C01 - REDACTED JA OTFOC HCIdM P00004 36C77624P0073_Redacted_.pdf

VHAPG Part 806.3 OFOC Page 1 of 5 Revision: 04 Effective Date: 12/15/25 Acquisition ID#: 36C24C-26-AP-0213

DEPARTMENT OF VETERANS AFFAIRS

Justification and Approval (J&A) For

Other Than Full and Open Competition (>SAT)

Acquisition Plan Action ID: 36C24C-26-AP-0213

Contracting Activity: Department of Veterans Affairs, Regional Procurement Office Central, Supplies & Services Division, 1639 Medical Center Pkwy, Suite 204, Murfreesboro, TN 37129. The Purchase Request Number associated with this action is 776-26-4-3201-0029.

Nature and/or Description of the Action Being Approved: The purpose of this justification is to modify contract number 36C77624P0073 for Healthcare Identity Management (HCIdM) Support in accordance with Revolutionary FAR Overhaul (RFO) Part 6.101 which requires Contracting Officers (C s) with certain limited exceptions, to promote and provide for full and open competition in soliciting offers and awarding Government contracts. More specifically, the modification will increase the monthly quantities of CLINs 2001, 3001, and 4001, for Monthly Potential Duplicate Records Support, and CLINs 2002, 3002, and 4002, for Monthly Identity Trait Data Anomaly Resolution and Support with Change/Verification Requests.

Description of Supplies/Services Required to Meet the Agency’s Needs: The Veteran and Family Member Programs (VFMP) Office has increased its resourcing dedicated to entering within the VA Master Person Index (VA MPI). VFMP was modernized and integrated into the Veterans Health Administration Enrollment System (VES) in December 2025 when 1.2 million records from the legacy system were migrated. Although VFMP undertook some data cleanup efforts before the go-live and migration, numerous discrepancies were discovered after migration including for the primary traits of Birth Sex, Name, Social Security Number, and Date of Birth, causing issues with VFMP beneficiaries being incorrectly identified as ineligible for Civilian Health and Medical Program of the Department of Veterans Affairs (CHAMPVA) healthcare benefits, including critical pharmacy benefits. he Health Care Identity Management (HCIdM) Program operates within the Veterans Health Administration’s (VHA) Data Quality Program. The HCIdM Program’s primary role is to serve as the steward of patient and beneficiary identity data, performing data integrity tasks to maintain and support the Veterans Identity, traits and their subsequent VA system records linked to the identity. The Identity Management Toolkit (IdM TK) is utilized to update beneficiary records. The VA MPI is a database that holds over 77 million unique entries and is populated by patient and beneficiary databases at VA facilities nationwide. The VA MPI provides the mechanism for linking the patient or beneficiaries’ information, enabling an enterprise-wide view of individual and aggregate electronic healthcare records and

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Acquisition ID#: 36C24C-26-AP-0213 their other beneficiary records. VA has partnered with the DoD to share a single Electronic Health Record Management System (EHRM) based on the Oracle Health Millennium product for use in providing care to both DoD and VA patients.

EHRM uses the DoD Defense Enrollment Eligibility Reporting System (DEERS), as the authoritative source of identity information in Oracle Health Millennium, and the DoD's Electronic Data Interchange Personal Identifier (EDIPI) as the unique identifier for the shared system. Creating and maintaining a correlation between these records and ensuring that they all identify a single individual, relies heavily on the integrity of the data within the VA MPI.

Due to this increased resourcing, starting immediately, VFMP anticipates sending between 200 to 300 IdM TK requests per day to the Health Care Identity Management (HC IdM) Team via the IdM TK for resolution. For reference, historically, 300-350 duplicate requests/tasks were sent per month.

The goal of this surge is to decrease VFMP’s inventory of identity data quality anomalies documented in their Customer Relationship Management (CRM) system, in parallel with proposed Artificial Intelligence (AI) solutions for batch resolution of VFMP identity issues.

The contract is currently in Option Year one (1). A modification to exercise Option Year two (2) with a period of performance of 08/19/2026-08/18/2027 was awarded on March 13, 2026 at a cost of $819,886.80. The request is to increase Option Year (2) funding from $819,886.80 to an IGCE estimated amount of

, which includes an optional CLIN of to further increase quantities that will not be exercised at time of modification award. Additionally, the modification request is to similarly increase spending for future option years three

(3) and four (4). Option Year three (3) will increase from 8 ,261.64 to including an optional CLIN to further increase quantities. Option Year Four (4) will increase from $ that includes an optional line item for transitional services when the contract ends to including the optional CLIN to further increase quantities. The Total Contract Value will increase from $4,314,359.79 to an increase of

