36C24120D0003-005.pdf

VHAPM Part 806.3 Other Than Full and Open Competition (OFOC) SOP Attachment 2: Request for Sole Source Justification Format >SAT

OFOC SOP Revision 08 Page 1 of 8 Original Date: 03/22/11 Revision 08 Date: 04/18/2018

DEPARTMENT OF VETERANS AFFAIRS

Justification and Approval (J&A) For

Other Than Full and Open Competition (>SAT)

Acquisition Plan Action ID:_______36C241-19-AP-3461 _________

1. Contracting Activity: Department of Veterans Affairs, VISN 01, White River Junction Medical Center RPO East, NCO-1, Services Team 1, Manchester NH

2. Nature and/or Description of the Action Being Processed:

Transportation broker services for non-emergent medical transportation (NEMT) to be provided to beneficiaries of the veteran transportation program at the White River Junction, Vermont and Manchester, New Hampshire VA Medical Centers. This J&A is to establish a one year IDIQ contract that will serve as a pilot program for an acquisition strategy that has not previously been attempted. This model seeks to utilize a transportation broker/ third party logistics provider (3PL) to serve the Veterans of rural communities. These are areas of New Hampshire and Vermont that have presented historical challenges for contracted ambulance and wheelchair van providers. This one year pilot for non-emergent transportation brokerage services has an estimated value of $690,405.50.

3. Description of Supplies/Services Required to Meet the Agency’s Needs:

Assist in building a partnership and sharing resources with the New Hampshire Department of Heath and Human Services to reduce double billing and streamline the billing process of transportation provided to Veteran beneficiaries who are also covered under Medicaid.

Reduce the barriers of federal market entry for small business transportation providers through mentorship programs and requiring the small business transportation providers within their network to register in SAM.gov.

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Provide administrative support services that foster fair and equitable business practices by providing fair opportunity to regional small businesses to respond to transportation requests for VA beneficiaries.

4. Statutory Authority Permitting Other than Full and Open Competition:

(X) (1) Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements per FAR 6.302-1;

6.302-1 -- Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.

(a) Authority.

(1) Citations: 10 U.S.C. 2304(c)(1) or 41 U.S.C. 3304(a)(1).

(2) When the supplies or services required by the agency are available from only one responsible source, or, for DoD, NASA, and the Coast Guard, from only one or a limited number of responsible sources, and no other type of supplies or services will satisfy agency requirements, full and open competition need not be provided for.

(i) Supplies or services may be considered to be available from only one source if the source has submitted an unsolicited research proposal that --

(A) Demonstrates a unique and innovative concept (see definition at 2.101), or, demonstrates a unique capability of the source to provide the particular research services proposed;

(B) Offers a concept or services not otherwise available to the Government; and,

(C) Does not resemble the substance of a pending competitive acquisition. (See 10 U.S.C.

2304(d)(1)(A) and 41 U.S.C. 3304(b)(1).)

5. Demonstration that the Contractor’s Unique Qualifications or Nature of the Acquisition Requires the Use of the Authority Cited Above (applicability of authority):

In the rural communities of Vermont and New Hampshire, the Government requires a contractor that is capable of leveraging municipalities, non-profit corporations, and small business providers to access Veterans across the entire state. There is no single contractor who can provide coverage over the entire states of VT or NH, as evidenced by years of market research and past performance. This leaves the government with two viable options; utilizing a prime contractor who has a robust subcontracting network, or pursuing a broker or 3rd party logistics provider. In this particular case, engagement with the VA OSDBU office and extensive market research has led to an acquisition strategy of pursing a pilot program with Coordinated Transportation Solutions, Inc. (CTS) an established non profit transportation broker with large networks of transportation providers inside

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Connecticut, Massachusetts, New Hampshire and Vermont. CTS currently provides transportation to Medicaid recipients in the state of New Hampshire as a contractor for the NH Department of Health and Human Services. Their ability to schedule, coordinate, dispatch and provide NEMT has been proven with their satisfactory performance with the state as reported by the Provider Relations Manager at the Office of Medicaid and Business Policy the NH Department of Health and Human Services.

This approach has the advantage of advancing small business concerns in the hard to access rural communities of New Hampshire and Vermont. CTS as a transportation broker has established partnerships with small businesses serving these communities that would not have the means to participate in a traditional solicitation for transportation services with the requirement to cover the entire state. The most recent solicitations for transpor ation services within New Hampshire and Vermont resulted in only one offer received from the incumbent contractor. This limited participation suggests the requirement to serve large geographic areas which require multiple assets and communication streams can burden small businesses by ncreas their overhead to the point that extending services to the Government would greatly impact their profitability.

