CHAT BOT - JA FAR Part 6 2024 - Redacted.pdf

DEPARTMENT OF VETERANS AFFAIRS

Office of Procurement, Acquisition and Logistics (OPAL)

Strategic Acquisition Center (SAC) 5202 Presidents Ct, Suite 103

Frederick, MD 21703

JUSTIFICATION AND APPROVAL

FOR OTHER THAN FULL AND OPEN COMPETITION

(1) Identification of the agency and the contracting activity

This Justification and Approval (J&A) for Other Than Full and Open Competition is executed by the Strategic Acquisition Center (SAC), on behalf of the Department of Veterans Affairs (VA), Veterans Health Administration, Office of Mental Health.

(2) Nature and/or description of the action being approved.

This activity proposes to negotiate a non-competitive (sole source) Firm Fixed Price (FFP) award to Aurelius Talent Solution LLC, a Service-Disabled Veteran Owned Small Business (SDVOSB), Unique Entity ID (UEID): EH1WWE7KUFT7. The required services are for a Simulated Orator to Promote Help-seeking and Recovery, Orient Self-care, and Yield Native Engagement (SOPHROSYNE): A Chatbot/Interface to Support Motivational Interviewing and Care Navigation to Encourage Reduced Substance Use.

(3) A description of the supplies or services required to meet the agency’s needs (including the estimated value).

The Contractor shall develop a prototype of a tool to support brief self-guided interventions for drug use. This effort will cover iterative development and usability testing of a prototype, with the expectation that subsequent to this effort this prototype would be additionally pilot tested for use in a VA primary care setting with patients with medical record signs of drug use to determine clinical value.

The Contractor shall provide iterative development and usability/acceptability testing of a prototype interactive interface to support patient education and build motivation and goals for reducing drug use. The application must utilize a Motivational Interviewing-informed approach and VA approved educational content. Use of chatbot functionality is encouraged to increase accessibility and patient engagement. Design should be optimized to maximize patient acceptability and perceived usefulness, while maintaining accuracy of presented content. The prototype must be developed within VA environments that allow for national deployment if the prototype is found to have clinical benefit (e.g., the VA Microsoft Copilot for Azure environment, if chatbot functionality is utilized). The total estimated value of the proposed action is

• The anticipated period of performance is:

o Base Period: September 29, 2024, - September 28, 2025 o Option Period 1: September 29, 2025 – September 28, 2026

(4) An identification of the statutory authority permitting other than full and open competition.

The statutory authority permitting other than full and open competition is 41 U.S.C. § 3304(a)(5) as implemented by the Federal Acquisition Regulation (FAR) Subpart 6.302- 5 entitled, “Authorized or required by statute”. The applicable statute is Public Law 109- 461: “Veterans Benefits, Health Care, and Information Technology Act of 2006” specifically, the “Veterans First Contracting Program” outlined in 38 USC § 8127(c) and VAAR 806.302-570(c).

(5) A demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited.

The proposed source for this acquisition is a certified SDVOSB, Aurelius Talent Solution LLC (Aurelius TS). Aurelius TS came to our attention through the Request for Information (RFI) process. This SDVOSB possesses over 16 years of experience as software developers in the healthcare domain and offers a unique combination of technical expertise in chatbot development and Microsoft Azure environments plus clinical expertise in mental health and substance use disorder treatment. While other vendors offer experience in chatbot development, only Aurelius TS additionally offers subject matter experts with clinical training as Licensed Alcohol and Drug Counselors, Licensed Clinical Social Workers, Licensed Mental Health Counselors, or medical doctors.

The availability of clinical substance use disorder subject matter experts makes Aurelius TS uniquely qualified to meet acquisition requirements. SOPHROSYNE chatbot development will require generation of logic and text that are adherent to Motivational Interviewing, and support evidence-based and clinically appropriate treatment for substance use disorders. The clinical training of team members should enable Aurelius TS to develop clinically appropriate messaging for Veteran chatbot users. Aurelius TS has already successfully implemented AI-driven chatbots for mental healthcare providers utilizing Microsoft Azure tools.

Aurelius TS is proficient in using cloud platforms, particularly Microsoft Azure, for scalable and secure solutions. They have extensive experience with Azure services such as Azure DevOps, Azure Bot Service, Azure Kubernetes Service, and Azure Functions. They possess a strong background in cybersecurity best practices, having conducted security assessments, identified PHI, and ensured HIPAA compliance.

Additionally, their expertise with tools like Microsoft Defender for Cloud and Azure Security further ensures robust security measures.

