Attachment I - DnF Consolidation - National Prescription Eyeglasses - 36C24126R0001.pdf

Consolidation Determination and Findings

National Prescription Eyeglasses Manufacturing Acquisition Plan: 36C241-26-AP-0017

FINDINGS

I. INTRODUCTION.

VHA Office of Acquisitions (VHA-A) plans to solicit offers for Prescription Eyeglasses Manufacturing to include VA Medical Centers (VAMCs) across the enterprise and has conducted market research that demonstrates consolidation of this procurement to be justified.

II. BACKGROUND.

A. Requirement. VHA-A intends to award a multiple-award, firm-fixed price with economic price adjustment (FFP-EPA), Indefinite-Delivery Indefinite-Quantity (IDIQ) contract with a ten-year performance period that includes a base five-year ordering period and one five-year option period. The goal of this requirement is to establish an efficient, reliable, and standardized process for ordering and delivering Prosthetic and Sensory Aids Service (PSAS) National Prescription Eyeglass Manufacturing Services.

The existing eyeglass contracting process is highly fragmented with no standardization across the Veterans Health Administration (VHA). VISN-level contracts currently take over 24 months to award, often interrupted by protests at various stages. Additionally, the VA Office of Inspector General (OIG) has flagged ongoing risks in current contracts.

This requirement will standardize prescription eyeglasses manufacturing services across VHA offering the same or similar frame selection across the nation. This requirement will establish multiple national level contracts and VA will provide fair opportunity to be considered for VISN or regional level Delivery Orders. The national contract will maintain standardized Frame Kits for all awarded contractors, ensuring consistent quality and selection across the nation.

The total estimated value of the resulting contract(s) is , inclusive of all options. Each IDIQ contract will have a ceiling value of $2 billion. Historically, this requirement has been set aside for Service- Disabled Veteran Owned Small Businesses (SDVOSBs) and competed at the VISN or local level. Some historical contracts have included optician services which have been identified as a potential Conflict of Interest;

therefore, optician services are not included in this requirement and shall be procured separately and not through the manufacturers selected for award for this requirement. This requirement will be set aside for SDVOSBs and there is no apparent risk of maintaining this set aside based on market research.

The consolidation of this requirement will standardize prescription eyeglasses offerings across the nation, provide a modernized survey process to ensure veteran satisfaction, standardize the ordering process and eliminate Government Purchase Card (GPC) used to fulfil individual purchase orders, and provide a single point of contact for any contracting related concerns. Due to the modernization and standardization of ordering and potentially utilizing multiple contractor systems to input prescriptions, the Agency will need to develop instruction manuals to ensure Purchasing Agents and VA Opticians have the information needed to appropriately input prescriptions and orders. Additionally, based on feedback there may be resistance from the local VAs to modernize their processes. It will be critical for

AP # 36C241-26-AP-0017

VAAM M807-C Page C-2 leadership from Contracting, PSAS, and VAMCs to assist in a cultural shift toward modern processes and efficiencies.

The selected North American Industry Classification System (NAICS) code for the requirement is 339115 – Ophthalmic Goods Manufacturing with a small business size standard of 1,000 employees. This requirement will be set aside for SDVOSBs and there is no apparent risk of maintaining this set aside based on market research.

B. Applicable Statutes/ Regulations. Federal Acquisition Regulation (FAR) 7.107-2

C. Market Research. Market research has been conducted in accordance with FAR 10.001(a), which is documented in the Market Research Report and Acquisition Plan. The market research has demonstrated that consolidation is necessary and justified.

Request for Information (RFI) Sources Sought Notice 36C24125Q0327 was issued on March 20, 2025, and closed on April 18, 2025. Additionally, the Contract Specialist (CS) hosted one-on-one meetings with 8 of the 13 identified contractors on April 9, 2025, and April 10, 2025.

The CS has also reviewed market research from existing VISN and local contracts for prescription eyeglasses manufacturing.

The CS has verified all parties size status’ in the System for Award Management (SAM) and Small Business Administration (SBA) Small Business Search (SBS), where applicable.

The CS queried the availability of these supplies on required sources of supply, national VA contracts, and other government contracts.

The CS has reviewed the applicability of the Nonmanufacturer Rule (NMR), Buy American Act (BAA) and Trade Agreements Act (TAA) clause and provision requirements, and Federal Information Technology Acquisition Reform Act (FITARA) compliance.

