Justification and Approval For Other Than Full and Open Competition KO signed 13 AUG 26.pdf

Request for SDVOSB/VOSB Sole Source Justification Format IAW VAAR 819.7008/9

VHAPG Part 819.7008/7009 Sole Source Awards to SDVOSB/VOSB Page 1 of 7 Revision: 03 Effective Date: 06/15/2024

DEPARTMENT OF VETERANS AFFAIRS

Justification and Approval (J&A) For Other Than Full and Open Competition

Acquisition Plan Action ID: 36C259-26-AP-2197

Contracting Activity: Department of Veterans Affairs, Regional Procurement Office West

RPO-W, 635 Medical Center, 2237 - 635-26-2-1515-0015

1. Nature and/or Description of the Action Being Approved: This procurement is for

Ceiling Mounted Patient Lift Systems and Installation in accordance with FAR 13.5

Simplified Procedures for Certain Commercial Items and specifically FAR 13.501 Special

Documentation Requirements, where acquisitions conducted under Simplified Acquisition

Procedures are exempt from the requirements of FAR Part 6, but still require a justification using the format of FAR 6.303-2. The action under review is the procurement and installation of 18 additional Guldmann GH3+ ceiling lift track systems to integrate with the hospital’s existing infrastructure of 177 Guldmann ceiling lifts already installed. This requirement will be awarded as a new stand-alone contract, not as a modification to an existing agreement, because the additional track systems constitute new installation work and new material procurement beyond the scope of previous contracts. The planned contract type for this action is Firm-Fixed-Price (FFP), consistent with the commercial-item nature of the

Guldmann lift systems, the predictable installation scope, and FAR Part 13.5 simplified procedures for certain commercial products and services. The FFP structure is appropriate because the specifications, quantities, and installation requirements are well-defined, commercially available, and supported by stable market pricing and OEM installation standards.

2. Description of Supplies/Services Required to Meet the Agency’s Needs: The action involves the procurement and installation of 18 additional Guldmann GH3+ ceiling lift track systems to expand the facility’s existing network of 177 installed Guldmann lifts. The supplies include A1200 Overhead Rails and Combi-Lock Systems (11 units), A1200A

Bariatric H-Track Systems (6 units), and A1203 Bariatric Overhead Track and Combi-Lock

System (1 unit), all of which are required to be the newest, current-production commercial models from a manufacturer of record meeting VA engineering, documentation, and lifecycle support requirements. The total estimated value of this acquisition—including installation services, materials, and all associated options—is $422,750.00. Installation services include complete OEM-compliant ceiling track mounting, integration with existing charging liners, installation of Government-furnished current Guldmann lifts. All equipment and services must comply with the VA Electronic Health Record Modernization (EHRM)

Standardization Memorandum dated March 6, 2025 (VIEWS 12862405), which mandates that all new patient-handling devices align with standardized VA clinical workflows and documentation requirements. The estimated period of performance for delivery and installation is 45 days after contract award, allowing time for OEM fabrication, freight scheduling, site preparation, ceiling interface work, and final commissioning.

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3. Statutory Authority Permitting Other than Full and Open Competition: 41 USC

§3304(a)(5), 38 U.S. Code § 8127(c), as implemented by FAR 6.302-5 (Authorized or

Required by Statute). COs may use the non-competitive (sole source) procedures authorized in VAAR 819.7008 (DEVIATION) or VAAR 819.7009 (DEVIATION) up to $5,000,000.

Check the specific VAAR clause used below:

(X) 819.7008 Sole source awards to a certified service-disabled veteran-owned small business; or

( ) 819.7009 Sole source awards to a certified veteran-owned small business

4. Demonstration that the Contractor’s Unique Qualifications and/or Nature of the

Acquisition Requires the Use of the Authority Cited Above (applicability of authority):

The action being reviewed is the procurement and installation of 18 additional Guldmann

GH3+ ceiling lift track systems required to integrate seamlessly with the facility’s existing network of 177 Guldmann ceiling‐mounted patient lifts already installed throughout the hospital. Market research demonstrates that only Guldmann GH3+ track and lift components meet the agency’s mandatory technical, functional, structural, and interoperability requirements. Because ceiling lift systems function as fixed medical infrastructure, the newly required track systems must be fully compatible with the existing installed lift motors, slings, charging rails, and safety systems. Any deviation from manufacturer-specific components would create incompatibility in charging interfaces, safety features, load ratings, and track geometry, resulting in significant patient-handling risk and non-compliance with VA engineering and patient‐safety standards. Therefore, the requirement directly satisfies the

FAR conditions permitting a Brand Name acquisition when standardization, interoperability, and safety considerations mandate a specific product.

The need for strict product uniformity is further reinforced by the VA Electronic Health

Record Modernization (EHRM) Standardization Memorandum dated March 6, 2025, which requires that all new patient‐handling equipment in the facility support consistent documentation workflows, standardized weight-measurement interfaces, and uniform data inputs. The Guldmann GH3+ system includes an integrated Class III scale and digital controls whose output and operation are already embedded in the hospital’s workflows and clinical documentation processes. Introducing alternate or non-compatible lift systems would disrupt EHRM compliance, require additional training, and create operational and documentation inconsistencies.

