Justification and Approval.pdf

Request for Sole Source Justification Format >SAT

VHAPG Part 806.3 OFOC Page 1 of 6 Revision: 04 Effective Date: 12/15/25 Acquisition ID#: _36C241-27-AP-0102_

DEPARTMENT OF VETERANS AFFAIRS

Justification and Approval (J&A) For

Other Than Full and Open Competition (>SAT)

Acquisition Plan Action ID: 36C241-27-AP-0102

1. Contracting Activity: Department of Veterans Affairs, VISN 01, VA Connecticut Medical Center

2. Nature and/or Description of the Action Being Approved: This is a new contract that will be a Firm Fixed Price (FFP) service contract for providing Residential Rehabilitation Treatment Program (RRTP) and Post-Traumatic Stress Disorder (PTSD) beds. This long-term contract will allow Mental Health (MH) service to maintain continuity of care. A Sole Source procurement is requested for RRTP and PTSD beds to maintain continuity of care at VA Connecticut Healthcare System (VACHS). These inpatient residential beds located in the community provide for the much needed home like environment within close geographic location to VACHS West Haven Campus, so the VA Mental Health (MH) RRTP program teams and providers manage and provide all clinical programming to the Veterans during their stay. This hybrid-style model of care is needed within very close proximity, not more than 10-15 minutes’ drive so the RRTP and PTSD providers can easily access the residence. VA leadership has recognized the ongoing need for RRTP and PTSD beds to maintain continuity of care for the Veteran population at VACHS.

3. Description of Supplies/Services Required to Meet the Agency’s Needs: The total estimated cost for this contract is $37,978,250.00 for a period of performance (POP) of 11/1/2026- 10/31/2031. Firm Fixed rate for the RRTP is $635.00 each bed day of care (BDOC) for eighteen (18) beds and for the PTSD residential beds is $938.00 each BDOC for ten (10) beds. The firm fixed rate is all inclusive and covers the necessary services for a length of stay (LOS) up to twenty-one (21) days and not to exceed (NTE) twenty-eight (28) days for RRTP and fifty-six (56) days NTE sixty-three (63) days for PTSD. Continuum of Care Inc. provides residential and housing in the community with a homelike environment with close geographic location to VACHS. Veterans are clinically assessed and evaluated by the VISN 01 centralized screening committee and if accepted, referred into one (1) of the treatment specialty beds. A Liaison within VACHS MHRRTP program will be assigned to oversee and assist as in past practice with this contract. Transportation is then arranged for transfer to the program.

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 41 USC §3304(a)(1) as implemented by

RFO 6.103-1;

VHAPG Part 806.3 OFOC Page 2 of 6 Revision: 04 Effective Date: 12/15/25 Acquisition ID#: _36C241-27-AP-0102_

( ) (2) Unusual and Compelling Urgency per 41 USC §3304(a)(2) as implemented by RFO 6.103-2;

( ) (3) Industrial Mobilization, Engineering, Developmental or Research Capability or Expert Services per 41 USC §3304(a)(3) as implemented by RFO 6.103-3;

( ) (4) International Agreement per 41 USC §3304(a)(4) as implemented by RFO 6.103-4

( ) (5) Authorized or Required by Statute per 41 USC §3304(a)(5) as implemented by RFO 6.103-5;

( ) (6) National Security per 41 USC §3304(a)(6) as implemented by RFO 6.103-6;

( ) (7) Public Interest per 41 USC §3304(a)(7) as implemented by RFO 6.103-7;

5. Demonstration that the Contractor’s Unique Qualifications or Nature of the Acquisition Requires the Use of the Authority Cited Above (applicability of authority): Continuum of Care Inc., has extensive experience and a proven track record of successfully supporting Veterans within close geographic proximity to the VA Connecticut Healthcare System, West Haven campus. The services provided by Continuum of Care Inc. allow VACHS Veterans to receive care in a residential-like setting, where they can benefit from clinical programming provided by the VACHS Mental Health RRTP staff and this ease of access is imperative to the veteran’s overall treatment process. The treatment regime includes a comprehensive assessment to develop individualized service plans by utilizing the interdisciplinary team approach in collaborating with the Veteran’s outpatient and other community providers. The services provided include at a minimum, case management and residential support, life skills training that covers areas of cooking, budgeting and personal grooming to maximize independence, as well as learning to make healthy choices; opportunities for socialization through participation in group activities to enhance integration into the community and support in the development of independent skills and interests including employment or other natural supports.

Resulting in the average LOS of 21-28 days for RRTP and 56-63 days for PTSD.

During this comprehensive and coordinated residential care provided by Continuum of Care Inc., the Veterans have structured daily activities that focus on mental health and/or substance abuse recovery needs. Daily and regular on-site supervision and monitoring of Veterans on 24-hour basis. This includes monitoring the needs of the Veterans to ensure while in the RRTP and PTSD beds that they receive the services, care and resources necessary to protect their health, safety and overall well-being.

