C38_SOA_JOFOC_Redacted_1.pdf
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- Solicitation number
- 140D0426Q0154
About this file
This document is a Justification for Other Than Full and Open Competition for the Department of Interior's Indian Health Services (IHS).
The Department of Interior is pursuing a sole-source, follow-on procurement with an incumbent contractor to continue providing behavioral health and primary care services across IHS, Tribal, and Urban Indian health programs. The services include screening for mental health and substance use disorders, assessment and diagnosis of suicidality and trauma, patient-centered treatment planning, evidence-based outpatient behavioral health and substance use treatment, crisis intervention, peer support, and comprehensive care coordination. The requirement is set-aside for Indian-owned businesses under the Buy Indian Act authority (41 U.S.C 1901). The underlying Purchase Order (140D0421P0043) expires May 24, 2026, and this follow-on will extend services through March 2027 to support grant close-out activities and post-award sustainability planning. Market research identified only one potential Indian Small Business Entity (ISBEE) capable of performing the work; approximately five additional Native American-owned small businesses were identified but lacked relevant performance histories and key service capabilities. The Contracting Officer determined that transitioning to a new vendor would require 7-13 months (typically 9-12 months) for procurement and transition, creating unacceptable risk of service disruption to vulnerable AI/AN populations. The incumbent contractor possesses established relationships with 14 IHS, Tribal, and Urban Indian Organization grantees and institutional knowledge of culturally informed, trauma-informed service delivery that cannot be quickly replicated. The Contracting Officer will conduct a cost/price analysis to ensure fair and reasonable pricing and will pursue competition in future acquisitions if qualified Indian-owned vendors develop market capacity.
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Solicitation: 140D0426Q0154 capable of meeting the Government’s urgent requirements with minimal transition risk.
Transitioning to a new vendor for the continuity of behavioral health and primary care services across IHS, Tribal, and Urban Indian programs would require a lengthy timeline due to the specialized, high-touch, and culturally informed nature of the work. These services support trauma-informed care, substance-use treatment, chronic-disease identification, and coordinated technical assistance functions that depend heavily on established relationships, active program cycles, and deep familiarity with Tribal and Urban Indian health systems.
If a sole-source is not implemented and a full competition is required, the combined procurement and transition period would realistically take 7–13 months, with 9–12 months being the most typical. This includes:
• 4–7 months for the competitive procurement (planning, solicitation, evaluation, award)
• 3–6 months for onboarding, knowledge transfer, and re-establishing coordination across IHS, Tribal, and Urban Indian partners
Because these services are integrated into ongoing grant cycles, program activities, and multi-stakeholder coordination structures, changing vendors too quickly would risk a disruption to critical behavioral-health and primary-care support for AI/AN communities.
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.
The exemption is RFO FAR 5.101(b)(2) – Using other than full and open competition.
7. A determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable.
The Contracting Officer will ensure all supplies and services sole sourced are procured at a fair and reasonable cost/price. In determining the cost/price fair and reasonable, the Contracting Officer will ensure that a thorough and detailed cost/price analysis is documented in the contract file. At a minimum, this analysis will include comparison of the offered cost/price to market pricing.
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.
Market Research for this requirement was conducted IAW RFO FAR Part 10, which
Solicitation: 140D0426Q0154 appropriate program frameworks, and recreating training and technical‑assistance materials, resulting in substantial delays and gaps in service delivery. Such a break in continuity would jeopardize critical behavioral‑health integration activities, impede early‑intervention capabilities, and negatively affect access to care for AI/AN communities. These disruptions would cause significant harm to the Government’s ability to meet program objectives and would place vulnerable populations at increased risk.
10. A listing of the sources, if any, that expressed, in writing, an interest in the acquisition.
There are no additional sources to list for this acquisition.
11. A statement of any 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.
DOI is demonstrating its commitment to Indian economic development through its Buy Indian Act implementation of procurement authorities that maximize the number of DOI contracting opportunities available to ISBEEs and IEEs. As a result, DOI does not anticipate removing or overcoming any barriers to competition for any subsequent acquisitions for supplies and services that can be set-aside for ISBEEs or IEEs.
The absence of eligible vendors today does not eliminate the potential for future competition. ISBEE and IEE capacity can evolve over time as new firms enter the market, expand their service offerings, or form partnerships to meet federal requirements. Therefore, while this acquisition cannot be competed among ISBEEs/IEEs, future requirements may be competed if market research identifies qualified Indian-owned vendors.
In short, current non-availability does not predetermine future non-availability, and the Government remains committed to competing future requirements among ISBEEs/IEEs if vendor capability develops.
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