Consolidation DnF_508-24-106_Rev_Redacted.pdf

ATTACHMENT VAAM M807- C

Consolidation Determination and Findings

Project 508-24-106 | Correct Electrical Deficiencies | Atlanta, GA VAMC

36C247-26-AP-0501

FINDINGS

I. INTRODUCTION

The Network Contracting Office (NCO) 7 plans to solicit offers for the Department of Veterans Affairs, VISN 07, Atlanta, GA VA Medical Center (VAMC) and has conducted market research that demonstrates consolidation of this procurement to be both necessary and justified.

II. BACKGROUND

A. Requirement

This proposed contract action will be for the acquisition of construction services to correct electrical deficiencies at three Atlanta, GA VAMC sites. A new, not previously acquired, Firm Fixed Price construction contract is contemplated for this proposed acquisition. Design was completed for this construction project under contract number 36C24723C0105.

The contractor shall provide all resources necessary to accomplish the deliverables for correcting electrical deficiencies at three Atlanta, GA VAMC sites. Site addresses and facility building numbers are outlined below:

Joseph Maxwell Cleland VA Medical Center (Main Campus located at 1670 Clairmont Rd, Decatur, GA 30033) o Buildings A, B, C Trinka Davis Village (located at 180 Martin Drive Carrollton, GA 30117) o Building 508 Fort Mcpherson (located at 1701 Hardee Avenue SW Atlanta, Ga 30310) o Buildings 125, 128, 129, 130 & 131

The purpose of this project is to correct, replace, and upgrade AVAHCS-owned facilities’ Facility Condition Assessment (FCA) deficient electrical equipment. The project will include, but is not limited to, replacing and upgrading panelboards, circuit breakers, transformers, disconnects, conductors, automatic transfer switches (ATS), fuses, and other electrical equipment as required and hazardous material abatement. The contractor shall conduct an on-site evaluation and analysis and collaborate with the Medical Center’s Facility Management Service and other VA Services on utility requirements including but not limited to the mechanical, electrical, fire protection, plumbing, communications, access controls, and plumbing. The contractor shall furnish all materials, equipment, supervision, and personnel necessary to accomplish the project. Work shall meet all applicable codes and regulations, drawings, and is subject to the terms and conditions of the contract.

The estimated value of this construction project is , and the Period of Performance is planned for 365 calendar days from the Notice to Proceed (NTP) date. The estimated award date for the proposed contract is approximately

/2026. The NAICS for this requirement is 238210, Electrical Contractors and Other Wiring Installation Contractors, with a Small business size standard of $19 million.

The proposed acquisition method for this requirement is a Sole Source contract to a responsible and capable Service-Disabled Veteran Owned Small Business (SDVOSB), The Government plans to sole source to a responsible and capable SDVOSB, DAX SAFETY & STAFFING SOLUTIONS LLC. The determination that only one SDVOSB can meet the requirement for this acquisition is not required since the authority above (i.e., VAAR 819.7008) allows sole source awards to SDVOSBs based on 38 U.S.C. 8127(c), and the SDVOSB concern, DAX SAFETY & STAFFING SOLUTIONS LLC has been determined to be a responsible source with respect to performance. DAX SAFETY & STAFFING SOLUTIONS, LLC will be required to meet business eligibility requirements as listed in VAAR 819.7003 (DEVIATION) prior to award.

Consolidating this requirement offers tremendous value to the Government and the VA mission by significantly reducing procurement lead times, streamlining contract administration, providing much faster project delivery, enhancing consistency and quality control, and allowing for cost and resource efficiencies.

There are no regional or Agency-wide contract implications since this project is limited to work at VA hospitals under the leadership of the Atlanta, GA VAMC. Since it is the VA’s plan to sole source this requirement to a capable SDVOSB vendor, there is no known negative effect on Small Businesses, and there are no set-aside issues to note since it is within the authority of the Contracting Officer to sole source to an SDVOSB concern that has been determined responsible with respect to past performance (see VAAR 819.7008).

B. Applicable Statutes/ Regulations

The Revolutionary Far Overhaul (RFO) 2.101 defines a Consolidation or consolidated requirement as “a solicitation for a single contract, a multiple-award contract, a task order, or a delivery order to satisfy” including “(ii) Requirements of the Federal agency for construction projects to be performed at two or more discrete sites.” Since this requirement will take place over three discrete sites for the Atlanta, GA VAMC, it is magnitude is between $2-5 million.

considered a consolidated acquisition. Therefore, the additional requirements at RFO 7.107 apply, and there is no exception in paragraph 7.107-1(c).

C. Market Research

Market research has been conducted in accordance with RFO 10 and has demonstrated that Consolidation is justified.

Market research shows availability of numerous qualified SDVOSB contractors under NAICS 238210, with 2,906 nationwide and 167 located in Georgia, and outreach performed by the COR confirmed interest from multiple firms. Although a competitive SDVOSB set-aside would likely result in fair, reasonable offers from responsible vendors, consolidating the work into a sole source contract with DAX Contracting Solutions (an SDVOSB already known and vetted by the local Engineering team) will significantly reduce administrative burden and accelerate project delivery to meet VA requirements. The Market Research report is available in the contract file.

