Sole Source Justification Labcorp 26-AP-3067 final.pdf
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- Solicitation number
- 36C25926F0235
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This is a Sole Source Justification document for a Federal Supply Schedule (FSS) Task Order issued by the Department of Veterans Affairs Network Contracting Office 19. The acquisition (36C259-26-AP-3143) seeks to award a three-month follow-on task order to Laboratory Corporation of America (Labcorp) for reference laboratory testing services supporting the Oklahoma City VA Health Care System and Salt Lake City VA Health Care System. The services include courier pickup of patient samples, CLIA-approved laboratory testing on FDA-approved instrumentation, and return of diagnostic test results to VA laboratories. The contractor will provide services across 13 special item number (SIN) categories under SIN 621, including anatomic pathology, clinical chemistry, cytogenetics, cytology, clinical drugs of abuse and toxicology, endocrinology, hematology, hemostasis, immunology, microbiology, organ or disease-oriented panels, serology, and urinalysis.
The justification relies on GSAR 538.7104-3(b)(iii), citing economy and efficiency as a logical follow-on to the original FSS contract V797D-50532, which was awarded as a multiple-award blanket purchase agreement (BPA 36C25925A0020) on eBuy in 2025 for the period April 1, 2026 through March 31, 2026, with final call orders expiring September 30, 2026. Because testing volume increased substantially from 2025 to 2026 and exceeded the scope of existing BPAs, which expired in March 2026, the agency determined that Labcorp's more extensive test list compared to competitors ARUP and Quest makes it the sole viable source for continuity during the three-month bridge period. The justification notes that FSS pricing has already been negotiated and discounted, and the contracting officer will request that Labcorp honor current pricing. A new long-term, five-year multiple-award FSS-RFQ is currently in presolicitation review and will be competed on eBuy to restore full competition for future requirements.
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| File | Type | Posted |
|---|---|---|
| J_A Notice V797D-50532 36C25926F0235_1.docx | DOCX document |
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GSAR 538.7104-3 Sole Source Justification Acquisition ID#: 36C259-26-AP-3143
Sole Source Justification
ORDER >SAT
GSAR 538.7104-3
Acquisition Plan Action ID: 36C259-26-AP-3067 and 36C259-26-AP-3152 JOFOC Tracking Number: FY26 – NCO 19 - 1606
(1) Contracting Activity:
Department of Veterans Affairs Network Contracting Office 19 6162 South Willow Drive, Suite 300 Greenwood Village, CO 80111
Organizational Activity:
Department of Veterans Affairs
Name Address 2237
Oklahoma City VA Health Care System
921 N.E. 13th Street Oklahoma City, OK 73104
635-26-3-114-0195
Salt Lake City VA Health Care System
500 Foothill Drive Salt Lake City, UT 84148
660-26-3-071-0080
(2) Description of Action: This acquisition is conducted under the authority of the Multiple- Award Schedule Program (41 U.S.C. 152(3) and 40 U.S.C. 501). The action being reviewed is a sole source justification to award a three-month FSS Task Order for reference laboratory testing to Labcorp. This is a follow-on to an original FSS contract V797D-50532.
Order against: FSS Contract Number: V797D-50532
Name of Proposed Contractor: Laboratory Corporation of America (Labcorp) Street Address: 231 Maple Ave.
City, State, Zip: Burlington, NC 27215 Phone: 720-261-2449
Acquisition ID#: 36C259-26-AP-3143
(3) Description of Supplies or Services:
The estimated value of the proposed action is
The services required are reference laboratory testing services with tests available under ALL the SIN categories below.
Contractor shall provide courier to pickup patient samples, test the samples in their laboratory using CLIA approved testing on FDA approved instrumentation and provide the results of the diagnostic tests back to the VA labs.
(4) Identify the Authority and Supporting Rationale (see below and if applicable, a demonstration of the proposed contractor’s unique qualifications to provide the required supply or service.
GSAR 538.7104-3(b)(i): An urgent and compelling need exists and following the ordering procedures would result in unacceptable delays:
GSAR 538.7104-3(b)(ii): Only one source is capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized;
GSAR 538.7104-3(b)(iii): In the interest of economy and efficiency, the new work is a logical follow-on to an original Federal Supply Schedule order provided that the original order was placed in accordance with the applicable Federal Supply Schedule ordering procedures. The original order must not have been previously issued under sole source or limited source procedures.
Acquisition ID#: 36C259-26-AP-3143
The original FSS-BPA was solicited on eBuy as a multiple award solicitation against FSS-RFQ 36C25925Q0120 and awarded for a period of performance of 04/01/2026 – 03/31/2026 (with the final call order expiring 09/30/2026). FSS-BPA 36C25925A0020.
Salt Lake City VA and Oklahoma City VA’s quantity or testing usage increased drastically from 2025 to 2026. The funding increase amounts for both stations are considered out of scope and the FSS-BPAs all expired March 2026. The final orders expire September 30, 2026. In order to continue testing and not risk testing stoppage which can pose great risk to patient care, a three-month, follow-on FSS Task Order is being sole-sourced to Labcorp.
GSAR 538.7104-4: Items peculiar to one manufacturer:
A patent, copyright or proprietary data limits competition. The proprietary data is:
These are “direct replacements” parts/components for existing equipment.
The material/service must be compatible in all aspects (form, fit and function) with existing systems presently installed/performing.
(5) Describe Why You Believe the Order Represents the Best Value consistent with FAR 8.404(d) to aid the contracting officer in making this best value determination:
FSS pricing has already been negotiated and discounted. Contracting Officer will be asking Labcorp to honor current pricing for the three-month FSS Task Order.
(6) Describe the Market Research Conducted among schedule holders and the results or a statement of the reason market research was not conducted.
This requirement will be awarded as a follow-on, sole-source, three-month FSS Task Order to Labcorp to continue patient testing for Oklahoma City VA Health Care System and Salt Lake City VA Health Care System.
There are over 300 small businesses that can perform reference laboratory testing but based on market research conducted in early 2025, there are only three large businesses that can conduct all the tests required and supported under the following SIN categories.
Acquisition ID#: 36C259-26-AP-3143
Out of the three large businesses given the multiple-award FSS BPAs in 2025 (Labcorp, ARUP and Quest), only Labcorp has a test list more extensive than Quest and ARUP. This is a short-term solution for continuing patient testing . Currently a new long-term FSS-RFQ is in presolicitation review. The new long-term solicitation will be competed on eBuy and awarded as multiple award FSS-BPAs.
(7) Any Other Facts Supporting the Justification: There are no other statements or facts supporting this justification.
(8) A Statement of the Actions, if any, the agency may take to remove or overcome any barriers that led to the restricted consideration before any subsequent acquisition for the supplies or services is made:
Currently, an FSS-RFQ for a five-year multiple award FSS-BPAs is out in presolicitation review.
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