COVID-19 PM - Other Than Full and Open Competition Justification and Approval.pdf

PM Part 813.5 SAP for Certain Commercial Items Page 1 of 6 Original Date: 08/30/17 Revision 03 Date: 02/11/2021

DEPARTMENT OF VETERANS AFFAIRS

SOLE SOURCE JUSTIFICATION UNDER SIMPLIFIED PROCEDURES FOR CERTAIN COMMERCIAL

ITEMS IN ACCORDANCE WITH FAR 13.5

Acquisition Plan Action ID: 36C776-21-AP-2153

1. Contracting Activity:

Department of Veterans Affairs (VA), Veterans Health Administration (VHA), Regional Procurement Office (RPO) Central, Program Contracting Activity Central (PCAC) in support of the VHA front office for the Undersecretary for Health and the VHA Chief of Staff

2237: 776-21-3-3235-0184

2. Nature and/or Description of the Action Being Processed:

This procurement is for executive program management support during COVID-19 in accordance with FAR 13.5 Simplified Procedures for Certain Commercial Items and specifically FAR 13.501 Special Documentation Requirements, where acquisitions conducted under Simplified Acquisition Procedures are exempt from the requirements of FAR Part 6, but still require a justification using the format of FAR 6.303-2.

This justification is in support of a new contract required by the VHA front office for the Undersecretary for Health and the VHA Chief of Staff. The contract will be for a new scope of work as well as incorporating tasks previously contracted for by this office.

3. Description of Supplies/Services :

VHA executive leadership seeks an industry partner to provide targeted program management support as it relates to our COVID-19 task forces, projects, and initiatives. This contract will provide executive program management support services including contract management, strategic planning support, and technical writing. Example tasks include establishing the structure, process, and procedures required to manage operations of a COVID-19 projects, optimizing performance across the COVID-19 project (functionally and technically), and evaluating COVID-19 projects for performance at defined intervals and create improvements where needed.

The estimated value of this procurement action is $749,253.53. These services are considered performance-based severable services that are available in the commercial marketplace. The period of performance for this contract is expected to be nine months from May 31, 2021 through February 28, 2021. There are no options on this contract.

4. Statutory Authority Permitting Restricted Competition:

41 USC §3304(a)(5), 38 U.S. Code § 8127. Contracting Officers may use the non-competitive (sole source) procedures authorized in VAAR 819.7007 up to $5,000,000. Full and open competition need not be provided for when awarded a sole source contract with a verified Service-Disabled Veteran- Owned Small Business (SDVOSB) in accordance with 819.7007, as authorized.

5. Demonstration that the C Unique Qualifications or Nature of the Acquisition Requires the Use of the Authority Cited Above (applicability of authority):

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In accordance with VAAR 819.7007 the VA has the statutory authority to award sole source to a verified SDVOSB using procedures other than competitive procedures given the following:

38 U.S.C 8127(c) permits a contracting officer of the Department to award a contract to a small business concern owned and controlled by veterans using procedures other than competitive procedures if

1) Such concern is determined to be a responsible source with respect to performance of such contract opportunity;

2) The anticipated award price of the contract (including options) will not exceed $5,000,000; and

3) It is estimated by the contracting officer that award will be made provided that a fair and reasonable price that offers best value of the United States.

The implementing regulations at VAAR 819.7007 (b) and (c) state in part:

b) business decision wholly within the discretion of the contracting officer

c) ...

The proposed source for this acquisition is Prometheus Federal Services LLC 13846 Rembrandt Way, Chantilly, Virginia 20151; a registered and verified SDVOSB by VA Center for Verification and Evaluation (CVE) and listed on the Vendor Information Pages (VIP). Prometheus is technically qualified by their experience providing transformation and strategic change management support to the front office. Prometheus is delivering a wide range of operations and strategic change

y. In addition, Prometheus has been awarded a new prime contract with VHA supporting the Women Veterans Program Evidence Based Quality Improvement (EBQI) Initiative. The Prometheus Team will work in partnership with the VHA to improve the process and quality of healthcare provided to women Veterans by clinical teams around the nation and will provide clinical informatics support for

Prometheus has been awarded an IDIQ for Human Capital and Training Solutions (HCaTS) with the General Services Administration (GSA) in

-in-vehicle and Prometheus will provide customized training and development, human capital strategy, and organizational performance improvement solutions government-wide through the vehicle.

Together, these contracts prove Prometheus s repeated success within a front office environment managing several complex and high visibility projects in tandem and for reasonable prices.

project and possesses the application knowledge and technical expertise required to complete this project within the established performance schedule.

In light of the above, the VHA front office and the COR have determined that Prometheus is capable of meeting all the for this effort and is considered a responsible SDVOSB. Furthermore, there is an expectation that an award will be made at a fair and reasonable price.

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6. Description of Efforts Made to ensure that offers are solicited from as many potential sources as deemed practicable:

Prometheus was verified in VIP as a certified SDVOSB, and in System for Award Management with an active registration and no felonies, delinquent taxes, or exclusions. In accordance with VAAR 819.7007(b), the contracting o business decision. For the reasons stated herein, and specifically, in response to Paragraph 5, the undersigned contracting officer has determined that Prometheus is a qualified, responsible SDVOSB.

