DEPARTMENT OF VETERANS AFFAIRS

Office of Procurement, Acquisition and Logistics (OPAL)

Strategic Acquisition Center (SAC) 5202 Presidents Ct, Suite 103

Frederick, MD 21703

JUSTIFICATION AND APPROVAL

FOR OTHER THAN FULL AND OPEN COMPETITION

(1) Identification of the agency and the contracting activity, and specific identification of the document as a "Justification for Other Than Full and Open Competition."

This Justification and Approval (J&A) for Other Than Full and Open Competition is executed by the Strategic Acquisition Center (SAC), on behalf of Department of Veterans Affairs (VA), Veterans Health Administration (VHA), Equipment Life Cycle Management (ELCM) Program.

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

The purpose of this document is to obtain Head Contracting Activity approval for the use of Federal Acquisition Regulation (FAR) 6.103-1(d) Application for brand-name descriptions.

This activity proposes to negotiate and award a single, competitive requirements contract utilizing the procedures set forth in FAR Parts FAR 11.204 with ordering procedures adhering to FAR subpart 16.5 procedures. The period of performance is for a twelve (12) month base period with four (4) twelve 12-month option periods.

(3) A description of the supplies or services required to meet the agency’s needs (including the estimated value).

VA Dental Services examine and treat eligible inpatient and outpatient beneficiaries.

It is not the established mission of VA to provide dental care to all Veterans or even to all those who are hospitalized. Dental eligibility is determined in a different manner than medical eligibility. The scope of care is determined by the patient’s dental classification and services are provided to very specific categories of Veterans. Eligibility for dental care is defined by statute and is to be provided in accordance with the provisions of existing law and VA regulations, i.e., 38 U.S.C. §§1710(c) and 1712, and 38 CFR §§17.160 through 17.166. Eligible Veterans are generally those with a service-connected compensable dental condition, a service-connected non-compensable dental condition that meets discharge and application criteria, a dental condition resulting from combat wounds, service trauma, or prisoner of war status, a dental condition that aggravates a service-connected disability, those requiring completion of treatment initiated during VA hospitalization, or Veterans rated at 100% service-connected disability (including those rated unemployable).

Most VA Dental patients are more medically and dentally compromised than the greater population. In addition, many Veterans who qualify for dental care under these categories face significant disabilities, including loss of mobility, chronic pain, post-traumatic stress disorder, or other service-related impairments. These conditions can create additional

Strategic Acquisition Center (SAC) barriers to accessing care and the VA must make every effort to accommodate these unique patients. This group of Veterans includes individuals with trauma-related dental injuries, chronic medical conditions aggravated by dental issues, severe disabilities (particularly those rated 100% service-connected), and those experiencing socioeconomic vulnerabilities, such as homelessness or recent discharge. It also includes Veterans requiring rehabilitation and reintegration support. These Veterans have unique and complex needs, making it imperative that the VA be equipped with the most accessible, comfortable, and safe dental delivery systems and chairs to ensure equitable, high-quality care.

Dental Delivery Units and Chairs are designed to facilitate dental examination, treatment, and/or minor surgical procedures performed in dental clinics. The dental delivery unit can be configured for rear or side delivery and integrates instrumentation mounts, cuspidors, assistant’s holders, lights, a foot control and an adjustable electric chair adaptable to correct body positioning of the patient during the examination, treatment or cleaning of patients’ teeth. Dental delivery units and chairs may be partially or completely attached as integral components or may stand separately as self-supported units. The A-dec 511 Dental Chair is a cutting-edge dental chair known for its ergonomic design, superior patient comfort, and advanced features.

The Independent Government Cost Estimate (IGCE) for this requirement is $45,802,190.20 (including all options).

(4) An identification of the statutory authority permitting other than full and open competition.

The statutory authority permitting other than full and open competition is 41 U.S.C.3304(a)(1) as implemented by FAR Subpart 6.103-1(d) entitled, “Application for Brand-Name Descriptions.”

(5) A demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited.