Contracting with CTS has the advantage of bridging the barriers of entry into the Federal contracting arena for these small business concerns. All small businesses within the CTS network will be registered in SAM.gov in order to accurately capture each subcontractors business size and report small business utilization during this trial period.

After extensive market research, community collaboration, engagement with industry and discussions with the New Hampshire Department of Health and Human Services it was determined that the best option is to pilot a third party transport ion broker model with CTS. There were no competitors identified who have the networking capabilities or experience with rural transportation that CTS has. As the current contractor providing NEMT services to the State of New Hamp hire for Medicaid and Healthy Families programs. In this role CTS has favorable past performance and access to communities that other transportation providers would struggle to access or find unprofitable due to remoteness, distance and the necessity of transporting an empty vehicle for two of the four required trips for round trip transportation. Utilizing CTS and tapping into their network allows small business concerns the opportunity to accept rides on a scheduled basis and the ability to only accept the rides that the small business decides it can support. This model allows for small businesses to gain knowledge and experience within the Federal contracting arena that will allow them to be more comfortable and competitive when participating in future solicitations.

CTS is uniquely positioned as they are currently meeting government standards of service in their performance with the New Hamp hire DHHS. CTS offers a call center open 24 hour a day, 7 days a week located within New Hampshire to receive transportation requests, dispatch transportation providers and communicate status to customers. This CTS call center is co-located with the New Hamp hire Local Government Center, a on rofit that provides administrative services to municipalities allowing for business engagement and collaboration with municipal transportation providers, a valuable and untapped resource to aid in the transportation of Veteran patients residing in rural areas.

In accordance with regulations on sole sourcing present in FAR 6.302-1(a)(2)(i) the requirements of exercising the authority is met as follows.

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Demonstrates a unique and innovative concept (see definition at 2.101), or, demonstrates a unique capability of the source to provide the particular research services proposed;

The transportation broker services offered by Coordinated Transportation Solutions, Inc.

represent a unique, un approach to providing transportation to a large pool of beneficiaries spread across a large geographic area.

Offers a concept or services not otherwise available to the Government; and, The ability to tap into and utilize a large pool of transportation providers has until now been unavailable to the government. While the Government could establish a multiple award contract or agreement with multiple private transportation providers it would be unable to tap into the municipal resources that Coordinated Transportation Solutions, Inc. has access to. Additionally even if multiple awards were made the service provided by CTS in announcing assigning, and coordinating the transports could not be achieved by the station Transportation Manager without considerable, unacceptable delays to the transports of beneficiaries.

Does not resemble the substance of a pending competitive acquisition. (See 10 U.S.C.

2304(d)(1)(A) and 41 U.S.C. 3304(b)(1).)

There are no current competitive actions for transportation broker or any services related to this proposed acquisition.

Accordingly, Coordinated Transportation Solutions, Inc. is the only firm capable of providing the transportation broker services for non emergent transport of patients of the White River Junction and Manchester VA Medical Centers without the Veteran’s Health Administration experiencing substantial duplication of cost that could not be expected to be recovered through competition.

6. Description of Efforts Made to ensure that offers are solicited from as many potential sources as deemed practicable:

Solitation VA241-17-R-0345 published to Fed Biz Opps on 7-13-2017 for Ambulance Services for the Manchester NH VAMC resulted in only one offer from incumbent contractor

The pricing proposed by was below Medicare rates but 75% higher than the Independent Government Cost Estimate.

Solicitation 36C24119Q0226 published to Fed Biz Opps on 3-25-2019 for Ambulance and Special Mode Transportation in Vermont was issued to . under Other than Full and Open Competition procedures. The procurement method was justified by stating was the only vendor capable of providing the required 20 minute response time, however in practice over the past six months has not been able to perform to this standard forcing the station to expand their VTS program, and procure trips individually from small business providers.

Several searches were performed in VIP in order to identify veteran owned small business concerns capable of performing the required services of a transportation broker. NAICS code 621910 –

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Ambulance Services was utilized in all searches as well as PSCs V225 Ambulance Services, V302 Travel Agent Services, and V999 Other Transportation, Travel and Relocation Services, these searches yielded 7, 1, and 2 results respectively. All vendors identified in the VIP search results were investigated, websites, if available, were viewed and capability statements posted within the VIP website were reviewed. None of the vendors identified in VIP were registered with the Vermont Department of Health, the Vermont Ambulance Association, the New Hampshire Bureau of Emergency Medical Services or the New Hampshire Ambulance Association. No certified Veteran owned small business concern was identified to have the immediate capabilities or experience to perform the transportation services essential to this requirement.

