CCAD JA (redacted).pdf

Control Number VA-20-00046153

JUSTIFICATION

FOR AN EXCEPTION TO FAIR OPPORTUNITY

1. Contracting Activity: Department of Veterans Affairs (VA) Office of Procurement, Acquisition, and Logistics Technology Acquisition Center 23 Christopher Way Eatontown, NJ 07724

2. Description of Action: The proposed action is for a hybrid firm-fixed-price (FFP) and time-and-materials (T&M) task order under the Transformation Twenty-One Total Technology Next Generation (T4NG), Contract VA118-16-D-1009.

3. Description of the Supplies or Services: The proposed action is to provide a 6-month task order for continued Community Care agile development and sustainment support services under the T4NG contract number VA118-16-D-1009 with AbleVets, LLC. VA requires a 6-month task order for the continuation Community Care Agile Software Development (CCAD) services beyond the expiration of the current task order with AbleVets to allow for key COVID-19 system capabilities to be delivered and to provide continued sustainment of the Community Care systems as it relates to the COVID-19 pandemic. The 6-month period of performance allows the clinicians and Veterans to receive immediate uninterrupted support for the COVID-19 critical CCAD systems containing a minimum of two builds for the enhancements and sustainment of the projects. In response to the COVID-19 pandemic, the Government plans to provide a sustainable backlog to support a follow-on CCAD development and sustainment contract estimated to begin in December 2020 to ascertain the required support for continued COVID-19 services and the continuation of normal project development and sustainment operations.

On March 13, 2020, the President of the United States declared the COVID-19 pandemic a national emergency. Community Care systems as part of the CCAD task order have been designated as critical systems during the COVID-19 pandemic for the Veterans Health Administration, due to the significant usage and heightened importance of the systems reliability to meet the demand being put on all healthcare facilities throughout the country. Additionally, COVID-19 invoked VA s Fourth Mission tied to national emergencies to provide support for national, state and local emergency management, public health, safety and homeland security efforts.

CCAD priority projects require continuous development, enhancement and sustainment efforts to support the COVID-19 response. Emerging Community Care COVID-19 requirements are primarily focused on optimizing existing products to ensure stability and continuity of care to Veterans, while also ensuring support for the influx of Non- Veterans. In response to the COVID-19 national emergency, Community Care must update its systems to manage the current influx of acutely ill patents. This includes enhancements and increased production support in terms of expediting eligibility, adjudicating healthcare claims, and ensuring continuity of coverage for Veterans. This must be done to ensure VA is able to rapidly address changing needs to Community Care systems as the COVID-19 pandemic continues to impact Veteran care.

Community Care Agile Development Control Number VA-20-00046153

The current task order provides development services, post deployment support and sustainment support to programs/projects under the Community Care portfolio which include projects such as Care Coordination (CC) Standard Episodes of Care (SEOC), Consult Tool Box (CTB), One Consult (OC), Decision Support Tool (DST), Enterprise Program Reporting System (EPRS) and Provider Profile Management System (PPMS), Provider Integration Engine (PIE) and Integrated Billing AR (IBAR) throughout the product lifecycle.

The total estimated value of the proposed 6-month extension is $13.4M. The period of performance of this action will be June 5, 2020 through December 4, 2020.

4. Statutory Authority: The statutory authority permitting an exception to fair opportunity is Section 41 U.S.C. 4106(c)(3) as implemented by the Federal Acquisition Regulation (FAR) 16.505(b)(2)(i)(C), which states that an exception to fair opportunity can be provided The order must be issued on a sole-source basis in the interest of economy and efficiency because it is a logical follow-on to an order already issued under the contract, provided that all awardees were given a fair opportunity to be considered for the original order.

5. Rationale Supporting Use of Authority Cited Above: The proposed source for this action is AbleVets, LLC, 15049 Conference Center Drive, Ste 25, Chantilly, Virginia 20151. AbleVets was awarded the CCAD task order on May 31, 2017 on a competitive basis under the T4NG contract vehicle. The task order is set to expire on June 4, 2020.