The incumbent contractor, Continuum of Care Inc. has been providing RRTP and PTSD beds to the VA Connecticut Healthcare System since 2021 under contract #36C24121C0020. Continuum of Care Inc. offers a unique hybrid residential treatment model that integrates VA clinical programming with community-based housing in a home-like environment. This model is tailored to VACHS requirements and is not currently available from other providers in the area. Currently, there is a short-term contract with Continuum of Care Inc. which is due to expire on 10/31/2026 providing similar services.

VHAPG Part 806.3 OFOC Page 3 of 6 Revision: 04 Effective Date: 12/15/25 Acquisition ID#: _36C241-27-AP-0102_

Request for Sole Source Justification Format >SAT

The incumbent contractor’s familiarity with the program and patients ensures continued high-quality care without the inefficiencies and potential risks associated with bringing a new contractor up to speed. This contract will allow for continued services without interruption, which is critical for Veterans enrolled in the RRTP and PTSD residential programs. Interruption of services is not an option due to the clinical and safety needs of the Veterans at VACHS.

The key qualifications that make Continuum of Care Inc. the only responsible source are the contractor’s ability to successfully provide critical care services to Veterans with a consistent record of meeting performance standards for over five (5) years and ensuring continuity of care through case management and residential support as described above. The contractor’s facilities are located within 10-15 minutes of the VACHS West Haven Campus, enabling VA Mental Health (MH) RRTP teams to provide essential on-site clinical programming and oversight. The 10–15 minute drive is required to ensure safe, timely, and effective clinical oversight for Veterans residing in these community-based inpatient RRTP and PTSD beds because the program involves daily coordination between VA MH RRTP teams and the contractor’s facility. These are inpatient beds located at the contractor’s site in which VA MH RRTP teams must be able to reach the residence quickly for routine care, urgent needs, and access to medical records and treatment resources.

VA MH RRTP teams frequently travel to the contractor’s location for scheduled clinical meetings, administrative coordination, and direct interaction with Veterans. In addition, unplanned visits occur when Veterans require immediate assessment or intervention for mental health or medical concerns. Travel times beyond 10–15 minutes would reduce the VA MH RRTP team’s ability to provide timely care, decrease staff availability for onsite treatment obligations at the VA, and increase the clinical risk to Veterans requiring rapid response. Weekly standing meetings occur between Continuum of Care Inc. staff and the VA MH RRTP team at VACHS;

however, VA staff also regularly go to the contractor’s residence to meet with Veterans and Continuum of Care Inc. staff to support treatment planning, crisis intervention, and case coordination. These clinical responsibilities require rapid access to the facility, which can only be achieved within a 10–15-minutes’ drive.

Continuum of Care Inc. has demonstrated having the necessary infrastructure, trained staff, and familiarity with VA protocols to ensure seamless coordination with VA clinical teams immediately upon award, without requiring a transition period.

Continuum of Care Inc. can meet the requirement in its entirety immediately upon award of this contract and no other contractor can satisfy the agency’s needs as defined. Therefore, under 41 USC §3304(a)(1) and RFO 6.103-1(b), Continuum of Care Inc. is the only responsible source capable for this contract.

6. Description of Efforts Made to ensure that offers are solicited from as many potential sources as possible (including whether a notice was or will be publicized as required by RFO Part 5 and, if not, which exception under RFO Part 5 applies): The Mental Health service has done an extensive search to locate facilities that may provide the same and/or comparable residential services within the geographic location area, but none were located that met the emergent standard

VHAPG Part 806.3 OFOC Page 4 of 6 Revision: 04 Effective Date: 12/15/25 Acquisition ID#: _36C241-27-AP-0102_ of care, direct access and geographical requirement to be within 10-15 minutes’ drive to VACHS West Haven Campus, so the MH RRTP Team of providers can assist in overseeing and providing clinical programming to these referred Veterans for improved quality of care. Continuum of Care Inc. has two houses which has housed VACHS two residential programs with VA Site designations for the past five (5)+ years.

The Contracting Officer conducted additional market research by utilizing keywords residential rehabilitation treatment program, NAICS Code: 623220 and Connecticut as location. The Government Database SBA Small Business Search yielded zero (0) results. Prior contracts #36C24121C0020 with period of performance 2/1/2021- 1/31/2026 and #36C24126C0006 with period of performance 2/1/2026-10/31/2026 were reviewed for pricing and service history. Hence, Continuum of Care Inc. is a viable option for the needs to VAMC Connecticut. The Contracting Officer issued a Sources Sought Notice #36C24126Q0462 on 4/27/2026 to identify potential contractors capable of providing RRTP and PTSD beds located within 10–15 minutes of VACHS. The notice generated five responses. After review, it was determined that none of the respondents met the required proximity to VACHS, and therefore no viable sources were identified through this market research effort.

The Connecticut Department of Mental Health and Addiction Services (DMHAS) website was reviewed for potential sources in New Haven, CT, only one was identified named Connecticut Mental Health Center (CMHC) with a total of twenty(20) beds with zero (0) availability.