Notifications.

This Determination and Findings form has been coordinated with the Office of Small Disadvantaged Business Utilization for the Department of Veterans Affairs, as evidenced by the signature block on the last page of the document. No incumbent small business concerns were contacted since this is a new, non-recurring requirement that is being consolidated (without bundling), and there is no prior small business involvement.

III. CONSOLIDATION

A. Benefits – The following benefits will come from consolidating this requirement:

1. Contract Administration Efficiency – Contract management will be simplified with a single point of contact, schedule, and reporting. Administrative burden is reduced for contracting and engineering oversight and payments. This project was also designed to be one project and not split into three separate projects.

Splitting the project will cause unnecessary overcomplication of a project intended to be completed with one prime contractor during construction.

2. Faster Procurement Timeline – If required to sole source for each discrete location individually, the Government would need to split the requirement into three separate procurement packages, each requiring its own evaluation and award cycle. While sole sourcing is more efficient than a full competitive procurement, handling three separate awards would still add administrative burden and extend the overall timeline. By consolidating into a single sole source package, the Government can realistically expect to save 3 to 6 months in award timeline, compared to issuing and processing multiple separate sole source actions for each site.

3. Continuity in Workmanship & Project Knowledge – Consolidation will ensure that the same contractor manages all three locations, improving consistency in standards, materials, safety practices, and quality of work. This continuity also reduces risks of miscommunication or inconsistencies between multiple contractors.

4. Enhanced Coordination & Scheduling – A single awardee can optimize scheduling, labor, and resource allocation across all locations. There would also give greater flexibility to respond to unforeseen issues or necessary changes (e.g., modifications).

5. Cost Savings/Potential Economies of Scale – Bulk procurement of materials and better project management may reduce overall costs to the Government through a lower offer price. Having one contractor and contract (rather than three) would also reduce duplicative contractor mobilization/demobilization expenses.

6. Lowered Contractual Risk – With fewer contracts and contractors involved, there would likely be fewer contractual disputes, and it would streamline risk management, bonding, and insurance processes.

7. Stronger SDVOSB Engagement – The strategy to sole source to a responsible and capable SDVOSB in a consolidated acquisition such as this directly supports the VA’s mission to maximize awards to SDVOSBs and builds contractor capacity with more substantial projects.

8. Simplified Communication – There will be a single contractor for the CO and/or

COR to engage, train, or brief regarding sensitive environments or compliance (e.g., infection control, safety, campus policies).

B. Procurement strategy – A Sole Source strategy is to be implemented with this acquisition. This will reduce the amount of time required to award the contract by several months which, combined with the time saved through consolidation, could allow the Government to reduce construction completion time by over a year.

C. Alternative approaches – Several alternative contracting approaches were considered in accordance with RFO 7.107-1(a)(2). However, none would meet the Government’s needs as effectively, efficiently, or economically as the proposed consolidated procurements.

One option considered was to solicit and award separate contracts for each discrete site (i.e., each of the three sites for the Atlanta VAMC) utilizing open-market procedures under RFO Parts 14 or 15 and RFO 36. Another option would be to award three separate non-competitive, sole source contracts to an SDVOSB at each discrete site using the authority found at 41 USC §3304(a)(5), 38 U.S. Code § 8127(c), as implemented by RFO 6.103-5 (Authorized or Required by Statute) and VAAR

819.7008 (DEVIATION).

While evaluating these approaches, the CO reached out to the Architect Engineer (AE) firm who designed the project for them to estimate costs for construction if the project were to be consolidated versus not consolidated. The AE estimated that the construction cost, if consolidated, would be . If not consolidated, the costs would be for the Fort McPherson site, for the Atlanta Main Campus, and for the Trinka Davis site. The total estimated cost for the non-consolidated project would therefore be , which is more than the cost for a consolidated project.

Although RFO 14 or 15 open market procedures or sole sourcing for each discrete site may seem to allow for greater tailoring to each site’s unique requirements, it would actually result in higher overall construction costs (as shown by the AE estimates), fragmented implementation, increased administrative complexity, and a substantial duplication of effort across acquisition, project management, and oversight functions. The inefficiencies inherent in managing multiple concurrent solicitations and contracts would also strain limited personnel resources. For these reasons, the alternatives to consolidation were determined to be not in the best interest of the Government.

D. Negative impact – Analysis shows that alternative, less consolidated contracting approaches would have pronounced negative consequences for the Government.

Dividing the project into multiple smaller contracts, as confirmed by the AE firm, would increase construction costs by roughly 14%. The splitting of this requirement would cause duplication of effort, additional contractor mobilizations, and the inability to achieve bulk purchasing discounts. Multiple contracts may also require substantially more AE site visits, reviews, and administrative oversight, placing a heavy strain on Government staff and resources. Managing several contractors and overlapping timelines could also complicate maintenance and future upgrades, thus increasing lifecycle costs. Importantly, the likelihood of bid protests and associated legal costs grows with the number of solicitations, leading to potential delays, elevated administrative expenses, and operational risk.

Altogether, these likely negative impacts – including higher costs, increased resource demands, schedule delays, and additional legal exposure – demonstrate that less

Note: Exact prices are redacted due to the potential for negotiations

14%