FY25 JOFOC NCO 19 Ada CBOC-Redacted.pdf

Effective Date: 02/01/2022 Page 1 of 4

DEPARTMENT OF VETERANS AFFAIRS

SOLE SOURCE JUSTIFICATION UNDER SIMPLIFIED PROCEDURES FOR CERTAIN COMMERCIAL ITEMS IN

ACCORDANCE WITH FAR 13.5

Acquisition Plan Action ID: 36C259-24-AP-4581 JOFOC Tracking Number: FY25 - NCO 19 - 39

1. Contracting Activity: Department of Veterans Affairs, VISN 19, Rocky Mountain Acquisition Center, NCO 19, 6162 South Willow Drive, Suite 300, Greenwood Village, CO 80111 on behalf of Department of Veterans Affairs Oklahoma City Health Care System (OKC VAHCS). 921 NE 13th ST Oklahoma City, Oklahoma 73104. 2237 number: 635-25-1-409-0006.

2. Nature and/or Description of the Action Being Processed: This procurement is for Community

Based Outpatient Clinic (CBOC) Primary Care Services and Tele-Mental Health Services 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 OKC VAHCS requires Community Based Outpatient Clinic (CBOC) Primary Care Services and Tele- Mental Health Services. The medical center estimates a panel size of 1826 Veterans per month. The contractor shall provide a professional medical staff and CBOC solely dedicated to Veterans. This is a short-term contract for continued Veteran care while a long-term contract is being procured. The contract will be awarded as a new contract. The type of contract planned is firm-fixed-price Indefinite Delivery Indefinite Quantity (IDIQ) contract. Services are currently being provided under IDIQ contract 36C25924D0001 for Period of Performance, October 1, 2023 – September 30, 2024.

3. Description of Supplies/Services Required to Meet the Agency’s Needs: The OKC VAHCS requires

CBOC services providing Patient Aligned Care Team (PACT) - Primary Care Services in a private clinic environment to Veterans, primarily Ada, Oklahoma. The Contractor is required to meet VHA performance and quality criteria and standards including, but not limited to, customer satisfaction.

The contract allows for telehealth services to be provided on site via tele-health with VA staff. The care provided by the Contractor should be patient centered, continuous, accessible, coordinated, and consistent with VA standards.

Description EST.

QTY

PMPM EST.

MONTHLY

TOTAL

EST. TOTAL

Ada CBOC Services Base Period

October 1, 2024 – March 31, 2025

1826 $93.02 $169,854.52 $1,019,127.12

Total Estimated Contract Value $1,019,127.12

This contract action will have a fixed-price six (6) month base performance period from October 1, 2024, through March 31, 2025. It is estimated that 1826 Veteran enrollees may visit the clinic each month over the base period at a cost of $93.02 per member per month (PMPM). The short-term contract will include Federal Acquisition Regulation (FAR) clause 52.217-8 Option to Extend Services.

If executed, the period of performance could be extended to September 30, 2025. The specified rates under this clause will be those rates in effect under the contract each time an option is exercised under this clause.

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4. Statutory Authority Permitting Restricted Competition:

FAR 13.5 Simplified Procedures for Certain Commercial Items. The statutory authority for applying the Simplified Procedures for Commercial Items of FAR 13.5 is 41 U.S.C. § 1901 and is implemented by FAR 13.106-1(b)(2) for restricting competition on this procurement. Competition is restricted on this procurement for the reason below:

(X ) Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements

( ) Unusual and Compelling Urgency ( ) Industrial Mobilization, Engineering, Developmental or Research Capability or Expert

Services ( ) International Agreement ( ) Authorized or Required by Statute ( ) National Security ( ) Public Interest

5. Demonstration that the Contractor’s Unique Qualifications or Nature of the Acquisition Requires the Use of the Authority Cited Above (applicability of authority): The services required by this procurement are essential to the continued patient care of the Veterans primarily residing in Ada, Oklahoma. With a required start date of October 1, 2024, the incumbent contractor, Bruce W.

Dennis M.D., P.L.L.C is the only source in the position to provide all the requirements of the PWS.

