36C10X24C0031 JA Sole Source Integrated Health Practices Redacted.pdf

DEPARTMENT OF VETERANS AFFAIRS

Office of Procurement, Acquisition and Logistics (OPAL) Strategic Acquisition Center (SAC)

5202 Presidents Ct, Suite 103 Frederick, MD 21703

Justification and Approval for Other than Full and Open Competition

6.302-5 -- Authorized or required by statute

1. Identification of the agency and the contracting activity.

This Justification and Approval (J&A) for Other Than Full and Open Competition is executed by the Strategic Acquisition Center – Frederick (SAC-F), on behalf of the Department of Veterans Affairs (VA), Veterans Health Administration (VHA), Clinical Informatics (CI).

2. Nature and/or description of the action being approved.

This activity proposes to negotiate a non-competitive, sole-source award, with Ben Allegretti Consulting, Inc., a Service-Disabled Veteran-Owned Small Business (SDVOSB), for the procurement of services for Integrated Health Support Services.

3. A description of the supplies or services required to meet the agency’s needs (including the estimated value).

This contract is to provide expanding support across the Human Systems Integration (HSI) domains to engage with critical projects throughout VHA, across the Systems Development Life Cycle (SDLC) on major VA initiatives. Many of the efforts are focused on enabling the implementation of common clinical care pathways that are evidence-based to provide high quality care and support the modernization initiatives of VA. HSI includes Manpower, Personnel, Training, Habitability, Safety & Occupational Health, Survivability, and Human Factors Engineering. As Health Informatics (HI) expands support across VA to support these efforts, HSI requires engaged and knowledgeable resources capable of implementing Human Centered Design (HCD) practices with rigor and skill to help shape critical clinical programs.

While the expansion of skillsets to include HSI domains is necessary to provide more holistic advice and direction to clinical and executive leadership, the integration at the earliest phase for each product is a critical aim to enable design solutions when the most flexibility is preserved.

This effort requires numerous assessment methods integral to the human factors engineer’s skillset, across the entire lifecycle, to encourage intentional trade-off analysis using standards, evidence, and data-driven assessment techniques. Furthermore, the diverse institutional knowledge regarding the expansive support of VHA clinical services necessitates readily available enterprise expert resources to be integrated into agile teams operating within iterative cycles of execution delivering specific value increments. Teams often operate using cross-functional expertise that support the overall objectives of the program, with transparency of operations and clear commitments amongst dedicated resources.

The estimated value for this acquisition is $3,999,997.00, and the period of Performance is a 12-month base period, with no option periods.

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Strategic Acquisition Center (SAC)

4. An identification of the statutory authority permitting other than full and open competition.

The statutory authority permitting other than full and open competition is 41 U.S.C.

3304(a)(5) as implemented by the Federal Acquisition Regulation (FAR) Subpart 6.302- 5 entitled, “Authorized or required by statute”. The applicable statute is Public Law 109- 461:

“Veterans Benefits, Health Care, and Information Technology Act of 2006” specifically, the “Veterans First Contracting Program” outlined in 38 USC § 8127(c).

5. A demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited.

Ben Allegretti Consulting is System for Award Management (SAM) registered and a verified SDVOSB who, as a responsible source, has successfully performed requirements of similar scope and complexity for the VA, via a Task Order, 36C77623N0749, against Indefinite Delivery Indefinite Quantity (IDIQ) Contract 36C77619D0016, with Veterans Health Administration (VHA) Digital Health Office (DHO).

As an SDVOSB sole source contract for VHA, Ben Allegretti Consulting will support collaborative teams working with clinical sponsors in specified domains through established Teams and enabling services. The support effort includes HF support, cross-disciplinary team engagement and study execution in alignment to targeted objectives across the systems development life-cycle (SDLC). Teams will have a chartered objective established, HSI must provide recommendations and input towards the optimal methods and techniques to be applied.

The Contractor shall apply scaled agile practices and engage in sprint and increment planning and appropriate retrospectives efforts beyond the active sprints. Some Team Product Increments (PI) may require more study activities than others based on the particular objectives, and the amount of aligned sprints will be responsive to the scoped effort that iteratively evolves through application of agile methodologies. This task includes Team support for 8 unique Teams each with a Contractor-provided Dedicated Resource Study Lead, Scrum support and a Study Support role, with access to clinical application and clinical expertise through 2 Contractor provided enabling services, as needed (Clinical Application & Clinical Expertise). Study Leads shall be the primary responsible party for the HCD approach and the Human Factor (HF) and User Experience (UX) products and commitments associated with the assigned teams, with operational titles evolving as CIDMO adopts the scaled agile framework.

Ben Allegretti Consulting, is in a more efficient position to take on the tasks associated with the performance of this contract. Specifically, they are already working on similar efforts that closely align with the tasks identified in this contract action. This will result in a more streamlined effort, rather than the additional financial impact that would result from having to start from “square one” with a brand-new Contractor, who lacks the familiarity.

