A13- SAP-Sole-Source-Procurement RFO Part 8 and 12 CO signed 17Jul2026.pdf
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This is a Justification for Sole Source Procurement under $350,000 submitted by the Centers for Disease Control and Prevention (CDC) on behalf of the National Institute for Occupational Safety and Health (NIOSH) Respiratory Health Division/Surveillance Branch.
The CDC seeks to award a sole source contract to the American College of Radiology (ACR) for an estimated $85,845.00 to provide virtual B Reader course transition, virtual course delivery, and remotely proctored examination services (Procurement Request Number 000HCCHD-2026-98252). The requirement is not on GSA Schedule. The justification is based on the "only one source available" criterion under FAR 12.102 (41 USC 1901), citing the need for continuity of operations. NIOSH has previously obtained B Reader training and testing services from ACR in an in-person format and requires direct transition of this existing partnership to a virtual environment due to ACR's closure of its in-person facility. ACR offers unique capabilities including existing program familiarity, continuity of content and delivery model, integrated course and examination support maintaining approximately 20 hours of instruction per course with expert-led live sessions, and preservation of instructional rigor. The program office rejected four alternatives: competing among other commercial training vendors (would disrupt 2027 course offerings and increase transition risk), in-house development (would require substantial Government infrastructure investment), continuation in in-person format (not viable due to facility closure), and using separate vendors for course hosting and exam proctoring (would fragment responsibility and increase coordination burden). The Program Official (Kathy J. Boyce) and Contracting Officer (Sheena Delanie) have certified the justification as accurate and adequate to support sole source procurement.
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| File | Type | Posted |
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| A1.b. Statement of Work part 2.docx | DOCX document |
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JUSTIFICATION FOR SOLE SOURCE PROCUREMENT (OPEN MARKET OR GSA)
UNDER $350,000
Sole source acquisitions may be used on a limited basis and only when the Contracting Officer’s Representative (COR)/Program Official has provided sufficient justification and the Contracting Officer has determined that the circumstances warrant such action. The content for a justification must contain detailed facts and rationale to justify the sole source acquisition. Soliciting from a single source must be done in accordance with FAR 12.102 or 8.401 (GSAR 538.7104-3). At a minimum, the following information must be included:
Identification of Program Office, Contracting Activity, and Proposed Requirement, Justification and Program Office Certification:
A. Program Office:
National Institute for Occupational Safety and Health Respiratory Health Division/Surveillance Branch
PO:
1000 Frederick Lane Morgantown, WV 26508
Centers for Disease Control and Prevention
B. Contracting Activity:
Centers for Disease Control and Prevention Office of Financial Resources Office of Acquisition Services
C. Identification of Requirement:
1. Nature of Action to be Approved by Contracting Officer:
a. Sole source acquisition of: Sole source acquisition of virtual B Reader course transition, virtual course delivery, and remotely proctored examination services.
OR
b. Competitive acquisition of brand name only items: Click here to enter text.
c. Procurement Request (PR) Number (if available): 000HCCHD-2026-98252
2. Proposed Vendor and Estimated Procurement Amount (if available):
a. Proposed Vendor: American College of Radiology
b. Estimated Procurement Amount: $$85,845.00
3. Is the requirement on GSA Schedule? ☐ Yes ☒ No
Rev. 5/28/26
If yes, provide schedule number: Click here to enter text.
D. Justification:
The justification for this non-competitive action is: The program office reviewed the current requirement in light of prior performance history and the specific need to continue B Reader training and testing services that CWHSP has previously obtained from ACR in an in-person format. The office also considered whether the requirement could be satisfied through a broader commercial training approach, a separate virtual proctoring arrangement, or internal performance.
In performing this review, the program office focused on the characteristics that matter most for this acquisition: continuity with the incumbent training model, compatibility with the existing ACR-delivered course and examination structure, ability to transition rapidly to a virtual environment due to closure of the in-person facility, integrated administration of courses and remotely proctored examinations, and the ability to preserve instructional rigor and participant experience.
The results of that review indicated that while other vendors may offer pieces of the requirement, such as generic online course platforms or remote proctoring services, the program office did not identify another source that could provide the complete combination of program-specific continuity, operational compatibility, and low-risk transition available through ACR. On that basis, the program office concluded that ACR is the only source reasonably available for this requirement under FAR 13.106-1(b)(1).
1.
☒ In accordance with FAR 12.102, “only one source is available” in accordance with 41
USC 1901:
X Only one source available A brand-name product or service being required without allowing “equal” products The need for compatibility with existing systems, equipment, software, licenses, warranties, or support arrangements Unusual urgency Exclusive licensing or proprietary rights Continuity of operations Other: [briefly describe]
☐ In accordance with GSAM 538.7104-3 as required in FAR 8.401(b) I hereby determine that the circumstances of this acquisition deems only one source reasonably capable of providing this requirement on the basis that:
The need is of such unusual urgency that following the procedures would result in unacceptable delays in fulfilling that need;
Only one source is capable of providing the products, services, or solution required at the level of quality required because the products, services, or solutions are unique or highly specialized;
The order should be issued on a sole source basis in the interest of economy and efficiency because it is a logical follow-on to an FSS order already issued on a competitive basis;
It is necessary to place the order with a particular FSS contractor to satisfy a minimum guarantee established in the FSS BPA; or
A law expressly authorizes or requires that the purchase be made from a specified source.