4. Statutory Authority Permitting Other than Full and Open Competition:

(X) (1) Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements per 41 USC §3304(a)(1) as implemented by RFO 6.103-1;

( ) (2) Unusual and Compelling Urgency per 41 USC §3304(a)(2) as implemented by RFO 6.103-2;

( ) (3) Industrial Mobilization, Engineering, Developmental or Research Capability or Expert Services per 41 USC §3304(a)(3) as implemented by RFO 6.103-3;

( ) (4) International Agreement per 41 USC §3304(a)(4) as implemented by RFO 6.103-4 ( ) (5) Authorized or Required by Statute per 41 USC §3304(a)(5) as implemented by RFO 6.103-5;

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Acquisition ID#: 36C24C-26-AP-0213

( ) (6) National Security per 41 USC §3304(a)(6) as implemented by RFO 6.103- 6;

( ) (7) Public Interest per 41 USC §3304(a)(7) as implemented by RFO 6.103-7;

5. Demonstration that the Contractor’s Unique Qualifications or Nature of the Acquisition Requires the Use of the Authority Cited Above (applicability of authority): The current contractor completing this work under contract 36C77624P0073 is EM Key Solutions, Inc. (EMKS), a Service-Disabled Veteran- Owned Small Business (SDVOSB). EMKS has trained staff and processes in place that are currently supporting duplicate records and identity trait anomaly resolution as well as monthly metric reports. With this modification, staff will be completing a higher quantity of resolutions per month. This service is an immediate need and any loss of support will result in delays correcting veteran beneficiary records.

Utilizing EMKS and the current contract is more cost effective than re-solicitating for a short term contract to complete a greater quantity of the current work.

Only One Responsible Source (RFO 6.103-1) – This action is for continued support of highly specialized services. It does not extend the period of performance and only seeks to increase the quantity of the contract’s CLINs per month within the existing periods of performance. Re-solicitating for the greater quantities would result in substantial duplication of cost to the government that is not expected to be recovered through competition. The HC IdM contract 36C77624P0073 was competitively awarded, and option-year rates were found fair and reasonable at time of award.

The requirement amount of increases the quantity of record corrections completed per month and also adds an optional CLIN to exercise should an additional increase be required due to the priority given to reduce the backlog of duplicate records and anomaly resolutions created by the migration of two record systems.

The current contractor EM Key Solutions, Inc is meeting or exceeding all performance metrics and fully understands the requirement. The most recent CPARS evaluation completed on this contract is for the period of 08/19/2024 - 08/18/2025, and three “Exceptional” ratings were given for quality, schedule and management and one “Very Good” rating was given for regulatory compliance.

If the resources of the HC IdM Support contract must concentrate its effort to this influx of VFMP requests, it will require HC IdM to pause identity anomaly resolution in VistA for several integrated partners. Additionally, the contractor has confirmed they can increase support for the contract within the requested time frame of thirty days. Accordingly, EMKS is the only firm capable of providing the supplies and services described in Section III above without the Veteran’s Health Administration experiencing unacceptable delays in fulfilling its requirements.

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Acquisition ID#: 36C24C-26-AP-0213

6. Description of Efforts Made to ensure that offers are solicited from as many potential sources as possible: The contractor is an SBA SBS verified SDVOSB and capable of completing the requirement. The justification will be posted to Contracting Opportunities via SAM.gov in accordance with RFO Part 5 and RFO Part 6.

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 pricing to the Independent Government Cost Estimate (IGCE) per RFO 15.404-1 (b)(5) and in comparison to historical prices paid for the same or similar items per RFO 15.404-1 (b )(2) (previously referenced under FAR 13.106-3) 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: SBA Small Business Search was utilized to verify the contractor’s small business certification as an SDVOSB. CPARS was utilized to review the contractor’s past performance for the same or similar services. Additionally, as stated above in Section 6, The justification will be posted to Contracting Opportunities via SAM.gov in accordance with RFO Part 5 and RFO Part 6.

9. Any Other Facts Supporting the Use of Other than Full and Open Competition: None.

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

a. EM Key Solutions, Inc., 2000 Park St. N., Saint Petersburg, FL 33710

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: To remove or overcome any barriers to competition before future acquisitions for the same supplies and services are conducted at the system’s end of life, the VA will ensure extensive market research is performed in a timely manner to evaluate vendor capabilities and further research if opening competition to all brands of evidence-based workflow management solutions that can potentially meet the Government’s requirements. Further, the Government will continue to conduct market research to ascertain if there are changes in the marketplace that would enable future actions to be completed.

12. Requirements Certification: I certify that the requirement outlined in this justification is a Bona Fide Need of the Department of Veterans Affairs and that the supporting data under my cognizance, which are included in the justification, are accurate and complete to the best of my knowledge and belief.