The work performed by AbleVets under this task order provides development services, post deployment support and sustainment support services for critical Community Care systems that facilitate the care of Veterans and currently, due to the pandemic, Non- Veterans affected by COVID-19. AbleVets releases system updates as frequently as weekly to provide critical defect resolution and new capabilities due to rapidly changing business needs for critical system features, such as the DST, CTB, EPRS, PPMS, and IBAR to ensure the systems can meet the demands of COVID-19.

The DST tool, for example, ensures that clinicians can determine a bility for Community Care and allow for unimpeded scheduling of appointments including those related to COVID-19. Uninterrupted sustainment of this system is imperative to ensure consistent and stable system performance during peak periods of demand for clinical and Veteran users of DST services.

The CTB tool is another critical system feature that allows for the rescheduling of clinical appointments that are canceled due to the prioritization of care of COVID-19 patients.

EPRS anticipates increased reporting needs and data volumes tied to monitoring and reporting of the community providers, who provide acute care inclusive of urgent/emergency care relative to COVID-19. EPRS is essential for monitoring and measuring performance of the Community Providers in areas such as provider network adequacy, urgent/emergent pharmacy prescription compliance, continuity of operations, clinical quality issues, etc.

PPMS data is utilized by Veterans to determine provider eligibility and location within the community. This is an essential tool to locate a provider in a timely manner to receive care. With the potential for system saturation, PPMS must conduct preventive maintenance rapidly to remediate emerging issues. PPMS and PIE Tier 2 and Tier 3 sustainment support needs to be appropriately staffed to support escalated COVID-19 demand on the system.

IBAR s COVID-19 response requires modifying the billing infrastructure for Urgent Care visits. These requirements support billing copay activities and creating value streams needed to manage the IBAR system, particularly at a time when copay policies are changing due to COVID-19. The current development team is highly engaged in the copay IT work through IBAR system and possess knowledge of interdependencies that is critical to expeditiously deliver COVID-19 requirements, which will be required to quickly update the IT system to align with VA policy on copays.

Even under normal conditions, Community Care development must mitigate complex transition risks. Based on contracts for similar development services, new vendors require a minimum of 3-months to fully transition and provide development and sustainment services at levels consistent with prior vendor services. The COVID-19

-organization to establish a DevSecOps model creates additional complexity during this unique time. With the COVID-19 pandemic this simply compounds and exacerbates the known risks of transition. Community Care is made up of a myriad of unique products integrated with numerous upstream and downstream systems built to stringent clinical specifications. Although the technology employed is common to industry, what is uncommon is the technical competency to understand hundreds of complex workflows and data variations that are inherent to Community Care requirements that can only be learned through clinical collaboration. To obtain the spatial and relational knowledge to develop technologies that safely meets clinical specifications requires clinical staff to orientate technologists to Community Care clinical workflows. With clinical staff already overburdened to focus on COVID-19 care, knowledge transfer will be impeded significantly and this additional complexity would further delay a new vendor in being able to understand the clinical aspects of the technical workflows and provide support at the level the current environment requires. Given these additional complexities it is estimated that a vendor, other than AbleVets would require between 3-6 months to onboard and to develop sound knowledge of complex workflows to capably fulfill requirements The current vendor has unique understanding of the clinical aspects of the technical workflows that potentially could take up to 3 months or longer to obtain culpable knowledge .

As an additional concern, COVID-19 has slowed onboarding due to VA medical centers limiting access, fingerprinting and Personal Identity Verification (PIV) delays, and other issues resulting from COVID-19 safety and social distancing measures. For example, the VA Central PIV Office has been operating only 40 percent of the time since impacted by COVID-19. Prior to COVID-19, the PIV Office was open five days a week, and since the pandemic, the PIV Office is PIV Office is only open 2 days a week. The reduced operating capacity of an essential function for onboarding Contractors will negatively impact the ability of new contract team members to gain access to the VA network. Onboarding delays translate to technical constraints as the timeliness of onboarding technical staff with account access and provisioned to VA environments will be delayed. As the federal government response to COVID-19 continues to evolve delays due to onboarding are unpredictable. A new vendor would be technically constrained due to onboarding delays and the impact would negatively delay or prevent the ability to employ diverse tool sets not commonly used in the VA for DevSecOPs relative to container management and automatic scaling, inability to establish local environment in VA instance to take on all builds, knowledge management, and help desk support services, and an inability to immediately provide operational maintenance of systems, no system administration, no account management, no defect remediation

