36C26318C0108-000.docx

VHAPM Part 806.3 Other Than Full and Open Competition (OFOC) SOP Attachment 2: Request for Sole Source Justification Format >SAT

FedBizOpps Fair Opportunity/Limited Sources Justification Notice

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CONTRACTING OFFICE

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FAIR OPPORTUNITY

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GENERAL INFORMATION

* = Required Field FedBizOpps Fair Opportunity/Limited Sources Justification Notice Rev. March 2011 U Continuing Prof'l Development Education - MD/DO Physician AMA PRA Category 1 Credit™ for Educational Activities Minneapolis VA HCS Base + 4 OPTN YRS to commence 7/1/2018 57741 36C26318Q0616 N 611430 Department of Veterans Affairs Network 23 Contracting Office (NCO 23) 113 Comanche Rd.

Fort Meade SD 57741 Angela G Beck Contracting Officer E-Mail: angela.beck@va.gov 36C26318C0108 36C26318C0108 06-28-2018

REGENTS OF THE UNIVERSITY OF MINNESOTA

200 OAK ST SE

MINNEAPOLIS

MN

55455 www.va.gov Dept. of Veterans Affairs angela.beck@va.gov angela.beck@va.gov

DEPARTMENT OF VETERANS AFFAIRS

Justification and Approval (J&A) For Other Than Full and Open Competition (>SAT)

Acquisition Plan Action ID:___VA263-18-AP-6070_______________

1. Contracting Activity: Department of Veterans Affairs, VISN VISN 23, Minneapolis VA Healthcare System (MVAHCS) (618-18-3-5852-0033)

2. Nature and/or Description of the Action Being Processed:

MVAHCS requests a sole source services contract with The Office of Continuing Professional Development (OCPD) at University of Minnesota Medical School (UMMS). This acquisition allows the VA to maintain trainings that are essential and mandatory to hold a professional license that, at present, cannot be performed at the Minneapolis VAHCS. Without the CME credits, the professional licensed staff cannot hold their license resulting in not being able to see/care for patients. OCPD at UMMS is able to provide CMEs (Continuing Medical Education) per the critical and specific requirements of the Dept. of VA.

This is a request for other than full and open competition for the procurement of CME (Continuing Medical Education) process training and certification of regularly scheduled series (RSS) that are planned as a series with multiple, ongoing sessions, e.g., offered weekly, monthly, or quarterly; and that will be primarily planned by and presented to the accredited organization’s professional staff. Offered series may include grand rounds, tumor boards, journal clubs, and morbidity and mortality conferences.

The proposed action supports a sole source contract with OCPD at UMMS (POC follows):

Mia Mullins, Director University of Minnesota Medical School, Office of Continuing Professional Development 420 Delaware Street SE, MMC 293, Mayo Building G-254, Minneapolis, MN 55455 Phone: (612) 626-7600 Email: cme@umn.edu

Contract Period Base Year (12 months) 2018 Option year 1 (12 months) 2019 Option year 2 (12 months) 2020 Option year 3 (12 months) 2021 Option year 4 (12 months) 2022

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

This acquisition allows the VA to maintain training that is essential and mandatory to hold a professional license that, at present, cannot be performed at the Minneapolis VAHCS. MVAHCS requires the contractor to furnish services related to the provision of AMA PRA Category 1 Credit™ for Educational Activities carried out at the Minneapolis VA Health Care System. The credit will be provided for live activities carried out in regularly scheduled series including grand rounds, tumor boards, journal clubs, morbidity and mortality conferences and other recurring educational offerings. This work is to support the requirements of MD and DO physicians that participate in educational activities at the VA for their state medical licensure and hospital credentialing/privileging. A contract will ensure the delivery of services and the fulfillment of roles that otherwise cannot be filled.

Services required:

· Per hour of content, 1 credit is awarded. There is no limit to number of presentations for calendar year. (Pricing is broken into once per month or less or more than once per month)

· Vendor keeps an active record of all paperwork. Statements depicting credit are issued to participants at the end of RSS year by CPD

· Vendor provides required guidelines and tools in order to be compliant with Joint Accreditation Standards

· Vendor provides Statement of Participation, which includes credit statement along with contact hours completed by each attendee to participants only. Speakers can submit for credit separately to their board.

