FY25 JOFOC NCO 19 Altus CBOC - Redacted.pdf

Effective Date: 02/01/2022 Page 2 of 4

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 Altus, Oklahoma. With a required start date of October 1, 2024, the incumbent contractor, Valor Healthcare Inc is the only source in the position to provide all the requirements of the PWS. Valor Healthcare, Inc 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 of October 1, 2024.

There are no other sources with CBOC capabilities located in the Altus 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 undergoing source selection review.

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 six (6) 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 on contracting opportunities, sam.gov. Market research was conducted through 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 Oklahoma from VetCert. The DSBS

Effective Date: 02/01/2022 Page 3 of 4 search performed under NAICS 621498 and location for Jackson 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.

Valor Healthcare, Inc is the only source capable of providing continuity of services within the limited period before contract expiration. 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 Altus 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 to the incumbent, Valor Healthcare, Inc 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.

Date Business Manager Oklahoma City VA Health Care System

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

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.

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.

Branch Chief, Health Care Resources, NCO 19

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.

Executive Director, Regional Procurement Office West Head of Contracting Activity (HCA)