Furthermore, time for the transference of knowledge would be required before a new source could perform at the current performance levels. With the immediate need for COVID-19 requirements, transitioning CCAD services to another source and meeting the rapidly increasing demands on the systems as a result of COVID-19 would have significant risks and issues. Onboarding of a new team to meet the immediate COVID- 19 needs that are estimated for a short 6-month period of performance would eliminate duplicative costs estimated at approximately $868K -1.25M per month related to labor and staffing leading to potential high risk delays to the urgent CCAD system needs in order to keep the current release schedule on track for immediate VA needs. The cost to onboard a new vendor in the short span of the new order would not be recovered through competition and could result in substantial duplicated cost and possible delays to the requirements enhancement and sustainment schedule. If a new vendor were onboarded and any gap in service or lack of full staff support could lead to delayed or failed releases due to insufficient staffing, all of which are unacceptable during the COVID-19 pandemic. VA is experiencing an increase of usage on critical CC systems and therefore needs to ensure the continuity of CCAD services to guarantee the reliability of its system performance, which will ultimately allow for the continuity of care to Veterans and Non-Veterans (VA Fourth Mission), as well as COVID-19 patients that are overwhelming the healthcare facilities on a daily basis. The continuation of CCAD services by AbleVets will expeditiously facilitate faster medical access for Veterans and Non-Veterans suffering from COVID. A lapse in these critical services would result in degradation in the coordination of care with healthcare providers thereby impeding access to healthcare for Veterans and Non-Veterans alike.

Awarding the proposed action as a logical follow-on is the most efficient manner for VA to obtain the required development services, post deployment support and sustainment support in support of COVID-19 requirements for Community Care s critical systems.

AbleVets is the only source that can provide the required services without a lapse in service. In addition to having the staff with the requisite security clearances, AbleVets is the only source with the domain knowledge surrounding the CC program to provide rapid capabilities in response to COVID-19 and ongoing critical maintenance.

6. Efforts to Obtain Competition: Market research was conducted, details of which are in the market research section of this document. This effort did not yield any additional sources that can meet the G equirements. There is no competition anticipated for this acquisition. In accordance with FAR 5.301 and 16.505(b)(2)(ii)(D), the award notice for this action will be synopsized on the Federal Business Opportunities Page (FBO) and the justification will be made publicly available within 14 days of award.

7. Actions to Increase Competition: The Government anticipates competing future CCAD requirements prior to the expiration of this 6-month effort. The planned acquisition request for a new task order is planned for submission in 3rd quarter fiscal year (FY) 2020 for requirement needs for the CCAD support services to award at the completion of this effort and awarded in FY21.

8. Market Research: Market Research was performed as part of an assessment of needs in March 2020 when urgent needs for COVID-19 impacts to clinicians were identified. Market Research was performed by researching various Contrac capabilities under T4NG. VA technical experts reviewed the capabilities of the T4NG prime contract holders and existing vehicles to potentially leverage for the required CCAD support, such as the Health Integration and Modernization task order with Liberty IT Solutions. It was determined that none of the T4NG prime contract holders are able to employ the diverse tool sets used in VA for DevSecOPs relative to container management and automatic scaling and complete a minimum of two COVID 19 builds by December of 2020. Additionally, none of the T4NG prime contract holders are able to establish a local environment to take on all builds; knowledge management; help desk support services without a lapse in service or be able to immediately provide operational maintenance of systems, system administration, account management, or defect remediation. While T4NG prime contract holders have the general capabilities to meet the CCAD requirements, none could ents in a seamless manner within the immediate timeframe required. Additionally, AbleVets has the already established processes in place and possesses the technical expertise of complex workflows and data variations unique to Community Care requirement and they possess the experience specific to the development services.

9. Other Facts: None.

Approval

In my role as procuring activity Advocate for Competition, based on the foregoing justification, I hereby approve the acquisition of a 6-month task order for development services, post deployment support and sustainment support on the Community Care Agile Software Development (CCAD) task order on an other than fair opportunity basis pursuant to the authority cited in Section 4 above, subject to availability of funds, and provided that the property and services herein described have otherwise been authorized for acquisition.

Date: ____________ Signature

Advocate for Competition Technology Acquisition Center

Office of Procurement, Acquisition, and Logistics