· Vendor will keep record of all attendees, speakers, disclosures, flyers/presentations/objectives, and statements. All statements are shared with RSS Course Director and RSS Coordinator at the end of RSS year.

· Vendor will provide per hour of content, 1 credit is awarded. There is no limit to number of presentations for calendar year.

· Vendor keeps an active record of all paperwork. Statements depicting credit are issued to participants at the end of RSS year.

· Vendor provides required guidelines and tools in order to be compliant with Joint Accreditation Standards

· Vendor provides Statement of Participation, which includes credit statement along with contact hours completed by each attendee to participants only. Speakers can submit for credit separately to their board.

· Vendor will keep record of all attendees, speakers, disclosures, flyers/presentations/objectives, and statements. All statements are shared with RSS Course Director and RSS Coordinator at the end of RSS year.

· Vendor provides CME office staff for instruction and consultation of the RSS course directors and RSS coordinators located at the Minneapolis VA.

· Vendor will train VA administrative staff on requirements and processes of CME organization and tracking.

· Vendor will keeps an active record of all documents. Statements depicting credit are issued to participants at the end of RSS year by vendor.

· Vendor provides required guidelines and tools in order to be compliant with the accrediting body.

· Vendor provides Statement of Participation, which includes credit statement along with contact hours completed by each attendee to participants only. Speakers can submit for credit separately to their board.

· The Vendor will provide updates to the series leaders and faculties about the status of the CME credits and compliance with requirements. This will include reports about the overall series as well as individual reports to participating physicians regarding their CME credits.

· Vendor will provide individual CME credits will be issued no less than once a year and upon individual request by physicians that participated in activities in the preceding year

The AMA’s definition of CME is educational activities which serve to maintain, develop, or increase the knowledge, skills, and professional performance and relationships that a physician uses to provide services for patients, the public or the profession. The content of CME is the body of knowledge and skills generally recognized and accepted by the profession as within the basic medical sciences, the discipline of clinical medicine and the provision of health care to the public. (AMA HOD policy #300.988)

The content of all activities certified for AMA PRA Category 1 Credit™ must meet the AMA’s definition of CME, be non-promotional, and be appropriate in depth and scope for the intended physician audience.

Accredited CME providers sought in this contract may certify nonclinical subjects (e.g. office management, patient-physician communications, faculty development) for AMA PRA Category 1 Credit™ as long as these are appropriate to a physician audience and benefit the profession, patient care or public health. CME activities may describe or explain complementary and alternative health care practices. As with any CME activity, these need to include discussion of the existing level of scientific evidence that supports the practices.

AMA PRA Category 1 Credit™ may only be awarded to MDs or DOs (or physicians with equivalent degrees from other countries). Accredited CME providers may document the amount of time a non-physician participated in one of their live AMA PRA Category 1 Credit™ activities. However, it should be listed as hours, not credits.

The AMA’s Core Requirements for all activities that are certified for AMA PRA Category 1 Credit™ are that each activity must:

· Conform to the AMA’s definition of CME.

· Address demonstrated educational needs.

· Communicate to prospective participants a clearly identified educational purpose and/or objectives in advance of participation in the activity.

· Be designed using AMA approved learning formats and learning methodologies appropriate to the activity’s educational purpose and/or objectives; credit must be based on AMA guidelines for the type of learning format used.

· Present content appropriate in depth and scope for the intended physician audience.

· Be planned in accordance with the relevant CEJA opinions and the ACCME Standards for Commercial Support , and be non-promotional in nature.

· Evaluate the effectiveness in achieving its educational purpose and/or objectives.

· Document credits claimed by physicians for a minimum of six years.

· Be certified for AMA PRA Category 1 Credit™ in advance of the activity; i.e. an activity may not be retroactively approved for credit.

· Include the AMA Credit Designation Statement in any activity materials that reference CME credit with the exception of “save the date” or similar notice. In addition, activities must comply with specific requirements for the AMA approved learning formats.

