Consolidation Determination Modular Ramps for Central Region Presolicitation.pdf

DEPARTMENT OF VETERANS AFFAIRS

Veterans Health Administration

Program Contracting Activity Central 212 3rd Avenue, Suite 29 Minneapolis, MN 55401

Determination That Consolidation Is Necessary and Justified:

Central Region Modular Ramp Systems

The Veterans Health Administration (VHA), Program Contracting Activity Central (PCAC) has established an ongoing requirement to furnish and install aluminum modular ramp systems the residences of veteran beneficiaries who are mobility challenged, cannot negotiate stairs and/or require use of a mobility device. This requirement will support veteran beneficiaries within Central Region catchment for Veteran Integrated S Networks (VISNs) 9, 10, 12, 15, 16 and 23. The contractor shall provide modular ramp systems, platforms, delivery, site assessment and installation services. The Contracting Officer has reviewed the requirement for modular ramps and associated services and intends to solicit as a consolidated procurement. This determination is issued pursuant to Federal Acquisition Regulation (FAR) 7.107-2(a), that consolidation is necessary and justified for an acquisition exceeding $2 million.

This review resulted in the following findings:

Background: Aluminum modular ramps are provided and installed by manufacturers and/or installers for veterans who are mobility challenged, cannot negotiate stairs and /or require the use of a mobility device on behalf of the Government. Each modular ramp contains several components and are specific to the veteran beneficiary’s home.

Historically, without a contract in place, the process for purchasing aluminum ramp systems was as follows:

The Prosthetic and Sensory Aids Service (PSAS) would obtain three (3) quotes per ramp requirement.

Each contractor was required to schedule an appointment to go to the veteran’s residence to assess and quote the ramp system project.

Upon receiving quotes the PSAS personnel would evaluate and purchase the ramp systems via Government purchase card, if below the micropurchase threshold; most ramp systems are below the micropurchase threshold and are able to be purchased via a Government purchase card. NOTE: The PSAS personnel are purchasing agents with limited purchasing authority via the Government purchase card.

If a ramp procurement action exceeded the PSAS personnel’s purchase card authority, the request was reassigned to the ontracting ffice to finish the procurement; the ontracting fficer (CO) would then prepare a purchase order for the PSAS. This process took up to or exceed 120 days.

The previous contract streamlined this ordering process. The procedure for purchasing aluminum modular ramps system was as follows:

i. PSAS personnel sent a request to the contractor with the beneficiary’s contact information and address.

ii. The contractor contacted the veteran beneficiary and completed an onsite assessment of the residence.

A sources sought notice was published on August 24, 2021, and ten (10) responses were received;

seven (7) SDVOSBs, two (2) small businesses and one (1) woman owned small business. Initial results dictate that all ten respondents could fulfill the requirement in all of the VISNs within the entral egion.

September 2021, the contracting officer conducted further market research via conference calls with sources sought respondents to further determine their capabilities. Six (6) SDVOSB authorized distributors and one (1) SDVOSB manufacturer/installer who can provide aluminum modular ramp and associated services. It was determined that three (3) authorized distributors and one (1) manufacturer/installer demonstrated their capabilities to support the contract in its entirety.

Sources sought notice 36C77623Q0030 was issued on October 27, 2022, via Contract Opportunities in S .gov. The purpose of this sources sought was to confirm that SDVOSB still had the capabilities to provide aluminum modular ramps and associated services for the Central Region. The sources sought was also to seek further information in regard to the contractor’s installation and/or manufacturing experiences, installation processes, program management, web-based program management software, manufacturers relationship/partnerships with installers, warranties and emergency deliveries. This notice resulted in three (3) respondents;

two (2) SDVOSB authorized distributors and one (1) small business. The ontracting fficer via calls contacted the remaining SDVOSB authorized distributors to confirm that they still have the capabilities to perform the requirement in its entirety. All SDVOSBs confirmed that they are still interested and that their capabilities remain the unchanged.