The unique features of the A-dec Dental 500 series chair and delivery units which set this technology apart from all other devices are as follows:

Design and Ergonomics:

Many Veterans who qualify for VA dental care face unique physical challenges that directly affect how they can receive treatment. The VA patient population is generally older, with a high prevalence of chronic health conditions and service-connected disabilities. Mobility limitations are common, and a significant portion of Veterans are wheelchair users or have difficulty transferring into traditional dental chairs. In addition, musculoskeletal injuries, chronic pain, and limited range of motion can make reclining or holding certain positions uncomfortable or even unsafe. Nearly 49% of all U.S. Veterans are age 65 or older—and a

Strategic Acquisition Center (SAC) significant number contend with mobility limitations or use assistive devices. Close to 250,000 Veterans use wheelchairs, hundreds of thousands more rely on canes or walkers and 69.5% who experience spinal and musculoskeletal disabilities and 50,000 patients with major limb loss.

To address these challenges, VA requires dental chairs with the widest possible range of height adjustment. This feature is essential to safely accommodate wheelchair transfers, allow for treatment in modified positions, and ensure that Veterans with limited mobility can receive care without undue strain. By investing in adaptable equipment, VA facilities are better able to provide equitable, accessible dental services tailored to the needs of their patient population.

The A-dec 511B dental chair is uniquely designed to meet the complex physical needs of the Veteran population. What sets the A-dec 511B apart is its exceptionally low base-down position, which adjusts down to 13.5 inches from the floor. This low-height capability is a critical feature in the VA clinical setting. It enables easier and safer transfers from wheelchairs, mobility devices, or standing positions—reducing the risk of falls or strain on both patients and clinical staff. The lower height increases the number of patients that can comfortably place their feet on the floor, removing barriers to access, increasing the patient’s confidence and lessening exertion in transferring from the chair to both the patient and the provider.

For Veterans with limited range of motion, spinal fusion, degenerative joint disease, or postural instability, the chair's low entry point and smooth articulation greatly enhances the ability to provide dental treatment to all eligible veterans. In essence, the A-dec 511B enhances clinical accessibility, safety, and treatment quality, making it a vital component in a modern VA dental operatory equipped to serve a population with high rates of physical disability.

Additionally, the chair’s adjustability supports optimal ergonomic positioning for providers while maintaining patient comfort and safety. Due to the physical demands of providing dental care, long hours spent hunched over patients can lead to musculoskeletal disorders, including back pain, neck strain, and carpal tunnel syndrome. Proper seat height is essential to support a neutral posture. By offering a lower seat height, dental equipment can accommodate a wider range of providers with varying body types, promoting optimal ergonomics and reducing the risk of injury. Optimal ergonomics is the design and functionality of dental chairs to promote the best posture and support for both the provider and the patient. This directly improves the quality of care by lessening fatigue and distraction from discomfort, keeping the focus on providing care and treatment and increasing the ability to perform appropriate healthcare.

In addition, the inability to lower the dental chair to its lowest possible height often results in patients remaining in a prolonged Trendelenburg position during intraoral examinations. For

Strategic Acquisition Center (SAC) instance, during a mandibular arch examination, the dentist requires the chair to be positioned at its lowest possible height for optimal access to the mandibular arch. If the chair's height setting is too high, the clinician must tilt the chair more significantly to conduct the exam, resulting in an increased Trendelenburg position. This positioning poses significant risks for medically complex patients, including cardiovascular strain, respiratory compromise, elevated intracranial and intraocular pressure, increased aspiration risk, and orthostatic instability. Increased intercranial pressure is of particular concern for patients with head trauma. Patients with respiratory issues may experience increased difficulty breathing in this position due to the elevated diaphragm pressing against the lungs. The Trendelenburg position can cause cardiovascular complications, especially in patients with heart disease or low blood pressure. The position can cause decreased cardiac output, increased heart rate, and decreased blood pressure. These risks are particularly pronounced in older Veterans and those with multiple comorbidities or service-connected disabilities. VHA Directive 1130 emphasizes that care must be delivered in a manner that is safe, efficient, and aligned with patient needs and clinical standards. To achieve this, dental chairs procured for VA facilities must include the widest possible range of vertical height adjustment and flexible positioning features. These requirements ensure safe wheelchair transfers, minimize reliance on Trendelenburg positioning, reduce adverse clinical risks, and align VA operations with both patient safety standards and federal accessibility guidelines.

