P03-JA Radiopharmaceuticals CAVHS.pdf

(>SAT) 6.103 - Justification Other Than Full and Open Competition

VHAPG Part 806.3 OFOC Page 1 of 3 Revision: 03 Effective Date: 04/15/24 Acquisition ID#: __________________

DEPARTMENT OF VETERANS AFFAIRS

Justification and Approval (J&A) For

Other Than Full and Open Competition (>SAT)

This justification aligns with the deviation outlined in the Revolutionary FAR Overhaul (RFO) for Part 6 - Competition Requirements, as required by Executive Order (E.O.) 14275, Restoring Common Sense to Federal Procurement, signed April 15, 2025. Deviation effective date: July 22, 2025.

Acquisition Plan Action ID: 619-27-1-7114-0003

1. Contracting Activity: Department of Veterans Affairs, VISN 07, Central Alabama Veterans Health

Care System (CAVHCS), Montgomery, AL

2. Nature and/or Description of the Action Being Processed: Central Alabama Veteran’s Healthcare System’s VA Medical Center (CAVHCS) Montgomery, AL requires a contractor to provide the unit dose Radiopharmaceuticals used by the Nuclear Medicine Imaging department, during normal working hours.

3. Description of Supplies/Services Required to Meet the Agency’s Needs: Contractor will furnish (including packaging, transportation, manifests and reports) all Nuclear Medicine radiopharmaceuticals ordered from the the Schedule of Supplies to the Central Alabama Veterans Healthcare System, 215 Perry Hill Road, Montgomery, AL 36116 for the period of performance October 1, 2026 through September 30, 3031. These are radiopoharmaceuticals supplies used in Nuclear Medicine to performan exams on patients.

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 FAR 6.103-1;

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

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

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

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

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

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

VHAPG Part 806.3 OFOC Page 2 of 3

Acquisition ID#: __________________

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

The specific radiopharmaceuticals have been determined by CAVHCS’s physicians and nuclear medicine staff to best meet the needs of the veteran population at the Montgomery VAMC. Based on the market research, Southeast Apothecary, Inc. is currently the only vendor capable of providing all the required radiopharmaceuticals and 30 minute to 1 hour delivery requirements.

Southeast Apothecary, LLC is a local small business manufacturer and distributor.

5. Description of Efforts Made to ensure that offers are solicited from as many potential sources as deemed practicable: Market research was conducted, details of which are in the market research section of this document. This effort did not yield any additional sources that can meet all the Government’s requirements. There is no competition anticipated for this acquisition.

6. Determination by the CO that the Anticipated Cost to the Government will be Fair and Reasonable: Market research conducted determined pricing fair and reasonable based on a comparison of proposed pricing to historical prices from Southeast Apothecary, Inc. for the radiopharmaceuticals.

7. Description of the Market Research Conducted and the Results, or a Statement of the Reasons Market Research Was Not Conducted: Search of VetCert using radiopharmaceuticals resulted in zero vendors within the required distance from the facility.

Searches were also conducted via google search. Searches of GSA Ebuy yielded zero results.

8. Any Other Facts Supporting the Use of Other than Full and Open Competition: There are no other supporting facts.

9. Listing of Sources that Expressed, in Writing, an Interest in the Acquisition: N/A

Southeast Apothecary Inc.

2032 Poplar Street Montgomery, AL 36106

10. 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: The proposed contract action is for a period of one base year, plus 4 option years. After the one year, the market will be surveyed to determine if there are other sources that could lead to a competitive procurement.

VHAPG Part 806.3 OFOC Page 3 of 3

Acquisition ID#: __________________

11. 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.

Nanal Clements Nuclear Medicine Supervisor, COR II Date

CAVHCS

12. 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.

Michelle Bocage Date Contracting Officer

NCO 07

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.

Robert Anthony Stephens Date Branch Chief

NCO 07

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