P03 JA Over SAT Teleradiology.pdf

DEPARTMENT OF VETERANS AFFAIRS

Justification and Approval (J&A) For

Other Than Full and Open Competition (>SAT)

Acquisition Plan Action ID:

1. Contracting Activity: Department of Veterans Affairs, VISN 10, Dayton VA Medical

Center, 4100 W. Third Street, Dayton, OH 45428. This action will be funded through

PR-IFCAP#

2. Nature and/or Description of the Action Being Approved: This action is a new requirement for offsite teleradiology services to ensure compliance for timely interpretation of diagnostic imaging studies for DVAMC beneficiaries. The VA OIG’s National Teleradiology Program (NTP) review substantiated delays in stat imaging interpretation and broader turnaround shortfalls, reinforcing the need for immediate, reliable coverage at local facilities when enterprise capacity is constrained.

This requirement seeks commercial teleradiology services to supplement the workload of Dayton VAMC and NTP radiologists. Current study volume exceeds local capacity, and NTP has been unable to absorb excess exams, particularly during off-hours. Due to the clinical urgency and national policy benchmarks, the DVAMC must restore compliance with imaging turnaround times. Required interpretation timeframes are:

• Stroke protocol CT: within 15 minutes

• STAT: within 1 hour

• Urgent: within 2 hours

• Routine: within 48 hours

NTP has not been able to meet these metrics, and in-house radiologists also cannot meet the 48-hour routine requirement, creating patient safety risks. Hundreds of exams remain unread, most exceeding 48 hours. Hiring additional radiologists is not feasible due to a national shortage and significant pay disparities, Additionally, further constraint have arose with the Federal EHR (FEHR) baseline onboarding procedures. DVAMC transitioned to Oracle Health in June 2026, and under FEHR baseline/standardization, commercial teleradiology providers must complete Federal Baseline approval before interpreting exams. The estimated vendor approval process is approximately 24 months, with approximately 12 to 15 months required to achieve Federal Baseline inclusion. The DVAMC cannot defer urgent teleradiology coverage for this long without risking clinical operations and patient safety.

3. Description of Supplies/Services Required to Meet the Agency’s Needs: The need exists for a teleradiology provider that can provide specialty and subspecialty interpretations of Diagnostic Imaging procedures as a 24/7/365 service. The contractor will act as an overflow outlet during the hours of 0700-1900 Monday through Friday and may be the primary service for the hours of 1900-0700 Monday through Friday, Federal Holidays, and weekends.

This requirement is for a one (1) year sole source contract with VetMed Group, LLC. The anticipated period of performance is December 1, 2026 through November 30, 2027.

The contract includes clause FAR 52.217-8 – Option to Extend Services. If an option is exercised under this clause, the specified rates will be the current rate in effect under the contract at the time the option is exercised.

Estimated quantity:

Estimated cost:

Reimbursement will be based on work relative value units wRVUs using Active (A) codes and modifier 26 values. Every CPT code has a corresponding wRVU value. This contract only uses wRVU values which are Active as indicated by an A. There are three

(3) wRVU components listed, the technical component would be the value for performing the exam, the value to interpret the exam (indicated by procedure modifier 26), and the total of the two. For teleradiology services, the contractor only receives the value indicated by the 26 modifiers.

4. Statutory Authority Permitting Other than Full and Open Competition: 41 USC §3304(a)(5), 38 U.S. Code § 8127(c), as implemented by FAR 12.102 Restricting Competition. 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

5. Demonstration that the Contractor’s Unique Qualifications or Nature of the Acquisition Requires the Use of the Authority Cited Above (applicability of authority): A contracting officer may award a contract to a certified service-disabled veteran-owned small business (SDVOSB) listed in the SBA certification database using other than competitive procedures provided—

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

(2) The requirement is synopsized and the required justification pursuant to FAR 6.302-5(c)(2)(ii) is posted in accordance with FAR part 5;

(3) The SDVOSB has been determined to be a responsible contractor with respect to performance; and

(4) 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.

The anticipated award price (including options) will not exceed $5 million. The justification for other than full and open competition will be published pursuant to and in accordance with FAR 6.302-5(c)(2)(ii) and FAR part 5. VetMed Group, LLC is certified as an SDVOSB in the Small Business Administration’s (SBA) Small Business Search (SBS) https://search.certifications.sba.gov/, and they are a responsible contractor with respect to performance. 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.

In addition to the above, VetMed is uniquely qualified for the sole source contract due to already being an approved vendor in the Federal Baseline Standardization. This company also has extensive experience with providing teleradiology services and they are capable of meeting the DVAMV’s requirements expeditiously.

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):

Sources sought notice 36C25026Q0268 was issued for this requirement, resulting in nine responses. Subsequently, solicitation 36C25026Q0444 was issued as a 100% set aside for SDVOSB companies. However, the DVAMC received information after the issuance of the solicitation of additional procedural and technical requirements associated with onboarding and approving a teleradiology vendor, due to Dayton VAMC’s transition to Oracle Health electronic health record (EHR) system. These requirements include compliance with standards necessary for inclusion on the Federal Baseline for Standardization requirement. This requirement and the associated timeline materially affected the solicitation’s scope and anticipated performance schedule and no longer accurately reflected the Government’s requirement; therefore, the solicitation was cancelled. None of the sources captured in the sources sought notice or solicitation have the Federal Baseline Standardization approval other than VetMed Group, LLC.

7. Determination by the CO that the Anticipated Cost to the Government will be Fair and Reasonable: The Contracting Officer will determine the price to be fair and reasonable based on historical pricing from NTP, comparing the vendor’s quoted price to the IGCE and other recently awarded teleradiology contracts from VetMed Group, 36C25025D0038 and 36C260P0684. Further, as mentioned above, the VHA National Teleradiology Program bills by CPT code. DVAMC converted prior NTP CPT volumes to wRVUs using CMS values, The CPT code data for Fiscal Year 2025 was used along with the 2026 wRVU values corresponding to each CPT code. This data was used to derive NTPs cost per wRVU for

. This analysis shows that paying a teleradiology service provider on a per wRVU basis is most cost effective and allows comparison of prices using the “apples to apples” technique.

8. Description of the Market Research Conducted and the Results, or a Statement of the Reasons Market Research Was Not Conducted: Market research was conducted through SBA SBS (VetCert) under NAICS Code 621512 and keyword “teleradiolgy” and resulted in 18 small business including four (4) SDVOSB and five (5) VOSB businesses.

Sources sought notice 36C25026Q0268 resulted in six (6) SDVOSB responses and a subsequent 100% set-aside solicitation 36C25026Q0444 was issued which resulted in

. Due to the new requirement for Federal Baseline for Standardization, the solicitation was cancelled. This new requirement has severely limited the number of vendors that are readily available and capable to perform the teleradiology services upon contract award.

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

Technical integration and compliance. DVAMC requires contractors with MPLS-capable, VAEC-compatible connectivity, HL7 direct-to-EHR report upload, DICOM conformance, HIPAA compliance, and enterprise quality monitoring (peer review, OPPE/FPPE). Developing and accrediting these interfaces for new entrants would cause unacceptable delays and duplication of effort, precluding timely restoration of clinical service levels.

The DVAMC requires a company with the capabilities, experience, and necessary approvals to immediately begin operations and restore the VAMC’s teleradiology program to compliance.

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

VetMed Group, LLC 393 NE 5th Ave., Unit B Delray Beach, FL 33483