Limiting Source Justification.docx

Attachment 1: Justification for Limiting Sources for Micro-Purchase Threshold up to the SAT

DEPARTMENT OF VETERANS AFFAIRS

GSAR 538.7104-3 – Justification for Limiting Sources (LSJ) For Limiting Sources (<SAT)

Acquisition Plan Action ID: 36C250-26-AP-1723

1. Contracting Activity: Department of Veterans Affairs, Network Contracting Office 10 located at 260 E University Avenue, Cincinnati, OH 45219-2356, in support of VISN 10, Richard L. Roudebush (RLR) VA Medical Center (VAMC), 1481 West 10th Street, Indianapolis, IN 46202-2803. 2237 #s: 583-26-1-997-0036 and 583-26-1-997-0038.

2. Description of Action: This new, one-time procurement from the Neurology Service and Physical Medicine and Rehabilitation Service (PMRS) at the Richard L Roudebush VA Medical Center (RLR VAMC) is required to update existing Electromyography (EMG) equipment and software for the EMG equipment in preparation for the transition to the Cerner Electronic Health Record Modernization (EHRM) system.

Order against: |X| FSS Contract Number: 36F79718D0330

3. Description of Supplies or Services: To ensure compatibility and seamless integration with the new Cerner system to maintain and enhance the quality of patient care, the following equipment/products and services are required.

Market research was conducted using SBA SBS, FPDS-NG, SAM.gov, ADDS UP, VA NAC databases and other sources. Numerous acquisitions were found to be awarded to Natus Medical Incorporated, a large business and the original equipment manufacturer (OEM). Only one FSS contract, 36F79718D0330 was found. It is awarded to the OEM

An email was sent to Natus’ District Sales Manager for EMG, EEG, & Ultrasound on 01/09/2026. He replied and confirmed that the country of origin (COO) for the needed equipment is the United States of America. They have one (1) SBA SBS verified SDVOSB reseller for its products; however, all field service engineers responsible for installing the EMG systems, consultants conducting needed training for the clinicians, the technical support teams, and warranty needs are provided only by Natus. He also confirmed that their FSS contract offers the VA the best pricing available.

No other SD/VOSBs or any SBs were found that are capable of successfully meeting this requirement. VA FSS contracts are preferred sources of supply. The VA and SBA Rules of Two are not attainable. The product NAICS code is included in the NMR Class Waiver database.

4. Rationale/explanation to support cited authority: The EMG equipment at the facility is brand name equipment considered to be the gold standard in EMG testing for over 40+ years. The current models are no longer supported for security updates, nor will they be compatible with the impending EHRM. The proposed action is to provide the service for an interface of existing EMG equipment to the new EHR, Cerner. These are required upgrades that must occur before this integration can be implemented. The contractor will ensure that the interface developed communicates effectively with the VHA Cerner Baseline and the VISN 10 Natus systems.

Any upgrades to the equipment for compatibility with the existing equipment must be performed by the OEM. Based on market research findings there are no SD/VOSBs or other SBs available for this request. The VA and SBA Rules of Two cannot be met. It is recommended that a sole source delivery order to Natus Medical Incorporated under FSS contract 36F79718D0330 be awarded to obtain the best value for the Government.

5. Note that this determination satisfies the requirements RFO FAR 8.401 and GSAR 538.71. I understand that processing of this justification restricts consideration of Federal Supply Schedule contractors in accordance with RFO 6.103-1(d).

VHAPG Part 808.405-6 Limiting Sources Page 1 of 3 Revision: 01 Effective Date: 09/01/2024 Acquisition ID#: 36C250-26-AP-1723