7. Determination by the CO that the Anticipated Cost to the Government will be Fair and Reasonable:

The cost of this contract is anticipated to be fair and reasonable based on transparency of the State of New Hampshire Department of Health and Human Service’s contract for transportation broker services with CTS ricing received from for A L S , B L S transports. The pricing was compared to current prices paid under current contracts servicing the delineated areas for identical services. The following substantial savings were identified:

In addition to the potential cost savings, the pilot program will also afford the stations the convenience of coordinating transportation services through network of providers, the ability to tap into a large network of municipalities, and small business transportation providers that have not historically had the opportunity to participate in a government contract. Reaching these available but unused resources will introduce these companies to the federal acquisition process and remove stigmas and barriers that once excluded them from providing their services to our VA Medical Centers.

Most importantly, this model offers a potential increase in the quality of care offered to our Veteran Patients. A reduction in canceled or delayed trips for Veterans will result in less missed and rescheduled appointments which not only presents an inconvenience but could delay the diagnosis or treatment of serious conditions. As the volume of transportation requests increase we must do all we can to ensure our Veteran Patients arrive to their appo ntments safely and timely.

8. Description of the Market Research Conducted and the Results, or a Statement of the Reasons Market Research Was Not Conducted:

The following methods were used in market research for this requirement:

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GSA Schedule 599 Travel Services Solutions was reviewed to identify any transportation brokers already available under government contract. The closest sub category to meet this requirement is 599-2 Travel Agent Services. All small businesses under the schedule were reviewed, while all offer commercial travel services such as scheduling, reservations and ticketing, and private chartered transportation services, no vendors under the 599-2 schedule provide ambulance or other forms of medical care transportation.

Several searches were performed in VIP in order to identify veteran owned small business concerns capable of performing the required services of a transportation broker. NAICS code 621910 – Ambulance Services was utilized in all searches as well as PSCs V225 Ambulance Services, V302 Travel Agent Services, and V999 Other Transportation, Travel and Relocation Services, these searches yielded 7, 1, and 2 results respectively. All vendors identified in the VIP search results were investigated, websites, if available, were reviewed for services provided and capability statements posted within the VIP website were reviewed. None of the vendors identified in VIP were registered with the Vermont Department of Health, the Vermont Ambulance Association, the New Hampshire Bureau of Emergency Medical Services or the New Hampshire Ambulance Association. No vendors were identified to have the immediate capabilities or experience to perform the transportation broker services essential to the success of this pilot program.

Market research also included contacting knowledgeable individuals in Government and industry regarding market capabilities to meet the station’s requirements. The New Hampshire Department of Health and Human Services currently utilizes a transportation broker model to support Medicaid transportation requirements within the state of New Hampshire. Contracting Officers from NCO-1 met with the New Hampshire Department of Health and Human Services Provider Relations Manager to discuss the shared obstacles encountered in navigating the high volume of transportation requests for New Hampshire’s multiple program offices and how the state’s solutions could be applied to aid in the transport of VA beneficiaries of medical transportation services. While discussing the VA’s increasing demand for transportation and challenges faced with the limited number of contractors the Provider Relations Manager stated that the New Hampshire DHHS experiences the same challenges in providing transportation to Medicaid beneficiaries. The solution derived by the tate was utilizing a transportation broker model which was found to be the best of all available options given the limited number of competitors in the state with the resources to provide the services required. The state of New Hampshire solicited for Transportation services for the Granite State Advantage program which they received a proposal from only one qualified transportation broker, non-profit entity Consolidated Transportation Solutions Inc. (CTS). What set CTS apart was their ability to maintain a large network of small business subcontractors throughout New England which provides customers a model that increases the probability of the request being accepted and decreases the risk of transportation refusals and delays.

9. Any Other Facts Supporting the Use of Other than Full and Open Competition:

10. Listing of Sources that Expressed, in Writing, an Interest in the Acquisition:

None

11. A Statement of the Actions, if any, the Agency May Take to Remove or Overcome any Barriers to Competition before Making subsequent acquisitions for the supplies or services required:

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The purpose of this action is to establish a pilot for a new process to meet the increasing need of transportation in rural areas. Throughout the one year trial period the Contracting Officers, Transportation Managers and stake holders will meet to discuss successes and failures of the program. After the one year trial period market research will commence once again for a long term solution to non-emergent medical transportation provision and coordination.