36C26320C0138-025.pdf

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

OFOC SOP Revision 08 Page 1 of 4 Original Date: 03/22/11 Revision 08 Date: 04/18/2018

DEPARTMENT OF VETERANS AFFAIRS

Justification and Approval (J&A) For

Other Than Full and Open Competition (>SAT)

Acquisition Plan Action ID: 36C263-20-AP-2669

1. Contracting Activity: Department of Veterans Affairs, Network Contracting Office 23 (NCO 23), Station 36C438. 438-20-3-140-0020.

2. Nature and/or Description of the Action Being Processed: Radiology services including onsite services, offsite services and offsite interpretations for all nonbusiness hours for the Sioux Falls VA Health Care System. This procurement is being conducted in accordance with procedures found in FAR Part 12, Commercial Items and FAR Part 15, Contracting by Negotiation. This will be a firm fixed price contract.

Name and Address of Proposed Contractor: Avera McKennan Hospital 1325 S Cliff Avenue Sioux Falls, SD 57105

3. Description of Supplies/Services Required to Meet the Agency’s Needs: Radiology services including onsite services, offsite services and offsite interpretations for all nonbusiness hours for the Sioux Falls VA Health Care System. Radiology onsite services during business hours are for approximately 96 hours every two weeks or 1040 hours for the five-month performance period from May 1, 2020 to September 30, 2020. Offsite readings for more complex radiology needs are available during business hours and are estimated to be 477 hours total for the five-month period.

In addition, offsite after hours interpreatations will be provided for all nonbusiness hours for approximately 3034 hours over the five-month period. The new contract must be awarded effective 5/12/2020 to avoid a lapse in coverage for these critical patient care services. The estimated cost for radiology services is $684,580.60 for the performance period.

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

(X ) (1) Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements per FAR 6.302-1;

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 and No Other Supplies or Services Will Satisfy Agency Requirements per FAR 6.302-1, due to the critical nature of the services requested, timeframe for awarding a competed long term contract and IT requirements of contractor. The current Radiology services contract, VA263-14-C-0151, will expire on April 30, 2020. There have been unforeseen delays with posting the long-term Radiology solicitation due to changes in contract type. Radiololgy services are a vital requirement for Verteran care and without this service, healthcare throughout the Sioux Falls VA Healthcare System would be impacted.

OFOC SOP Revision 08 Page 2 of 4

Revision 08 Date: 04/18/2018

Avera McKennan Hospital is currently the contractor performing these Radiology services and a short five-month interim contract was determined to be the best option as the solicitation for a long-term contract utilizing full and open competition is prepared. Due to the highly specialized nature of radiology services, the specialized IT systems in place to send radiology readings and reports offsite and then back to the VA and lengthy credentialing process, Avera McKennan Hospital is the only responsible source at this time for this requirement. Accordingly, Avera McIKennan Hospital is the only firm capable of providing the supplies and services described in Section III above without the Veteran’s Health Administration experiencing unacceptable delays in fulfilling its requirements and impacting Veteran care.

6. Description of Efforts Made to ensure that offers are solicited from as many potential sources as deemed practicable: In an effort to ensure as many potential sources are considered, the intent to sole source was posted to SAM beta on 4/11/2020 as required by FAR 5.201. Sioux Falls VA Health Care System credenentialing was also consulted and it was determined that new radiology physicians could not be credentialied by 4/30/2020.

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

Reasonable: The estimated cost per hour for Radiology services is $451.34. Overall cost for the five-month period is $684,580.60. In accordance with FAR Subpart 15.404-1(b) the following price analysis techniques and procedures will be utilized to ensure a fair and reasonable proce.

Comparison of previous Government contract prices for the same service. The cost for previous Government purchases for the same service, based on the contract VA263-14-C-0151, option year IV and 6-month extension was $438.19 per hour. The hourly rate estimated for the short-term contract is 3% more, which lines up with cost of living changes per US Bureau of Labor Statistics for an 18-month period and is in line with the current contract pricing. Current pricing was previously found to be fair and reasonable before contract VA263-14-C-0151 was awarded.

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.” The market research report for the upcoming long-term contract was also reviewed.

9. Any Other Facts Supporting the Use of Other than Full and Open Competition: There are no other actions the VA can take to increase competition to continue these services by the 5/1/2020 need date. Any potential companies wishing to qualify for this procurement would have to obtain approval to connect to the VA network for radiology exams and reading transmittals. The Radiology services under the contract ending on 4/30/2020 are vital to Veteran care and if interrupted would significantly impact and jeopardize Veteran care. Avera McKennan Hospital is currently performing the services and can continue without any break in service to the eligible beneficiaries of the Sioiux Falls VA Health Care System.

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

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Revision 08 Date: 04/18/2018

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 Radiology Services contract for a base with four option years will be solicited and awarded during this interim short-term contract period of performance. An updated sources sought notice for the long-term contract will be posted due to the delays with solicitation and award.

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Revision 08 Date: 04/18/2018

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.

Kevin Lawrence Date Imaging Supervisor Sioux Falls VA 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.

Sandra McAnany Date Contracting Officer NCO 23 Contracting

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.

Arlene Jorgensen Hillestad Date Branch Chief, Health Care Team 2

NCO 23 Contracting http://vaww.pclo.infoshare.va.gov/PMWeb/VHAPM_Part_806.3.aspx