C01 - JA_Redacted 36C77626P0009.pdf

Request for SDVOSB/VOSB Sole Source Justification IAW VAAR 819.7008/9

VHAPG Part 819.7008/7009 Sole Source Awards to SDVOSB/VOSB Page 1 of 4 Revision: 04 Effective Date: 11/15/2024

DEPARTMENT OF VETERANS AFFAIRS

Justification and Approval (J&A) For

Other Than Full and Open Competition

Acquisition Plan Action ID: 36C776-26-AP-0170

1. Contracting Activity: Department of Veterans Affairs (VA), Veterans Health Administration (VHA), Program Contracting Activity Central (PCAC), 6150 Oak Tree Blvd, Suite 300, Independence, OH 44131. Purchase Request Number

2. Nature and/or Description of the Action Being Approved: This justification is in support of a new, single award, firm-fixed price contract for VHA National Clinical Recruitment and Placement services in support of the Office of Workforce Management and Consulting (WMC), Workforce Recruitment and Retention Service, National Recruitment Service Program Office to VetCert verified SDVOSB, Argent ARC LLC.

3. Description of Supplies/Services Required to Meet the Agency’s Needs: The contractor shall provide all management, equipment, tools, and resources necessary to aid in the recruitment of historically “hard to fill” clinical positions throughout VHA. The purpose of this requirement is for individual VA Medical Centers (VAMC) to obtain recruitment services to fill mission-critical vacancies they were unsuccessful in filling. This requirement will expedite the referral and selection of qualified clinical professionals by filling current and future vacancies. The vendor(s) shall refer qualified candidates in requested clinical occupations and specialties to VA Medical Centers (VAMC) to meet urgent staffing needs and to address access issues within specified timeframes. These qualified candidates must meet the grade requirements criteria for each respective profession based on the appropriate occupational VA Qualifications Standard. The Contractor shall also develop and maintain standardized documentation, including a Search Request Form, and related templates to ensure consistency in information received from VA facilities and to expedite the recruitment process.

The total contract value is estimated at . The period of performance is one year from the date of award, which is currently estimated to be October 31, 2025.

4. Statutory Authority Permitting Other than Full and Open Competition: 41 USC §3304(a)(5), 38 U.S.

Code § 8127(c), as implemented by FAR 6.302-5 (Authorized or Required by Statute). COs may use the non-competitive (sole source) procedures authorized in VAAR 819.7008 (DEVIATION) or VAAR

819.7009 (DEVIATION)- up to $5,000,000. Check the specific VAAR clause used below:

(X) 819.7008 Sole source awards to a certified service-disabled veteran-owned small business; or ( ) 819.7009 Sole source awards to a certified veteran-owned small business

5. Demonstration that the Contractor’s Unique Qualifications and/or Nature of the Acquisition Requires the Use of the Authority Cited Above (applicability of authority): 38 U.S.C. 8127(c) states, in part, “…a contracting officer at the Department may award a contract to a small business concern owned and controlled by veterans using procedures other than competitive procedures if - (1) Such concern is determined to be a responsible source with respect to performance of such contract opportunity; (2) The anticipated award price of the contract (including options) will exceed the

VHAPG Part 819.7008/7009 Sole Source Awards to SDVOSB/VOSB Page 2 of 4

Effective Date: 11/15/2024 simplified acquisition threshold (as defined in section 4 of the Office of Federal Procurement Policy Act (41 U.S.C. 403)) but will not exceed $5,000,000; and (3) in the estimation of the contracting officer, the contract award can be made at a fair and reasonable price that offers best value to the United States.

The implementing regulations at VAAR 819.7007 (b) & (c) [DEVIATION] state in part: (b) “The contracting officer’s determination whether to make a sole source award is a business decision wholly within the discretion of the contracting officer...” (c) “A determination that only one SDVOSB can meet the requirement is not required…”

The proposed source for this acquisition is Argent ARC LLC. They are located at 110 North Royal Street, Floor 400, Alexandria, VA 22314-3234. Argent ARC is a registered and verified SDVOSB by SBA’s Veteran’s Small Business Certification (VetCert). Argent ARC is technically qualified for this project as they have been awarded numerous VA marketing and recruiting projects including the current VHA Marketing and Recruiting contract 36C77623C0104. The most recent Contractor Performance Assessment Report (CPAR) for that contract shows Exceptional ratings for Quality, Schedule, Cost Control and Management. The contractor has three additional CPARs in the system under SAM UEID K6BVRM8LQ4Q8 dating back to 2023. All ratings are Exceptional or Satisfactory.