The AMA requires that accredited CME providers must be able to provide documentation to participating physicians of the credit awarded, at the request of the physician, for at least six years after completion of each activity. When an accredited CME provider issues a certificate, transcript or other means of documentation, it must reflect the actual number of credits claimed by the physician for live and PI CME activities, and not just automatically record the designated maximum credits for the activity. Documentation provided to participating physicians must accurately reflect, at a minimum, the following:

Physician’s name Name of accredited CME provider Title of activity Learning format of the activity Location of activity (if applicable) Date(s) of the live activity or date that the physician completed the activity Number of AMA PRA Category 1 Credits™ awarded

4. Statutory Authority Permitting Other than Full and Open Competition:

5. Demonstration that the Contractor’s Unique Qualifications or Nature of the Acquisition Requires the Use of the Authority Cited Above (applicability of authority):

Only One Responsible Source (FAR 6.302-1) The OCPD at UMMS is the only locally accredited entity for the critically required AMA PRA Category 1 Credit™, as no separate travel is authorized or funded. The AMA PRA Category 1 Credit™ allows the VA to offer accredited continued education credits to the clinical providers which is essential and mandatory to hold a professional license. At present, the Minneapolis VAHCS is not able to issue accreditation of continued education in-house and must rely upon this service through an outside Contractor. Patient clinical care is directly, negatively affected when physicians are not licensed and cannot legally care for patients. The AMA provides information, resources, and guidance about the AMA continuing medical education (CME) credit system for CME providers. Activities certified for AMA PRA Category 1 Credit™ are locally offered only at OCPD at UMMS; these activities meet both the AMA's and the accreditor's licensure requirements for physicians within the Dept. of VA.

For the last several years the MVAHCS has used OCPD at UMMS for their CME services using 1358’s as a mechanism for payment (Finance Dept. now requires a contract). Any attempted, potential change in credit Contractors will cause a substantial disruption in processing, as well as cause unacceptable delays to fill the requirement of essential and mandatory training for a professional license (training must commence NLT 7/1/18). A change of credit Contractors at this juncture will exceed available funds, as this will require new databases and forms to be developed, recapture of time and locations of conferences, new instructions and guides to be purchased from the new provider, and travel fees – none of which have authorized funding. OCPD at UMMS is the only Contractor to offer a cost effective and time sensitive solution for the Dept. of VA.

OCPD at UMMS’s service covers regularly scheduled series that occur weekly or monthly in which up to 18 different service lines have participated and used the CME training provided, also all areas of the MVAHCS can participate. This fixed price, sole source option ensures the delivery of services and fulfillment of continued education offerings that have a direct, critical, and time-sensitive impact on patient care.

6. Description of Efforts Made to ensure that offers are solicited from as many potential sources as deemed practicable:

Web searches, Catalogs, past documentation searching CME training needs.

University of Minnesota, HCMC and EES were contacted about CME services.

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

There is a clear pricing used in determining if the current pricing is fair and reasonable.

The rates and prices for this service using historical 1358’s are comparable in pricing for this new contract. The Contracting Officer believes the price noted to be fair and reasonable in comparison to past and similar contracts. Price negotiations may be conducted if the CO determines this is necessary.

8. Description of the Market Research Conducted and the Results, or a Statement of the Reasons Market Research Was Not Conducted:

Web searches, Catalogs, past documentation searching CME training needs.

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:

Office of Continuing Professional Development @ University of Minnesota Medical School

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:

Given the unique nature of this requirement and the collaborative nature of the research work being conducted services must continue to be met through the sole source provisions FAR 6.302-1 6.302(a)(2)(i).

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.

Title Facility

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 Black Hills Contracting; NCO 23

b. One Level Above the Contracting Officer (Required over SAT but not exceeding $700K): I certify the justification meets requirements for other than full and open competition.

Services Branch Chief Black Hills Contracting; NCO 23

OFOC SOP Revision 08 Page 7 of 7 Original Date: 03/22/11 Revision 08 Date: 04/18/2018