRS to Oracle within the next five years.

Procurement deferral until Oracle EHR implementation is complete. Delaying this action is not feasible because more than 50 VAMCs still rely on VistA/CPRS to conduct high-risk infusion therapy operations. Without VCM/ITM, these sites would be forced to revert to manual processes, introducing immediate patient-safety risks and operational disruptions. Manual workflows for biologics

VAAM M807-C Page C-10 and chemotherapeutic agents increase risk of dosing and scheduling errors and can negatively impact care continuity and compliance.

D. Negative impact.

The consolidated acquisition approach will have some impact on small business participation, particularly for those authorized as resellers of brand name DSS under NASA SEWP. Historically, several small businesses—including SDVOSB, VOSB, Women Owned Small Business, and other socio-economic categories— have been able to provide DSS licenses as prime contractors on NASA SEWP.

Since DSS resellers do not perform 50% or more of the work, this requirement cannot be set-aside to small businesses, and award may be made to an other than small business.

Failure to procure the software that manages specialty care infusion treatments will remove a currently operational capability that VA uses to coordinate orders, schedule infusions, calculate doses, document administration, and track monitoring for high-risk infusion therapies. In the absence of this system staff would be required to use manual processes for these activities, which is associated with increased risk of scheduling errors, dosing errors, incomplete documentation, and delays in care for complex medication regimens. For high-risk infused medications, such as biologic and chemotherapeutic agents, these types of failures are known to be associated with adverse clinical outcomes and increased utilization of higher-acuity services. Accordingly, failure to procure this software would disrupt continuity of these functions and would introduce identifiable patient safety, operational, and compliance risks to VA’s delivery of specialty infusion care.

E. Inclusion of small business concerns.

This determination has been coordinated with the VA Office of Small and Disadvantaged Business Utilization. This acquisition strategy has addressed impact to small businesses. This requirement will be solicited as an unrestricted brand name requirement through open market under NAICS code 513210, Software Publishers, since this cannot be solicited on GSA or NASA SEWP.

Any award will be made based on the best overall (i.e., best value) proposal that is determined to be the most beneficial to the Government, with appropriate consideration given to the four following evaluation Factors: Technical, Past Performance, Price, and Veterans Involvement. The Technical Factor is significantly more important than the Past Performance Factor, which is more important than the Price Factor, which is more important than the Veterans Involvement Factor. To receive consideration for award, a rating of no less than "Acceptable" must be achieved for the Technical Factor. The non-Price Factors combined are significantly more important than the Price Factor. Offerors are cautioned that any resulting award may not necessarily be made to the lowest

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Price offered or the most highly rated technical proposal. The Government intends to award one contract to one vendor.

In addition, this action cannot be set aside for small business due to the Limitations on Subcontracting since the resellers cannot perform at least 50% of the work, as confirmed by DSS. In accordance with RFO FAR 19.104, solicitations may not be set aside for small businesses unless small businesses can perform at least 50% of the work. As a result, a Justification for Other than Full and Open Competition has been completed for this effort.