Data Control System:

The A-dec 532/533/541 delivery systems are the only chairs on the market that have a Data Control System, a highly advanced platform that controls all electrical and digital components of the dental unit. This system offers a plug-and-play interface, allowing seamless integration of additional equipment or technology without requiring complex rewiring or system overhauls. It provides the ability to control numerous types of external equipment via a single, central control module.

This level of modular adaptability is particularly needed in the VA environment, where clinic configurations and treatment requirements vary widely across facilities. Whether adapting for different dental specialties, space constraints, or Veteran-specific accessibility needs, A-dec’s Data Control System ensures that clinics can standardize core equipment while maintaining the flexibility to customize as needed by allowing dentists to integrate almost any device they choose. Modular adaptability allows the dentist to keep essential equipment readily available within their immediate workspace, reducing the need to move equipment in and out during procedures. This enhances workflow efficiency, minimizes disruptions, and supports better infection control by limiting unnecessary handling. It supports diverse specialties, whether configuring operatories for general dentistry, prosthodontics, oral surgery, or endodontics, modular components can be added, reconfigured, or removed to support specialized workflows and toolsets without requiring a full equipment replacement.

Strategic Acquisition Center (SAC)

• Improves accessibility: Clinics serving Veterans with mobility impairments can adapt systems—such as adjusting delivery arm reach, control location, or chair positioning—ensuring compliance with accessibility standards and improving patient comfort and safety.

• Space Optimization: Many VA facilities have limited square footage or unconventional layouts. These facilities require the ability to customize system configurations (e.g., rear vs. side delivery) to maximize efficiency and operatory functionality. This central control module allows equipment to be powered and controlled via the small, centrally located touch screen. This eliminates the need to rotate equipment in and out of the patient area, thereby minimizing care delays and reducing overall appointment duration

• Integration and Expansion: The Data Control System streamlines the addition of plug-and-play devices and accessories, reducing installation complexity, minimizing downtime, and enabling future expansion as clinical needs evolve. The Data Control System enhances clinical readiness, and the standardized but adaptable systems simplify staff onboarding and cross-clinic support, ensuring that dental teams can quickly become proficient across different VA sites which improves continuity of care and operational resilience. No other unit is designed with modular adaptability.

The Data Control System supports enhanced clinical efficiency, diagnostics, and maintenance tracking, making it a forward-compatible solution that aligns with the VA’s goals for future-ready infrastructure, interoperability, and long-term cost savings through reduced downtime and easier upgrades.

Integrated Water Pick-Up Tube:

The A-dec delivery systems also feature an integrated water pick-up tube designed to minimize cross-contamination and support infection control best practices. The pickup tube remains inside the bottle, significantly reducing exposure to ambient contaminants, greater reducing contamination between patients since the tube is secured. This system plays a vital role in helping VA dental clinics meet the stringent water quality standards set by the Centers for Disease Control and Prevention (CDC) and the American Dental Association (ADA), which require that dental unit waterlines maintain bacterial colony counts of no more than 500 CFU/ml. Although other manufacturers meet the minimum standards, the VA National Dental Program Office requires that the highest level of precaution be taken to decrease the potential for cross contamination. Competing systems often leave the water pick-up tube exposed during refilling, increasing the chance of contact with contaminated equipment, instruments, or surfaces. These designs demand additional staff precautions, increased disinfection, and more work hours to achieve comparable infection control. In alignment with VA’s responsibility to provide the safest care possible, A-dec’s system represents a best-practice solution that supports both Veteran health and operational efficiency.

Strategic Acquisition Center (SAC)

By reducing the risk of biofilm buildup and microbial contamination, the integrated pick-up tube ensures a consistent and safe water supply to the dental chair. This not only protects Veterans, many of whom may be immunocompromised or have complex medical conditions but also ensures exceeding compliance with VA infection control protocols and Joint Commission accreditation requirements.

Additionally, the design simplifies routine maintenance and disinfection procedures, contributing to operational efficiency and reducing the risk of healthcare-associated infections. In sum, this integrated feature supports both clinical safety and regulatory compliance, making it an essential component of a modern VA dental delivery system.