Market research further shows that Guldmann is the only manufacturer of record capable of providing the required ceiling lift track systems, and that the systems meet FAR 2.101 commercial-item definitions. The manufacturer maintains an active production line, engineering documentation, stocked replacement parts, and current-model production, satisfying Government requirements for lifecycle maintainability and long-term support. No other manufacturer’s products can be used to expand the existing infrastructure without requiring full system replacement, which would result in duplicative expenditures and violate

FAR requirements relating to cost-effectiveness and avoidance of unnecessary duplication.

https://www.va.gov/oal/docs/business/pps/deviationVaar20230216.pdf https://www.va.gov/oal/docs/business/pps/deviationVaar20230216.pdf

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In accordance with Veterans First Contracting Program (38 U.S.C. 8127) and FAR 13.5 simplified procedures for certain commercial products and services, market research identified Premier Medical Distributors, LLC as a qualified Service-Disabled

Veteran-Owned Small Business (SDVOSB) that is authorized by Guldmann to distribute, install, and maintain GH3+ systems. Premier Medical Distributors has verified capability and past performance supporting installation of Guldmann systems across numerous VA medical centers. Because the requirement is both manufacturer-specific and installation-specific, and because the OEM recognizes Premier Medical Distributors as an authorized SDVOSB installer and distributor, the conditions supporting Veterans First SDVOSB preference under

VAAR 819.7007 and 819.7008 are fully met.

5. Description of Efforts Made to ensure that offers are solicited from as many potential sources as deemed practicable, including whether a notice was or will be publicized as required by FAR Subpart 5.2 and, if not, which exception under FAR 5.202 applies:

In accordance with FAR Part 5 and VAAR Part 810, the contracting officer undertook all practicable efforts to identify capable sources for this acquisition. The VA Rule of Two was applied as required under 38 U.S.C. §8127, PPM 2016-05 (Revised Aug 2019), and VAAR

Class Deviation 810.001-70, which mandates review of the Vendor Information Pages (VIP) database to identify verified SDVOSBs/VOSBs under the applicable NAICS code. A comprehensive VIP search was conducted and documented in the contract file; this search identified only one responsible SDVOSB source, Premier Medical Distributors, LLC, capable of performing OEM-authorized installation of Guldmann GH3+ ceiling lift systems.

No other verified SDVOSB or VOSB possessed OEM authorization, installation certification, or demonstrated capability to meet interoperability requirements with the existing 177 Guldmann lift systems already installed at the facility.

To ensure maximum practicable competition, the contracting officer also reviewed prior procurement records—including SDVOSB set-aside awards involving Guldmann lift systems—and confirmed that Premier Medical Distributors remains the sole SDVOSB authorized by Guldmann to provide the required equipment and installation services. Because this is an SDVOSB sole-source action under VAAR 819.7007/7008 (permitted up to

$5,000,000), public posting is not required under FAR 5.2. The applicable exception is FAR

5.202(a)(4), which exempts noncompetitive SDVOSB awards made under agency-specific statutory authority. As required by Veterans First policy, the contracting officer verified that no other responsible SDVOSB concern has been identified.

Sources Sought Synopsis

No Sources Sought Notice was issued because preliminary market research and VIP database verification confirmed that only one SDVOSB—Premier Medical Distributors, LLC—could meet the manufacturer-authorization requirement and the mandatory interoperability https://www.acquisition.gov/far/part-5#FAR_Subpart_5_2 https://www.acquisition.gov/far/part-5#FAR_5_202

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Effective Date: 06/15/2024 specifications. Issuing a Sources Sought would not have produced additional capable

SDVOSB sources and would have delayed fulfillment of a critical patient-handling requirement without any benefit. Therefore, consistent with FAR 10.001(a)(2)(iii) and

Veterans First guidance, the contracting officer determined that a Sources Sought notice was not practicable.

These actions collectively demonstrate that opportunities were made available to the broadest number of certified SDVOSBs practicable under the circumstances, and that the sole-source determination is justified, appropriate, and fully compliant with FAR, VAAR, and Veterans

First statutory requirements.

6. Determination by the CO that the Anticipated Cost to the Government will be Fair and

Reasonable:

The Contracting Officer (CO) has determined that the anticipated cost for this acquisition— estimated at $422,750.00—will be fair and reasonable based on multiple price-analysis methods consistent with FAR 13.106-3(a) and the commercial-item procedures of FAR

Subpart 13.5. To ensure reasonableness, the CO evaluated historical pricing for comparable

Guldmann ceiling lift procurements previously awarded by the Department of Veterans

Affairs, including Purchase Orders 36C25225P0588, 36C24625P1307, and other awards involving Guldmann ceiling-mounted patient lift systems. These prior procurements demonstrate consistent market pricing for GH3/GH3+ systems, installation labor, and associated track components, providing a valid benchmark against which the proposed price may be compared. Additionally, the CO reviewed available commercial catalog pricing from the manufacturer of record (Guldmann) and verified that Premier Medical Distributors, LLC—an authorized SDVOSB distributor—offers prices aligned with prevailing commercial rates.