Other: [briefly describe]
2. Market Research Conducted:
ACR can provide a direct transition of the existing CWHSP/NIOSH B Reader training and testing relationship from in-person delivery to virtual delivery without requiring the Government to start over with a new provider. This is significant because CWHSP has used ACR in the past for in-person B Reader trainings and tests, and the current requirement is to continue that same partnership in a virtual setting. More specifically, ACR offers the unique combination of capabilities needed for this requirement: • Existing program familiarity. ACR already understands the structure, expectations, and operational history of the B Reader training and testing services it has provided to CWHSP. • Continuity of content and delivery model. The proposal is built around transition of the existing preparation courses and examinations from ACR’s current in-person infrastructure into ACR’s established virtual learning and assessment system, rather than development of an entirely new program. • Integrated course and examination support. ACR proposes both the course delivery and the corresponding secure, remotely proctored examinations, allowing the Government to preserve a single accountable source for instruction, assessment, reporting, and participant support. • Preservation of instructional rigor. ACR’s proposal maintains approximately 20 hours of instruction per course, expert-led live sessions, case-based learning, and alignment with current examination standards, thereby preserving the substance and intensity of the prior training model. • Immediate continuity despite facility closure. Because ACR is closing its in-person facility, the practical way to continue the same partnership is to move the effort into ACR’s virtual environment. Another source could potentially provide online training generally, but not the same direct continuation of this established ACR-delivered program with the same degree of compatibility and continuity.
For this particular requirement, the distinguishing factor is not simply the ability to host a webinar or proctor an exam. It is the ability to carry forward an established and successful B Reader training/testing arrangement into virtual operations with minimal disruption to the Government, participants, and program outcomes. Based on the information available to the program office, only ACR can do that without a substantial and avoidable transition penalty.
3. Facts supporting sole source procurement: What can this product/service do that other products/services cannot do? Include description of other products/services considered and why they did not meet the need.
The program office considered the following alternatives:
Alternative 1 – Compete the requirement among other commercial training or medical education vendors. This alternative was not selected because other vendors may be able to provide general virtual learning support or radiology education services, but they would not provide the same continuity with the existing CWHSP/ACR B Reader training and testing arrangement. A competed award would require a new vendor to learn the program, rebuild or redesign delivery workflows, identify and organize appropriate faculty support, establish examination administration processes, and demonstrate readiness. That would increase transition time and risk and could disrupt the planned 2027 course offerings.
Alternative 2 – Develop and deliver the training and virtual examinations in-house. This alternative was not selected because it would require the Government to stand up or obtain learning management support, registration and participant tracking processes, secure remote proctoring capability, scheduling and logistics support, and the administrative and technical infrastructure needed to deliver and document three complete course-and-examination cycles.
Based on the current requirement, this would not be the most efficient or timely approach.
Alternative 3 – Continue the effort in an in-person format. This alternative is not viable because ACR is closing its in-person facility. Since the program’s intent is to continue the partnership with ACR, continuation of the prior model requires a virtual setting.
Alternative 4 – Use separate vendors for course hosting and exam proctoring. This alternative was considered less suitable because it would fragment responsibility for a tightly connected requirement. The Government would assume additional integration and oversight burden to coordinate course delivery, participant eligibility, examination scheduling, proctoring, scoring, and reporting across multiple vendors. ACR’s integrated approach is more compatible with the existing arrangement and reduces operational risk. For these reasons, the alternatives considered either could not meet the need at all or could not meet it without significant compatibility, continuity, schedule, and performance risk compared with continuing the existing partnership through ACR in a virtual setting.
E. Program Office Certification:
I have reviewed this sole source justification and certify the justification is true and accurate to the best of my knowledge and adequate to support other than full and open competition.
Center/Institute/Office COR/Program Official Name: Kathy J. Boyce
Center/Institute/Office COR/Program Official Signature/Date
F. Contracting Office Certification:
I have fully relied on the information provided herein and hereby certify that this justification is accurate and complete to the best of my knowledge and belief:
Contracting Officer Name: Sheena Delanie
Contracting Officer Signature/Date
| Yes: Off | |
| Only one source available: Off | |
| A brandname product or service being required without allowing equal: Off | |
| The need for compatibility with existing systems equipment software licenses: Off | |
| Unusual urgency: Off | |
| Exclusive licensing or proprietary rights: Off | |
| Continuity of operations: Off | |
| Other briefly describe: Off | |
| In accordance with GSAM 53871043 as required in FAR 8401b I hereby determine: Off | |
| The need is of such unusual urgency that following the procedures would result: Off | |
| Only one source is capable of providing the products services or solution: Off | |
| The order should be issued on a sole source basis in the interest of economy and: Off | |
| It is necessary to place the order with a particular FSS contractor to satisfy a: Off | |
| A law expressly authorizes or requires that the purchase be made from a: Off | |
| Other briefly describe_2: Off | |
| 2026-07-15T07:27:47-0400 | |
| Kathy J. Boyce -S |
| 2026-07-17T18:09:43-0400 | |
| SHEENA R. DELAINE -S |
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