Compatibility with Existing Infrastructure and Inventory:

All 200 VA dental clinics are currently standardized on A-dec delivery systems. Existing plumbing, electrical, cabinetry, and handpieces are fully integrated with the A-dec platform.

Replacing these units with an alternate brand introduces significant infrastructure and equipment compatibility issues, leading to increased cost and extended implementation timelines.

Non-A-dec units may require facility-level changes to accommodate differences in utility locations, footprints, and installation requirements. Based on historical data from prior contracts, these adjustments typically include, at minimum, electrical rewiring and plumbing relocation.

The current VA inventory includes A-dec electric handpieces that are not compatible with air-driven systems used by many other manufacturers. Switching brands would necessitate the replacement of all handpieces or procurement of couplers at each operatory. Estimated cost impact:

• Average cost per handpiece (electric motor system): $2,800 – $3,500

• 3 handpieces per operatory × $3,000 avg. = $9,000 per operatory

For a standard 10-operatory clinic:

• Handpiece replacement cost: 10 × $9,000 = $90,000

Choosing a brand other than A-dec introduces at minimum $90,000 in additional costs per 10-operatory clinic for handpiece replacement and added undetermined infrastructure cost, not including higher lifecycle chair replacement costs. Maintaining A-dec as the standard mitigates infrastructure risk, prevents handpiece obsolescence, and ensures compatibility with existing VA systems — resulting in substantial cost avoidance and improved operational efficiency.

Strategic Acquisition Center (SAC)

For these reasons, procuring A-dec dental delivery systems is in the best interest of the Government, ensures continuity of care for Veterans, and upholds responsible use of federal resources.

(6) A description of efforts made to ensure that offers are solicited from as many potential sources as is practicable, including whether a notice was or will be publicized as required by subpart 5.2 and, if not, which exception under 5.202 applies.

Market research was conducted from July 2024 – August 2025. This research consisted of reviews of a similar previous procurement and a market survey through search engines of open market contractors and Federal Supply Schedule contractors. Search engines utilized included Google, Bing, GSA Advantage and the ECRI sourcebook catalog. Additionally, the proposed action will be synopsized on the Federal Business Opportunities Webpage in accordance with FAR 5.201 and made available with the published solicitation in accordance with FAR 6.302-1(c). Any proposals that are received shall receive consideration and be evaluated to the extent capable of meeting agency needs.

(7) A determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable.

No award shall be made until the Contracting Officer determines the cost to the Government to be fair and reasonable. In accordance with FAR 15.305(a)(1), normally, competition establishes price reasonableness; the prices quoted will be evaluated to determine whether they are fair and reasonable by any one or combination of the following:

a. Comparison of the proposed prices to historical prices paid, whether by the Government or other than the Government, for the same or similar items.

b. Comparison with competitive published price lists of similar products, published market prices of commodities, similar indexes, and discount or rebate arrangements.

c. Comparison of proposed prices with Independent Government Cost Estimates.

(8) A description of the market research conducted (see part 10) and the results or a statement of the reason market research was not conducted.

IAW FAR Part 10, as described in Section 6 above, market research includes a sources-sought announcement issued specifically for the replacement effort, advising the industry of the pending acquisition and soliciting inquiries from interested parties.

https://www.acquisition.gov/far/part-5#FAR_Subpart_5_2 https://www.acquisition.gov/far/part-5#FAR_5_202

Strategic Acquisition Center (SAC)

A Request for Information (RFI) was published on 3/05/2025 and closed on 3/18/2025. The RFI resulted in a response from eleven (11) vendors. The RFI sought a qualified source to provide brand name or equal to A-dec® Dental Delivery Units and Chairs.

Market Research concluded that A-dec 500 series dental delivery units and chair is the only brand name that meets all the requirements of VHA. Below are the proposed salient characteristics.

SC 1-6 applies to CLINs 1-6

SC # SALIENT CHARACTERISTICS METHOD OF

EVALUATION

SC 1

Dental Chairs and Delivery Units must have a minimum chair capacity of 500 lbs. patient weight without the chair.