VAAR 819.7008(c) states explicitly, “A determination that only one SDVOSB can meet the requirement is not required,” and that using this authority, the following must be verified:

(1) The anticipated award price of the contract (including options) will not exceed $5 million;

Strategic Acquisition Center (SAC)

The estimated value is $3,999,997.00 and does not exceed $5M.

(2) The justification prepared pursuant to FAR 6.302-5(c)(2)(ii) is posted in accordance with FAR subpart 5.301(d);

The justification will be posted to sam.gov at the time of award.

The SDVOSB concern has been determined to be a responsible source with respect to performance; and in the estimation of the Contracting Officer, contract award can be made at a fair and reasonable price that offers best value to the Government

Ben Allegretti is a registered and verified SDVOSB. Ben Allegretti Consulting has successfully provided these services and is familiar with the tasks for this effort. Ben Allegretti Consulting has experience with integrated health practices for the VA and can provide the required services to complete this effort.

The current VHA Task Order mentioned above was made to Ben Allegretti Consulting using competitive procedures with pricing that was found acceptable at time of award.

Ben Allegretti Consulting’s proposed pricing will be verified using the Independent Government Cost Estimate (IGCE), the pricing from the previous contract, and technical expertise. A fair and reasonable price determination will be made prior to award.

6. A 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.

IAW VAAR § 819.7008 Sole source awards to service-disabled veteran-owned small business concerns (b), “The Contracting Officer’s determination whether to make a sole source award is a business decision wholly within the discretion of the contracting officer.”

IAW VAAR § 819.7008(c), “A determination that only one (1) SDVOSB concern is available to meet the requirement is not required.”

7. A determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable.

No award shall be made until the Contracting Officer determines the cost to the Government to be fair and reasonable. This determination will be based on a comparison of current contract pricing, past proposal submissions (if available), other information made available, and an

IGCE.

8. A description of the market research conducted (see Part 10) and the results or a statement of the reason market research was not conducted.

https://www.acquisition.gov/content/part-6-competition-requirements#i1119843 https://www.acquisition.gov/content/part-5-publicizing-contract-actions#i1120562

Strategic Acquisition Center (SAC)

Market research was conducted and Ben Allegretti Consulting has been determined to be a responsible source with respect to performance. They are registered and certified in veterans.certify.sba.gov (VetCert) as a SDVOSB with the NAICS code for this requirement (NAICS 541611), Administrative Management and General Management Consulting Services, which in accordance with Public Law 109-461 Section 502(c) meets the requirements of this statute to sole source to a SDVOSB. In addition, a review of their Representations and Certifications was conducted in the System for Award Management (SAM) and represented that they are an SDVOSB.

The Integrity Information for Ben Allegretti Consulting was reviewed in SAM, and shows no reports g that would indicate defective pricing, instances of contractor fault or recipient not-qualified, terminations for cause, default or material failure to comply, or non-responsibility of the contractor.

9. Any other facts supporting the use of other than full and open competition.

In accordance with Public Law 109-461, codified at 38 USC § 8127, in order to increase contracting opportunities for small business concerns owned and controlled by veterans and small business concerns owned and controlled by veterans with service-connected disabilities, contracting officers of the VA are given specific statutory authority to award a contract to a small business concern owned and controlled by veterans using procedures other than competitive procedures (i.e., a “sole source” contract). The contracting officer may do so in accordance with VAAR 819.7007.

10. A listing of the sources, if any, that expressed, in writing, an interest in the acquisition.

N/A

11. A 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.

Future requirements will be issued on a competitive basis against the soon to be awarded Integrated Healthcare Transformation (IHT) 2.0 IDIQ contract vehicle.

Strategic Acquisition Center (SAC)

12. Certifications / Signatures.

Technical Representative Certification:

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

Chris Petteys, Date Chief Operating Officer, Human Systems Integration Digital Health Office

Contracting Officer Certification:

Pursuant to (FAR 6.303-2(a)(12)), I certify that this justification is accurate and complete to the best of my knowledge and belief.

Caitlin Ruc, Date Contracting Officer Strategic Acquisition Center- Frederick (SAC-F)

For acquisitions over $750K not exceeding $15M

Approval

In my role as Contracting Activity Competition Advocate, based on the foregoing justification, I hereby approve this acquisition on an “other than full and open competition” basis pursuant to the statutory authority cited in paragraph four above, subject to availability of funds, and provided that the property and services herein described have otherwise been authorized for acquisition. As this action does not exceed $15M, the certification below required by FAR 6.304 serves as approval.

Signature: _________________________________ Date: ____________

Efrain J. Fernandez Director of Contracts, Acquisition Services 1-3 Procuring Activity Advocate for Competition (SAC-Frederick) Strategic Acquisition Center