WMC’s technical experts involved in acquisition planning determined Argent ARC is the most qualified to perform the required services for this near-term solution, and they are considered a responsible SDVOSB. Award will be made provided that a fair and reasonable price that offers best value to the Government can be obtained.

6. Description of Efforts Made to ensure that offers are solicited from as many potential sources as deemed practicable, including whether a notice was or will be publicized as required by FAR Subpart 5.2 and, if not, which exception under FAR 5.202 applies: Special Notice of Intent to Sole Source, 36C77626Q0021 was posted to Contracting opportunities via SAM on October 17, 2025. The Notice stated that while not a request for competitive quotes, any responsible source who believes it is capable of meeting the requirements may submit a capability statement, which shall be considered by the agency by October 24, 2025. Thirteen (13) responses were received. Of the thirteen (13) responses received, five (5) of them were VetCert verified SDVOSBs.

An SBS search was performed on October 23, 2025, utilizing the NAICS 561311 and keyword ‘clinical’ (Attachment 4). There are eight (8) businesses designated as small in NAICS code(s) 561311 and include keyword(s) "clinical" in their profile. Of the eight (8) small businesses identified, three (3) of them were VetCert verified SDVOSBs.

A search of FPDS for NAICS 561311 identified five (5) VA contracts awarded in the last five years (Attachment 5). None of the contracts were for national clinical recruiting services.

A review of the Veteran Small Business Certification (VetCert) database at https://veterans.certify.sba.gov/ as required by subpart 819.70 was completed on October 20, 2025.

Argent ARC LLC is a VetCert verified Joint Venture SDVOSB.

A SAM search of Argent ARC LLC on October 20, 2025, verified the company is Active with no exclusions, and the expiration date of the registration is October 17, 2026.

VHAPG Part 819.7008/7009 Sole Source Awards to SDVOSB/VOSB Page 3 of 4

Effective Date: 11/15/2024

7. Determination by the CO that the Anticipated Cost to the Government will be Fair and Reasonable: The contracting officer will determine the price is fair and reasonable by comparing the proposed pricing to the Independent Government Cost Estimate (IGCE) per FAR 13.106-3(a)(2)(vi)) to ensure that the price is determined to be fair and reasonable before the award is made.

8. Description of the Market Research Conducted and the Results, or a Statement of the Reasons

Market Research Was Not Conducted: Pursuant to FAR Part 10, the Class Deviation – Implementation of the Veterans First Contracting Program as a result of the U.S. Supreme Court Decision (Class Deviation – Veterans First Contracting Program (VFCP 2016), VHAPM Part 810.001.

the results of the market research conducted found one (1) Service-Disabled Veteran-Owned Small Business, capable of performing the requirements. Argent ARC LLC meets the eligibility criteria outlined in VAAR 819.7003, they are verified in VetCert, and the action is below the $5M threshold.

9. Any Other Facts Supporting the Use of Other than Full and Open Competition: None per the authority under 38 USC 8127(c).

10. Listing of Sources that Expressed, in Writing, an Interest in the Acquisition:

a. Argent ARC LLC

b. Four Oaks Consulting, LLC

c. Asa Healthcare Staffing, LLC

d. Grey’s Staffing LLC

e. Govtek Recruiting LLC

f. New Healthcare Professionals, LLC

g. Lime Professionals, LLC dba Prime Care Diagnostics

h. Prometheus Federal Services, LLC

i. Solvet Services, LLC

j. Therapeutic Living

k. Sales Talent International

l. Crescent City Recruitment Group

m. The Arora Group, Inc.

n. TrueCare24

11. A Statement of the Actions, if any, the Agency May Take to Remove or Overcome any Barriers to

Competition before Making subsequent acquisitions for the supplies or services required: Given the current shortage of healthcare providers and an increasingly competitive recruitment environment, as well as the urgency of the need, this requirement is a near-term solution that will allow VHA to rapidly move on urgent mission critical recruitment needs while working on a longer-term solution. A follow-on acquisition is expected to be solicited within the next year. For that requirement, VA will perform market research to find other sources before soliciting a new award for the same or similar future acquisitions of the services being acquired.