A search on GSA Advantage confirmed there are modular ramp contract holders under supply schedule 65II Portable Ramp Systems and specifically F-8C Modular Ramps. Using keywords “modular ramp” produced a total of eight (8) SDVOSB/VOSB manufacturers and/or installers who have the capability to provide modular ramp(s) for the Central Region in its entirety. A review of the schedules reflect that the contract holders only offer the modular ramp systems and not the required associated services (installation, delivery, recovery, and assessment) to fulfill the procurement in its entirety. Furthermore, the Contracting Officer could not identify any schedules that includes Economic Price Adjustments (EPA) to account for fluctuating aluminum costs. It is the intent of the Contracting Officer to include VAAR part 852.216-71 Economic Price Adjustment of Contracting Price(s) based on a Price Index to permit a reasonable division of risk between the Government and Contractor in the event that the cost of aluminum fluctuates throughout the life of the contract.

Based on the market research conducted and the resulting analysis, adequate sources of supply for small business concerns were obtained and after reviewing VA’s VIP database to identify verified and capable SDVOSB/VOSBs, sources sought responses and market research confirming capabilities, the data supports setting aside the procurement for SDVOSB using competitive procedures as outlined in FAR 12-Acquisition of Commercial Products and FAR 15-Contracting by Negotiation. The Contracting Officer has determined that SDVOSBs have the capability to meet the requirement in its entirety. The agency anticipates awarding a single award IDIQ to the contractor that meet the qualification requirements outlined herein and included in the forthcoming solicitation.

The ontracting fficer reviewed the Non-Manufacturer Rule (NMR). In accordance with the Non-Manufacturer Rule as defined in 13 CFR 121.406(b) Of the seven (7) SDVOSB respondents the following has been determined:

i. All seven (7) SDVOSBs have 500 or less employees.

ii. Four (4) SDVOSBs engage in the retail wholesale trade and normally sell modular ramps and associated services.

iii. All seven (7) SDVOSBs take ownership or possession of all modular ramp components via its facilities and/or personnel.

iv. Six (6) SDVOSBs supply the end-item of a small business manufacturer (EZ Access, National Ramp, TJ Rampit and Access4U). One (1) SDVOSB is a manufacturer and installer of modular ramp systems-American Access.

The CO has confirmed there is no class waiver associated with modular ramps under NAICS Code 339113 Surgical Appliance and Supplies Manufacturing. Market research has confirmed that there are two or more SDVOSBs who are capable, can comply with the on anufacturer ule for the purpose of this acquisition and can fulfill the requirement in its entirety.

5. Alternative Contract Approaches:

The following options were considered to determine if there were acquisition alternatives for this requirement:

a. Purchase cards. Purchase cards were considered as an alternative contract approach, however purchase cards do not provide terms and conditions that the contractor must adhere to regarding timeliness, materials, installation processes and assessment processes. Furthermore, purchase card spending patterns are difficult to track.

b. Delivery orders via FSS. Individual orders by the VISNs were utilized under FSS contracts and required all associated services, to include site assessments, installation, and reuse/recovery to be purchased only via open-market. Although the contracts provided pricing of aluminum modular ramps systems, they did not include, nor account for, fluctuating aluminum prices. This created additional costs that could have been prevented if the services were readily available on the contracts and the modular ramp systems priced IAW the fluctuating market conditions for metal. This form of ordering also created inconsistencies in the quality of products, timeliness issues, and lack of adherence to ADA guidelines.

c. Award of Multiple IDIQ Contracts. Multiple award IDIQs were considered as an alternative option, however utilizing multiple awards would create timeliness and efficiency issues. PSAS or Contracting personnel would need to compete each individual order; this would create a disruption to the veteran beneficiary because multiple contractors would need to visit the veteran’s residence for assessment and quote. PSAS or Contracting would be required to evaluate the quotes received and, if above the micro purchase threshold, Contracting would process the procurement package adding additional time to the ordering process. This acquisition alternative creates delays that are not

I hereby approve, in accordance with FAR 7.107-2, the necessary steps have been taken to support the need for consolidation; the benefits of the acquisition

; and as a result consolidation for the above referenced requirement is necessary and justified.

Date

Angela Billups, Ph.D.

Executive Director Office of Acquisition and Logistics Senior Procurement Executive

ANGELA

BILLUPS

Digitally signed by

ANGELA BILLUPS

Date: 2023.02.28 20:38:41 -05'00'