P03 - JOFOC Symplr Software_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: 36C261-24-AP-1575 JOFOC Tracker 24: FY24-NCO21-1109

1. Contracting Activity: Department of Veterans Affairs (VA), Veterans Health Administration (VHA), Network Contracting Office (NCO) 21, located at Palo Alto, CA, in support of VA Palo Alto Health Care System (VAPAHCS) at 3801 Miranda Avenue Palo Alto, CA 94304-1207 2237: 640-24-3-4399-0028

2. Nature and/or Description of the Action Being Processed: This procurement is for the Symplr Provider credentialing software and annual service 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 nature of this action is to request approval to procure the Symplr Provider credentialing software and annual service as a sole source, open market action. This a new requirement that will be awarded under a firm-fixed-price contract.

3. Description of Supplies/Services Required to Meet the Agency’s Needs: The VAPAHCS has a need for the Symplr’s Provider credentialing software. The requirement is to provide subscription and annual services, which consists of a one-year base period with three (3), one (1) year option periods, with the option to include a six-month extension period IAW FAR 52.217-8.

The period of performance and estimated costs are:

Contract Period Period of Performance Estimated Cost

Base Year 05/1/2024-04/30/2025 $211,326.00 Option Year 1 05/1/2025-04/30/2026 $196,326.00 Option Year 2 05/1/2026-04/30/2027 $196,326.00 Option Year 3 05/1/2027-04/30/2028 $196,326.00 Optional 6 Month Exten 05/1/2028-11/30/2028 $98,263.00

Total Cost: $898,567.00

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

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

( ) 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 VAPAHCS has a requirement to ensure proper credentialing and privileging of all physicians, dentists, podiatrists, psychologists, optometrists, and other health care providers who are independent practitioners involved in direct patient care. This includes personnel who are appointed or utilized on a full-time, part-time, intermittent, consultant, attending, without compensation (WOC), on-station fee-basis, on-station contract, or on-station sharing agreement within this system. Credentialing is in accordance with requirements set forth by Veterans Health Administration and The Joint Commission.

The VAPAHCS currently uses the PRIVplus credentialing software in conjunction with the VHA Federal Credentialing Program for Healthcare Providers (VetPro) Database, to document the credentialing of VAPAHCS health care providers. Symplr Software LLC is the sole provider for the PRIVplus credentialing software. Symplr Software LLC retired the PRIVplus software and ended support of the software on December 21, 2022. VAPAHCS was provided a license that allowed continued use of the PRIVplus software until December 31, 2024.

Symplr Software LLC developed the new Provider credentialing software as a replacement for the PRIVplus credentialing software. Symplr Software LLC is the sole source provider for the Provider credentialing software. Due to the proprietary elements of the credentialing software, only Symplr Software LLC can provide the service. Additionally, PRIVplus and Provider are the only credentialing software that have undergone a software as a service (SaaS), security oversight, and compliance reviews for approved use with constraints with VA network systems such as VetPro.

Obtaining new information technology for use with VA systems is a lengthy process. Getting a new product fully compliant with all VA security, privacy, and other requirements will likely take more than a year. The process includes the product vendor team to comply with VA security policies; this means the product will need an authority to operate as well as external security controls (FedRAMP). Additionally, vendors will need to get Federal Risk and Authorization Management Program (FedRAMP) compliant if they are not already compliant, so this will require upfront costs for the vendor, without any guarantees of receiving a contract.

Upon the release of the Symplr Provider software and notification of the retirement the PRIVplus software, a request was submitted to install the Provider software as a cloud-based service provider within the VA-controlled cloud environments. The decision was approved on July 28, 2023, by the Department of Veterans Affairs Technical Reference Model Management Group. Furthermore, the Provider software underwent an additional SaaS, Security Oversight & Compliance, and FIRARA review and approval in January 2024.

Failure to acquire Provider credentialing software would result in the VA's inability to efficiently manage credentialing requirements, which could pose a risk to ensuring timely physician license verification, accurate reporting and potentially impact patient care. Additionally, Symplr Software LLC owns the proprietary database software which allows them to build, convert and manipulate data within the software. The VA owns the license usage but does not have copyright ownership.

Thus, Symplr Software LLC is the only vendor that can provide the maintenance and technical support required to ensure functionality and properly address any issues that arise.

Effective Date: 02/01/2022 Page 3 of 4

The VAPAHCS Credentialing & Privileging Manager stated that Symplr Software LLC has been providing the service for the VAPAHCS in a satisfactorily manner. The PRIVplus software extension has allowed for continued use without interruption of service but will be unavailable December 31, 2024. Once approved the VAPAHCS Credentialing & Privileging Manager will immediately coordinate with the vendor to update the software throughout the VAPAHCS.

6. Description of Efforts Made to ensure that offers are solicited from as many potential sources as deemed practicable: Market research was conducted, details of which are in section 8 of this document. This effort did not yield any additional sources that could meet the Government's requirements. There is no competition anticipated for this acquisition. Additionally, the proposed intent to sole source was posted to contract opportunities (36C26124Q0408) on February 26, 2024, with a response due date of March 4, 2024. No responses were received.

7. Determination by the CO that the Anticipated Cost to the Government will be Fair and Reasonable: IAW FAR 13.106-3(a)(2), the anticipated cost to the Government will be considered fair and reasonable by comparing the proposed pricing to the independent government cost estimate (IGCE) and previous purchases. A comparison will be made with contract, 36C10A24P0007 awarded by NCO 9 in December 2023, to also determine fair and reasonable.

8. Description of the Market Research Conducted and the Results, or a Statement of the Reasons

Market Research Was Not Conducted: As described in Section 6 above, market research, in accordance with FAR Part 10, was conducted by synopsis of the proposed acquisition, advising industry of the pending acquisition, and soliciting inquiries from interested parties.

Market research was conducted and due to the proprietary nature of this requirement no Service- Disabled Veteran Owned Small Businesses (SDVOSBs) or Veteran Owned Small Businesses (VOSBs) were found who are capable of meeting this requirement. A search of the Small Business Administration (SBA), Veteran Small Business Certification (VetCert) website utilizing the North American Industry Classification System (NAICS) code 541511 yielded 3,797 possible VOSBs/SDVOSBs. As a sole source acquisition, this requirement cannot be set-aside for VOSBs/SDVOSBs. A search of the VA National Acquisition Center Contract Catalog Search Tool yielded no results for credentialing software. A search of the Strategic Acquisition Center (SAC) did not yield any contract for credentialing services. A search of the National Aeronautics and Space Administration (NASA) Solutions for Enterprise-Wide Procurement (SEWP) website did not yield any information technology contracts for credentialing services. A search of contract opportunities on SAM.gov for credentialing software, yielded an Intent to Sole Source for the Symplr Provider software, by Network Contracting Office (NCO) 9. The action was ultimately awarded under contract number 36C10A24P0007 as a sole source procurement.

The Buy American Statute does not apply to the acquisition of services or commercial information technology (IT).

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

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

Symplr Software LLC, 315 Capitol ST STE 100, Houston, Texas 77002-2827

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: In order to remove or overcome barriers to competition in future acquisitions for this requirement, VA will continue to conduct additional market research so that other software solutions can be considered.

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This will include identifying vendors that provide credentialing software and working with the Digital Transformation Center and the Federal Risk and Authorization Management Program to identify vendors with applications that meet VA security and other requirements.

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

Credentialing & Privileging Manager VA Palo Alto Health Care System

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 21

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.

Director of Contracting

Network Contracting Office 21

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 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)

3/29/2024

04/01/2024