Bruce W. Dennis M.D., P.L.L.C has the appropriated staff, systems and facility equipped to provide the continuity of highly specialized services to the Veterans in the area thus avoiding unacceptable delays in fulfilling the agency’s requirements by the need date.

There are no other sources with CBOC capabilities located in the Ada Oklahoma area that can provide the existing services in the required time frame. A new CBOC contractor will need a fully credentialed staff and suitable facility that meet PACT standard prior to providing care to the

Veterans. Credentialing new personnel is taking three to six months; however, the facilities have been experiencing delays. Further, setting up a new CBOC would take up to six months after award to set up. Therefore, there is insufficient time to accomplish this prior to the need date of October 1, 2024.

6. Description of Efforts Made to ensure that offers are solicited from as many potential sources as deemed practicable: A long term competitive requirement is being currently being evaluated for award. This short-term interim contract will ensure continued services until the long-term acquisition is awarded.

7. Determination by the CO that the Anticipated Cost to the Government will be Fair and Reasonable:

The Contracting Officer will determine that the anticipated cost to be fair and reasonable based on current contract pricing, IGCE and United States Bureau of Labor Statistics (BLS) employment cost index rate of 3.7% for Oklahoma Region for the 6 (six) month contract period.

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 June – August 2024 using Veteran Small business Certification (VetCert) and Dynamic Small Business Search (DSBS) for this short term. The VetCert identified 265 Service Disabled Veteran Owned Small Business (SDVOSB) and Veteran Owned Small Businesses (VOSB) under North American Industry Classification System (NAICS) 621498, All Other Outpatient Care Centers; Cole International, Inc., and Howard Construction Company and Central Contracting LLC, were two SDVOSB companies identified in

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Oklahoma from VetCert. The DSBS search performed under NAICS 621498 and location for Pontotoc County Oklahoma resulted with no SDVOSBs or VOSBs.

VA Rule of Two, was conducted through review of the VETCERT database and DSBS to determine if two or more SDVOSBs and VOSBs could provide services. The rule of two could not be met because there are no SDVOSBs and VOSBs with capability in Oklahoma to stand up a CBOC in the time-frame required for services.

Bruce W. Dennis M.D., P.L.L.C is the only source capable of providing continuity of services within the limited period before contract expiration date of September 30, 2024. Any change in contractor support at this time is not feasible as the process would require the new contractor to locate and build-out a new facility, recruit and hire staffing, undergo VA background checks, and complete credentialing, which is not realistic given the timeframe of current services expiring on September 30, 2024. A new contractor will need at least six (6) months to provide a fully operational CBOC in Ada Oklahoma once a location has been selected.

9. Any Other Facts Supporting the Use of Other than Full and Open Competition: This requirement is for a follow-on, short-term contract to provide continuity of CBOC services to veteran beneficiaries for the period of October 1, 2024 - March 31, 2025. This short-term contract will allow for sufficient time, as required per the PWS, for the build-out and start-up of the new clinic.

This requirement is being procured on a sole source basis to the incumbent, Bruce W. Dennis M.D., P.L.L.C to allow uninterrupted primary care services.

10. Listing of Sources that Expressed, in Writing, an Interest in the Acquisition: This procurement is anticipated to be sole sourced to the incumbent.

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: A long-term competitive solicitation for an SDVOSB set-aside has been issued. This will remove barriers to competition.

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.

Karli Bacon Date Business Manager Oklahoma City VA Health Care System

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13. 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.

Patricia Toliver Date Contracting Officer Network Contracting Office 19

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

Yomika Brock Date Branch Chief, Health Care Resources, NCO 19

Michelle T. Gray Date Director of Contracting, NCO 19

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 approve ($750K to $7.5 million (or $15.0 million for acquisitions described in FAR 13.500(c)) for other than full and open competition.

Curtis M. Jordan Date Executive Director, Regional Procurement Office West Head of Contracting Activity (HCA) https://dvagov.sharepoint.com/sites/VHAProcurement/VHAPM/VHAPM_Part_806.3.aspx