Most notably, the Aurelius TS team includes members who are not just mental health professionals, but who also have first-hand experience with mental health issues and substance abuse and are currently in recovery. This ensures a deep understanding of the challenges and needs in this domain and provides an informed perspective in designing and responding to usability and acceptability feedback. This collective expertise is crucial for developing effective solutions that support motivational interviewing and care navigation. Given personal and professional insights, Aurelius TS is well positioned to generate empathetic and impactful tools that resonate with users, ultimately enhancing the effectiveness of the SOPHROSYNE initiative.

VAAR 819.7008(c) and VAAR 819.7009 states explicitly, “A determination that only one SDVOSB can meet the requirement is not required,” and that using this authority, the following must be verified:

(1) The anticipated award price of the contract (including options) will not exceed $5 million.

(2) The justification prepared pursuant to FAR 6.302-5(c)(2)(ii) is posted in accordance with FAR subpart 5.301(d). This J&A will be posted on SAM.gov

(3) The SDVOSB concern has been determined to be a responsible source with respect to performance; and

• Aurelius Talent Solution LLC is a registered and verified SDVOSB.

• The proposed action meets all three requirements of 38 U.S.C. 8127(c);

• Is verified by the Small Business Administration (SBA) Veteran Small Business Certification (VetCert) database as owned and controlled by a Veteran.

• Possesses the capability to provide the required services and has over 16 years of experience as software developers in the healthcare domain and has successfully developed AI-driven solutions, particularly in natural language processing (NLP) and machine learning.

• Is determined to be a responsible source with the required knowledge, capabilities, and expertise.

(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.

IAW VAAR § 819.7008(b) and (c), sole source awards to service-disabled veteran-owned small business concerns: The contracting officer’s determination whether to make a sole source award is a business decision wholly within the discretion of the contracting officer. To ensure that opportunities are available to the broadest number of SDVOSBs, this authority is to be used only when in the best interest of the Government. A determination that only one SDVOSB concern is available to meet the requirement is not required. In accordance with 819.7007(b), the determination to make a sole source award to an SDVOSB is a business decision wholly within the discretion of the contracting officer; therefore, the requirement to ensure that offers are solicited from as many potential sources as practicable is not applicable to this procurement. In addition, 819.7007(c) further authorizes the contracting officer to make the award without first determining that only one SDVOSB source can meet the requirement.

A notice of the proposed action will be synopsized via the Government Point of Entry (GPE) in accordance with FAR Section 5.201, and the agency will make publicly available the justification required by 6.305(a) within 14 days after contract award.

(7) A determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable.

No award shall be made until the Contracting Officer determines the cost to the Government to be fair and reasonable. This determination will be based on a comparison of current contract pricing, an Independent Government Cost Estimate, past proposal submissions (if available), and other information as made available.

(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 was conducted by reviewing the websites GSA Advantage; SBA Certification Database; and GSA e-library. Market research included searching for the skills of IT Scrum Master, Data Architect, Agile Developer, Psychologist, Program Manager, Project Manager, Human Factor Specialist/Engineer, and Computer Scientist/Systems Analyst. No one vendor was found to have all the skills we searched for, but the following companies had one or more of the requested skills: Phoenix Team, Agility Consulting International, Snowbird Agility, Novo ProSo Ince, Linkware, Cadre, Your Wellness sources, Platinum Business corporation, Federal Staffing Resources, Project Management Experts, Sophic Synergistics, CGH Technologies, and Joint Venture Solutions.

Aurelius TS has successfully supported Department of Defense and Library of Congress in similar efforts and has been determined to be a responsible source with respect to performance. They are registered and verified in VetBiz.gov as a SDVOSB with the NAICS code 541519 for this requirement which in accordance with Public Law 109-461, Section 502(c) meets the requirements of this statute to allow a sole source to a SDVOSB.

In addition, the Federal Awardee Performance, and Integrity Information System (FAPIIS) was reviewed and FAPIIS shows no reports for Aurelius TS that would indicate defective pricing, instances of contractor fault or recipient not- qualified, terminations for cause, default, material failure to comply, or non-responsibility of the contractor.

(9) Any other facts supporting the use of other than full and open competition.

The procuring Contracting Officer has determined that this proposed action meets all the requirements of 38 U.S.C. 8127(c). This acquisition is below the $5,000,000.00 threshold, Aurelius TS is a responsible SDVOSB for performance of the services described herein, and the proposed contract can be awarded at a fair and reasonable price.