Based on these steps—historical price comparison, catalog price review, SDVOSB quotation analysis, independent Government estimate verification, and technical review—the CO affirms that the final negotiated price will be deemed fair and reasonable, fully satisfying the requirements of FAR 6.303-2(b)(7).

7. Description of the Market Research Conducted and the Results, or a Statement of the

Reasons Market Research Was Not Conducted: Market research was conducted in accordance with FAR Part 10, VAAR Part 810, and VHAPG Part 810.001, including a mandatory review of the Vendor Information Pages (VIP) database required under the

Veterans First Contracting Program. VIP searches using NAICS 339112 and 339113 to determine whether two or more verified SDVOSBs or VOSBs could provide and install the required Guldmann GH3+ ceiling lift track. The search identified one SDVOSB—Premier

Medical Distributors, LLC—verified in VetCert and fully meeting the eligibility criteria under VAAR 819.7003 (Deviation) for SDVOSB status, including active registration in

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SAM.gov (UEI NXG6V8L9SY13, CAGE 8HVU5) and current VetCert verification (expires

January 28, 2027). Premier Medical Distributors was also confirmed through federal award data as an experienced VA supplier of Guldmann ceiling lift systems, including awards such as 36C25225P0588 and 36C24625P1307, demonstrating capability and past performance in lift installation and replacement requirements. The market research further determined that no other SDVOSB or VOSB in VIP possessed OEM authorization or certified installer credentials required to maintain Guldmann system compatibility, warranty integrity, and safety compliance. VA historical procurement records were reviewed, including previous

SDVOSB set‑asides for Guldmann ceiling lift maintenance and installation (e.g., VA247‑16‑R‑1225), which again confirmed that OEM installation requirements restrict viable sources to Premier Medical Distributors. Because only one responsible SDVOSB was identified, the Rule of Two cannot be met, and the requirement qualifies for SDVOSB sole‑source procedures under VAAR 819.7007/819.7008.

8. Any Other Facts Supporting the Use of Other than Full and Open Competition: None.

The authority for this action is 38 U.S.C. 8127(c), which permits awards to verified

Service‑Disabled Veteran‑Owned Small Businesses (SDVOSBs) when the conditions of the statute are met.

9. Listing of Sources that Expressed, in Writing, an Interest in the Acquisition: Market research conducted in accordance with FAR Part 10 and VAAR Part 810 identified one verified and capable source that formally expressed interest in this acquisition: Premier

Medical Distributors, LLC, an actively registered Service‑Disabled Veteran‑Owned Small

Business (SDVOSB). Premier Medical Distributors, LLC is listed in the VA Vendor

Information Pages (VIP) database as verified under NAICS 339112 and 339113 and is recognized by the OEM (Guldmann) as an authorized distributor and installer of GH3+ ceiling lift systems. The firm maintains an active SAM.gov registration, with UEI

NXG6V8L9SY13, CAGE 8HVU5, and a registration expiration date of January 28, 2027, confirming continued eligibility to participate in federal contracting. Their physical address is

141 Chapel Ridge Cir, Myrtle Beach, SC 29588–5506, United States, and they have performed multiple prior VA contracts involving Guldmann equipment. No other SDVOSB or VOSB sources—verified in VIP and possessing OEM authorization—responded or were identified as capable of performing this requirement. Therefore, Premier Medical

Distributors, LLC is the sole source expressing interest and demonstrated capability to fulfill the Government’s needs for this acquisition.

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: At this time, no actions are planned to foster competition for future acquisitions of these supplies or services. The barriers to competition identified in this justification—specifically the proprietary and non‑interoperable nature of Guldmann GH3+ ceiling lift systems, the facility’s existing investment in 177 installed Guldmann units, mandatory compatibility with the current infrastructure, and EHRM standardization requirements—cannot be feasibly removed without causing substantial duplication of cost or unacceptable delays. Because the additional track systems must fully integrate with the existing Guldmann lift network, the Government’s minimum needs cannot be met by any alternative manufacturer now or in the foreseeable future. Additionally, due to the proprietary

VHAPG Part 819.7008/7009 Sole Source Awards to SDVOSB/VOSB Page 6 of 7 Revision: 03 Effective Date: 06/15/2024 installation certification required to maintain warranty and safety compliance, no viable pathway exists to broaden competition without replacing the entire installed system—an action that is neither cost‑effective nor operationally practicable. As a result, no competitive follow‑on acquisition is anticipated, and no future competition‑enhancement milestones will be developed. The agency will continue routine market monitoring, but based on current requirements and constraints, competition for this requirement—and similar follow‑on requirements—cannot be fostered at this time.

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.

Date

Everett A. Heuer

Program Specialist Oklahoma City – OR & SICU Renovation

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

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

Gerald Wright Date

Contracting Officer

RPO-W

b. One Level Above the Contracting Officer (Required over the SAT but not exceeding $750K): I certify the justification meets requirements for other than full and open competition.

Jeffery Crysler Date

Branch Chief

RPO-W

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