The national team performed in-person site visits July 9, 2025 – July 15, 2025, to 4 of the 5 identified SDVOSB interested parties. The national team performed the final site visit on August 14, 2025, due to a weather cancellation.

Notifications (see FAR 10.001(c)).

VA Small Business Specialist and local Small Business Administration (SBA) procurement center representative (PCR) (see FAR 10.001(c)).

Affected incumbent small business concerns (see FAR 10.001(c)).

Results of Market Research (FAR 7.707-2(1)).

RFI 36C24125Q0327 yielded responses from 13 vendors. Additionally, the VA hosted one-on-one meetings with 8 of the interested contractors.

SBA certified Service-Disabled, Veteran-Owned (SDVOSB): 5 contractors Woman-Owned Small Business (WOSB): 2 contractors Small business: 4 contractors Other than Small Business: 2 contractors

AP # 36C241-26-AP-0017

VAAM M807-C Page C-4

Interested Parties:

Contractor UEI Socioeconomic

SDVOSB

SDVOSB

WOSB & Minority Large

Small Small (SDVOSB in

SAM, not in SBA)

SDVOSB

SDVOSB

Small

Small

SDVOSB

Unicor/FPI

WOSB

Based on the market research conducted, the CO has an expectation that two or more SBA certified SDVOSBs are capable of providing the requirement, will submit offers and that award can be made at a fair and reasonable price offering best value to the government. In accordance with the VA Rule of Two, this requirement must be set aside for SDVOSBs. This requirement will result in multiple awards to capable SDVOSBs. The intended contract ceiling is $2 billion for each resulting contract in the unlikely event one contractor becomes responsible for all prescription eyeglass manufacturing supporting the VA. Delivery Orders will be issued at the Regional or VISN level based on fair opportunity required by FAR Part 16.

III. CONSOLIDATION.

A1. Benefits. Consolidating this requirement will reduce contract administration burden by combining 29 VISN and local contracts into one initiative for all VISNs, freeing up contracting resources to focus on other efforts, which is in-line with the goal of this Administration.

This requirement will support any overflow (locally contracted) from VISN 10 and VISN 20 Fabrication Labs which manufacture eyeglasses in-house for eligible Veteran beneficiaries throughout VISN 10, 12, and 20. The established contract ceiling accounts for all VISNs, including the in-house estimates, in the event of reduced services from the VISN 10 and 20 Fabrication Shops.

This requirement will standardize ordering processes and eliminate GPC use to fulfil orders, requiring 1358s for purchase orders and electronic invoices submitted to Tungsten, minimizing Purchasing Agent administrative burden.

A national contract will also standardize the Statement of Work for the country, ensuring standardized Veteran care across the VA.

A2. Mission success. This consolidated requirement will centrally address deficiencies identified by the VA and OIG in “Better Coordination Needed to Negotiate Consistent Prices

VAAM M807-C Page C-

AP # 36C241-26-AP-0017

PREPARED BY: I hereby certify that the supporting information and data used to complete this determination is accurate and complete to the best of my knowledge and belief.

Jeremy J. Boston Date Contract Specialist MSPV Supplies

Jeremy J. Parker Date Contracting Officer MSPV Supplies

One Level above CO or Director of Contracting REVIEWED BY: I have reviewed this determination and find it to be accurate and complete to the best of my knowledge and belief.

Date

Date

Date

Gerald F. Jacobs Executive Director, Regional Procurement Office East VHA Head of Contracting Activity (HCA)

Approve / Disapprove

Joseph P. Maletta

Executive Direct Office of Acquisition Logistics

JEREMY BOSTON

Digitally signed by JEREMY

BOSTON

Date: 2025.10.15 11:11:18 -04'00' 10/15/2025

11/12/2025

11/12/2025

11/13/2025

JEREMY PARKER Digitally signed by JEREMY PARKER Date: 2025.11.12 10:20:48 -07'00'

WILLIAM NALLS

Digitally signed by WILLIAM

NALLS

_________________________________________ Date: 2025.11.12 16:12:23 -05'00'

William Nalls Director of Contracting Network Contracting Office 1

Concur

JULES TCHOUJAN Digitally signed by JULES TCHOUJAN Date: 2025.11.13 09:31:29 -05'00'

11/13/2025GERALD JACOBS Digitally signed by GERALD JACOBS Date: 2025.11.13 15:36:18 -05'00'

JOSEPH MALETTA

Digitally signed by JOSEPH

MALETTA

Date: 2025.11.19 13:52:08 -05'00'