7. Determination by the CO that the Anticipated Cost to the Government will be Fair and Reasonable: Cost analysis will be conducted by comparing the contractor’s pricing to inpatient Medicare rates, which average over $868.00 per day, and Connecticut rehabilitation costs, which average $641.00 daily. Rates in metro areas such as Hartford and New Haven are typically higher due to demand and operational costs. The Contracting Officer issued a Request for Information (RFI) to Continuum of Care Inc. on 5/11/2026 requesting RRTP and PTSD bed rates, and the vendor responded with the required information.

Continuum of Care Inc. proposed a fixed price of $638.00 BDOC for up to 18 RRTP beds and $938.00 BDOC for 10 PTSD beds, inclusive of nursing, transportation, and room and board for five years. This contract action for the Residential Rehabilitation Treatment Program (RRTP) and Post-Traumatic Stress Disorder (PTSD) beds is designed to ensure continuous service provision without disrupting ongoing care.

The proposed prices are considered fair and reasonable based on a comparison to Medicare rates and in consideration of the additional services included in the requirement. Specifically, the RRTP rate of $638.00 BDOC is below both the average inpatient Medicare rate and the average Connecticut rehabilitation daily cost, while still providing a more comprehensive bundle of services, including nursing and transportation, which are not typically included in standard per-diem rates. The PTSD rate of $938.00 BDOC is justified due to the regular on-site supervision and

VHAPG Part 806.3 OFOC Page 5 of 6 Revision: 04 Effective Date: 12/15/25 Acquisition ID#: _36C241-27-AP-0102_ monitoring of Veterans on 24-hour basis associated with PTSD residential treatment.

Based on this analysis, the price increase is justified and determined fair and reasonable.

In accordance with RFO 6.104-1(a)(7), the Contracting Officer has determined the anticipated cost to be fair and reasonable.

8. Description of the Market Research Conducted and the Results, or a Statement of the Reasons Market Research Was Not Conducted: The Contracting Officer conducted market research using relevant keywords, NAICS Code 623220, and Connecticut as the location in the SBA Small Business Search, yielding zero results.

Prior contracts were reviewed, and a Sources Sought notice was posted, generating five responses; none met the location requirement. DMHAS listings were checked, identifying only CMHC, which had no available beds. Based on this research, Continuum of Care Inc. is the only source capable of meeting the VA's needs. As this is a services requirement, FAR Part 25 BAA considerations do not apply.

Based on RFO 6.103-1, only one responsible source, As described in Section 6 above, market research, in accordance with RFO Part 10, was conducted by synopsis of the proposed acquisition, advising industry of the pending acquisition and soliciting inquiries from interested parties.

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

None

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

The following entities expressed interest in response to the Sources Sought notice, despite being outside the required 10–15 minute radius from VACHS:

Vietnam Veterans Workshop, Inc. (d/b/a New England Center and Home for Veterans) – Boston, MA.

Lincoln Health Services – Woodbridge, VA.

Client Care Continuum LLC – Arley, AL.

BHPE LLC – Oklahoma City, OK.

LoveLynn Solutions, LLC – Dallas, TX.

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: VA will continue to conduct appropriate market research to identify other firms that can meet this requirement, like the steps outlined in Paragraph 8, in order to attempt pursue competitive acquisitions in the future.

12. Requirements Certification: I certify that the requirement outlined in this justification is a Bona Fide Need of the Department of Veterans Affairs and that the supporting data under my cognizance, which are included in the justification, are accurate and complete to the best of my knowledge and belief.

VHAPG Part 806.3 OFOC Page 6 of 6 Revision: 04 Effective Date: 12/15/25 Acquisition ID#: _36C241-27-AP-0102_

Date

Ismene Petrakis Service Chief

VACHS

13. Approvals in accordance with the VHAPM Part 806.3 OFOC SOP:

a. Contracting Officer Certification (required): I certify that the foregoing justification is accurate and complete to the best of my knowledge and belief.

Date

b. One Level Above the Contracting Officer (Required over SAT but not exceeding $900K): I certify the justification meets requirements for other than full and open competition.

Date

Joshua N. Davis Division Chief

NCO 1

c. VHA RPO HCA Review and Approval: I have reviewed the foregoing justification and find it to be complete and accurate to the best of my knowledge and belief and recommend approval (if over $90 million) or approve ($900K to $90 million) for other than full and open competition.

Brent Goe Date Acting Executive Director Head of Contracting Activity Regional Procurement Office - East

ISMENE

PETRAKIS

Digitally signed by

ISMENE PETRAKIS

Date: 2026.06.03 09:37:47 -04'00'

PORTIA FREDUA-

AGYEMANG

Digitally signed by PORTIA

FREDUA-AGYEMANG

Date: 2026.06.04 07:40:04 -04'00'

Portia Fredua-Agyemang Contracting Officer

NCO 1

JOSHUA

DAVIS

Digitally signed by

JOSHUA DAVIS

Date: 2026.06.16 13:46:27 -04'00'