A special notice announcing the intent to sole source to Prometheus contract action was be posted to Contracting Opportunities on beta.SAM on March 18, 2021 through March 22, 2021. Only one response was received from an independent Program Management Consultant who is an SDVOSB and based on the capability statement provided the individual does not have program management experience in healthcare and appears to focus on IT and finance. The Contracting Officer determined the sole source award pursuant to VAAR 819.7007(b) is in the best interest of the government. The Justification and Approval (J&A) document will be posted within 14 days after award in accordance with FAR Subpart 6.305. The award synopsis will be posted to beta.SAM in accordance with FAR Subpart 5.301(a)(2).

7. Determination by the CO that the Anticipated Cost to the Government will be Fair and Reasonable:

Based on the authorities cited in this justification, a sole source award under the Veterans Benefits Act of 2003 to Prometheus is proposed pending negotiation of a fair and reasonable price for the work performed.

An individual IGCE has been completed. A fair and reasonable price determination will be made for the contract prior to award.

8. Description of the Market Research Conducted and the Results, or a Statement of the Reasons

Market Research Was Not Conducted:

Market research was conducted to consider the acquisition history with Prometheus on VHA contracts, as well as their capability statement and interviews with the vendor. Prometheus has previously been awarded the following VA contracts and task orders:

Front Office Support contract

Contracting Office: Strategic Acquisition Center-Frederick (SAC-F) Contract Number: 36C10X19C0045 Contract Value: $3,026,422.36 Period of Performance: 09/24/2019 09/23/2021

Performance to date: Exceptional (CPARS rating for 09/24/2019 - 09/22/2020)

Health Services Research & Development (HSR&D) including VA Quality Enhancement research Initiative (QUERI) Contracting Office: Department of Veterans Affairs, RPO East

Contract Number: 36C24E18C0066 Contract Value: $4,304,653.79 Period of Performance: 09/10/2018 - 09/09/2023

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Performance to date: Exceptional (CPARS rating for 09/10/2018 - 09/09/2020)

VA Women's Health Evidence Based Quality Improvement Initiative Contracting Office: Strategic Acquisition Center-Frederick (SAC-F)

Contract Number: 36C10X19P0111 Contract Value: $3,203,565.10 Period of Performance: 09/26/2019 - 09/25/2022

Performance to date: Very Good (CPARS rating for 09/26/2019 - 09/24/2020)

WHS Clinical Skills Support IDIQ Contracting Office: VA Network Contract Office 5

Contract Number: 36C24518D0101 Contract Value: $4,499,996.77 Period of Performance: 05/02/2018 05/01/2022

Performance to date: Exceptional (CPARS rating twice for 05/02/2018 - 04/17/2020)

WHS Clinical Skills Support Task Order Task Order Number: 36C24520N0457 Task Order Value: $1,119,448.30 Period of Performance: 05/02/2018 05/01/2022 Performance to date: Not available

WHS Clinical Skills Support Task Order Task Order Number: 36C24518N0388 Task Order Value: $1,137,961.05 Period of Performance: 05/02/2018 - 05/01/2019

Performance to date: Exceptional (CPARS rating for 05/02/2018 - 05/01/2019)

WHS Clinical Skills Support Task Order Task Order Number: 36C24519N0430 Task Order Value: $1,098,375.94 Period of Performance: 05/02/2019 - 05/01/2020

Performance to date: Exceptional (CPARS rating for 05/02/2019 04/30/2020) and Satisfactory (CPARS rating for one day, 05/01/2020) documented positive performance on the above contracts, the contracting officer anticipates Prometheus will be capable of meeting the g this requirement and will be determined to be a responsible source.

Additionally, VIP was queried in NAICS 541611 and over 4,000 vendors were listed, including Prometheus. However, per the statutory authority, it is not required to demonstrate Prometheus is the only SDVOSB that can perform these services. Therefore, a Rule of Two determination is not required.

9. Any Other Facts Supporting the Use of Other than Full and Open Competition:

Prometheus Federal Services is a lower risk SDVOSB for this work because they have been intimately involved with COVID-19 work within the front office already and they understand the sensitivities, urgency, and sometimes turbulent nature of the tasks assigned from the highest levels of

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Prometheus has performed successfully on several similar contracts for highly visible VHA government staff with a clear understanding of their roles and responsibilities. Prometheus does not subcontract most of their work, and when they do, they maintain control of their contracts and ensure there is no scope creep.

Based on the authorities cited in this justification, a sole source award under the Veterans Benefits Act of 2003 to Prometheus is proposed pending negotiation of a fair and reasonable price for the work to be performed.

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

A special notice announcing the intent to sole source to Prometheus contract action was be posted to Contracting Opportunities on beta.SAM on March 18, 2021 through March 22, 2021. Only one response was received from J.B. Brown, an independent Program Management Consultant who is not an SDVOSB, and based on the capability statement provided the individual does not have program management experience in healthcare and appears to focus on IT and finance.

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:

Future actions are expected if the COVID-19 pandemic continues or transitions into an endemic.

Similar work that is not COVID-19 related will be competed on the IHT IDIQ which is also an SDVOSB vehicle.

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.

13. Approvals in accordance with the VHAPM Part 806.3 OFOC SOP:

a. Contracting Officer or Certification (required): I certify that the foregoing justification is accurate and complete to the best of my knowledge and belief.

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b. One Level Above the Contracting Officer (Required over SAT but not exceeding $750K): I certify the justification meets requirements for other than full and open competition.