Literature Review

SC 2 Dental Chairs and Delivery Units base must be able to lower to 13.5 inches

Literature Review

SC 3 Dental Delivery Unit and Chairs must have an integrated pick-up tube system for water source

Literature Review

SC 4

Dental Delivery Units and Chair must be able to accommodate both right and left-handed provider positions

Literature Review

SC 5

Dental Chairs and Delivery Units must be able to swivel with a minimum of 60 degrees (30 degrees each side of center)

Literature Review

SC 6

Dental Chairs and Delivery Units must have a multi-position arm rest that will accommodate entrance and exit from the chair to and from a wheelchair.

Literature Review

SC 7-10 applies to CLINs 7-40

SC # SALIENT CHARACTERISTICS METHOD OF

EVALUATION

SC 7 Dental Chairs and Delivery Units must have antimicrobial silicone waterlines

Literature Review

SC 8 Dental Delivery Units must have a minimum 5+ holder position(s).

Literature Review

SC 9

Dental Chairs and Delivery Units must be able to be able to accommodate a dedicated line integrated ultrasonic system.

Literature Review

SC 10

Dental Chairs and Delivery Units must have a digital touchpad that can chair position, control water and speed levels to handpieces, air venting, and power to the ultrasonic scaler (if a scaler is requested).

Strategic Acquisition Center (SAC)

SC 11 applies to CLINs 41-53

SC # SALIENT CHARACTERISTICS METHOD OF

EVALUATION

SC 11

Dental Chairs and Delivery Units must have an integrated LED light that can be chair mounted and has a touchless sensor option, with auto turn-on and at least two intensity settings and a cure safe mode light setting

(9) Any other facts supporting the use of limited competition.

A-Dec is the only dental delivery unit that meets all of the salient characteristics above. A- Dec brand is a trusted provider in the dental industry and is FDA-approved to refurbish dental chairs and delivery systems. Their commitment to quality and innovation makes them a reliable choice that maximizes the equipment’s lifespan while minimizing operational costs. A-dec’s buyback program will benefit facilities by providing cost savings and reducing facility workload in removing and disposing of used equipment.

Market research indicates other companies’ similar products do not meet, and cannot be modified to meet, the agency’s needs as stated above.

(10) A listing of the sources, if any, that expressed, in writing, an interest in the acquisition.

VENDORS

RESPONDED

SOCIO

ECONOMIC

CATEGORY

MFG/DIST/Reseller PRODUCT

SOURCE

PRODUCT

SOURCE

BUSINESS

SIZE

COUNTRY

OF

ORIGIN

MEETS

SC

CME Corp. SB Distributor Midmark LB USA No

A-Dec LB Manufacturer A-Dec LB USA Yes

Fidelis SDVOSB Reseller A-Dec LB USA Yes

Midmark LB Manufacturer Midmark LB USA No

Pro-Alliance SDVOSB Distributor A-Dec LB USA Yes

Strategic Acquisition Center (SAC)

(11) A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition for the supplies or services required.

The Government will continue to conduct market research to ascertain if there are changes in the marketplace that would enable future actions to be competed.

All future requirements will be handled on a case-by-case basis. Toward the expiration of this contract, consideration will be given as to whether the future acquisition should be competitive.

(12) Technical and Requirements Certification:

I certify that the supporting data under my cognizance, which are included in this justification, are accurate and complete to the best of my knowledge and belief.

Signature: _________________________________ Date: ____________ Annette Holland Program Manager VHA Procurement and Logistics Office (P&LO)

(13) Contracting officer certification that the justification is accurate and complete to the best of the contracting officer ’s knowledge and belief.

I certify that this justification is accurate and complete to the best of my knowledge and belief.

Kimberly LeMieux Contracting Officer Strategic Acquisition Center

Strategic Acquisition Center (SAC)

For acquisitions over $15M not exceeding $75M

Approval

Based on the foregoing justification, I hereby approve this acquisition on an “other than full and open competition” basis pursuant to the statutory authority cited in paragraph four above, subject to availability of funds, and provided that the property and services herein described have otherwise been authorized for acquisition. As this action does not exceed $75M, the certification below required by FAR 6.304 serves as approval.

Joy M. Smith Head Contracting Activity Strategic Acquisition Center and National Acquisition Center