70Z02320FPIT01200 Healthcare Service Justification Redacted.pdf

Justification for an Exception to Fair Opportunity Healthcare Support Services for CG112 and C5ISC

(Exceeding the SAT pursuant to FAR 16.505(b)(2)(ii)(B))

1. Agency and Contracting Activity.

The Department of Homeland Security (DHS), United States Coast Guard (USCG), Assistant Commandant for Acquisition and Chief Acquisition Officer (CG-9), Office of Contract Operations (CG-912), Formal Contracts Division III (CG-9123) proposes to award a task order for a period of performance of one (1) twelve (12) month base period and one (1) ten (10) month optional period under DHS Best-in-Class Strategic Sourcing Vehicle (SSV) General Services Administration (GSA) 8(a) Streamlined Technology Acquisition Resources for Services (STARS) II Contract No. GS00Q17GWD2232 on the basis of an exception to fair opportunity.

2. Nature and/or description of the action being approved.

The USCG proposes to issue Request for Proposal No. 70Z02320RPIT01200 to award a firm, fixed-price task order, without considering other sources, under GSA 8(a) STARS II Contract No. GS00Q17GWD2232 pursuant to FAR 16.505(b)(2)(ii)(B) for providing respective functional and technical support services in support of the USCG Electronic Health Records Acquisition (eHRa) Program Management Office (CG-9333).

The USCG proposes to award this firm, fixed-price task order to:

A. Reddix & Associates Inc (ARDX) 5700 Lake Wright Dr Ste 203 Norfolk, VA 23502-1859

3. Description of Supplies/Services.

CG-9333 has a requirement Services Program, which includes the electronic Health Record Acquisition (eHRa) Project.

The scope primarily includes providing respective functional and technical support services to two (2) eHRa Stakeholder offices - Sponsor Office, Office of Health Services (CG-112) and Command, Control, Communications, Computers, Cyber, and Intelligence Service Center (C5ISC). CG-112 requires assistance with functions associated with the monitoring and managing activities to support deployment, implementation and sustainment of the lectronic Health Record (EHR) solution. C5ISC requires assistance to install and maintain Medical and Dental Radiology IT Systems that will interface with the EHR system.

The place of performance for this requirement is:

The USCG Headquarters, Washington, DC USCG C5ISC, Norfolk, VA

The period of performance of this task order is one (1) twelve (12) month base period and one

(1) ten (10) month option period with an anticipated start date of 21 August 2020.

The total estimated price for the task order is as follows:

Period of Performance Estimate Base Period

Option Period One Total Estimated Price

The requirements will be funded with Fiscal Year (FY) 2020 operating expense (OE) funding.

4. Identify the exception to fair opportunity and supporting rationale.

Justification for Exception to Fair Opportunity

This procurement is being conducted under the authority of FAR 16.505(b)(2)(i)(E): For orders exceeding the simplified acquisition threshold, the FAR expressly authorizes or requires that the purchase be made from a specified source.

In accordance with FAR 19.8(d), for procurements above the simplified acquisition threshold, the contracting officer shall consider 8(a) set-asides or sole source awards before considering small business set-asides. The total estimated value of this requirement is under the 8(a) competitive threshold of $4M.

5. Determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable.

The Contracting Officer anticipates that the price will be fair and reasonable based on conducting a price analysis in accordance with FAR 15.404-1(b)(2)(v), comparison of proposed prices with the independent Government cost estimate that was developed utilizing the GSA 8(a) STARS II pricing tool. Prior to awarding the task order, the ordering activity will conduct a price evaluation by considering the level of effort and mix of labor hours proposed.

6. Demonstration that the Nature of the Acquisition Require Use of the Authority Cited.

In September 2019, CG-9333 entered into an Inter-Agency Agreement (IAA) with the Defense

EHR

system. MHS GENESIS is currently being deployed by the Department of Defense (DoD) and the Veterans Affairs (VA). The MHS GENESIS solution will protect Personally Identifiable Information (PII) and Personal Health Information (PHI) as well as markedly enhance core and priority Coast Guard health care services and improve interoperability with the DoD and the VA.

The potential impact of an unimproved health record solution is suboptimal quality of health care due to limited access to medical information such as previous medical evaluations, laboratory results, radiologic results, treatment and medication prescription history.

This is a new requirement and therefore has not previously been offered into the Small Business

However, during market research, these requirements were determined to be within the scope of the GSA 8(a) STARS II Contract, a DHS SSV that is mandatory for use. GSA 8(a) STARS II was authorized under the provisions of Section 8(a) of the Small Business Act 15 U.S.C. 637(a) and retains the 8(a) sole GSA 8(a) STARS II allows for directed orders under the competitive threshold, currently $4.0 million, per FAR 19.805-1(a)(2). In accordance with the GSA 8(a) STARS II ordering guide, the ordering agency may not compete requirements under the $4.0 million competitive threshold under GSA 8(a) STARS II without seeking and receiving approval from the SBA. Due to the total estimated value of this requirement falling under the 8(a) competitive threshold of $4.0 million, these requirements may be sole sourced to an 8(a) small, disadvantaged business (SDB) in accordance with FAR 16.505(b)(2)(i)(E). A. Reddix & Associates Inc (ARDX), an 8(a) SDB and a GSA 8(a) STARS II contract holder, was determined capable of supporting these requirements and was selected to receive the direct 8(a) award.

7. USCG intends to post this requirement on Beta.SAM.gov pursuant to FAR 16.505(b)(2)(ii)(D).

8. A Listing of the Sources, That Expressed in Writing, an Interest in the Acquisition.

(a) APFS entry F2020051111 was published on 1 July 2020. Two (2) responses were received from the following vendors:

Nolij Consulting LLC 22nd Century Technologies Inc.

(b) The GSA 8(a) STARS II Contract was reviewed to determine if there were any 8(a) Small, Disadvantaged Businesses (SDB) contract holders capable of performing these requirements.

The USCG requested additional information from three (3) contract holders, listed below, to further evaluate their ability to meet the Statement of Work (SOW) requirements:

A. Reddix & Associates Inc (ARDX) Peregrine

CP Marine

Each of the three contractors were given an opportunity to review the SOW requirements and provide their analysis, comments and/or recommendations to demonstrate their capability. Based on the technical responses received from the respective contractors, ARDX best demonstrated its capability and understanding of the requirements and was selected to receive the 8(a) directed order for these requirements.

9. A Statement of the Actions, if Any, the Agency May Take to Remove or Overcome Any Barriers to Competition Before Any Subsequent Acquisition for Supplies or Services Required.

In accordance with 13 CFR 124.506(c)(1), the SBA Associate Administrator for Business Development (AA/BD) may approve a request from a procuring activity to compete a requirement that is below the applicable competitive threshold among eligible participants when a large number of potential awardees exist. Currently, there are not a large number of potential awardees that are DHS SSV contract holders. In the event there are a large number of potential

Data Integration Support Services for CG-913 awardees in the future, the USCG will consider requesting approval to compete the requirements if they continue to fall under the competitive threshold.

Data Integration Support Services for CG-913

I certify that the data supporting the recommended use of other than full and open competition is accurate and complete to the best of my knowledge and belief.

Date

Contracting Officer

11. Technical/Requirements Personnel Certification.

I certify that this requirement meets t data, which forms a basis for the justification, is accurate and complete.

Technical Representative/COR

12. Legal Review and Concurrence:

I have reviewed this justification and consider it legally sufficient.

Attorney

APPROVAL:

CPACA