Diameter Health Inc _DH_ Availity Data Quality Tool _DQT_ FINAL signed _Redacted.pdf

Diameter Health, Inc. (DH) /Availity Data Quality Tool (DQT) VA-25-00011523

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: This proposed action is for the award of a firm-fixed-price delivery order (DO) issued under the National Aeronautics and Space Administration (NASA) Solutions for Enterprise-Wide Procurement (SEWP) V Governmentwide Acquisition Contract (GWAC) on a sole source basis to Four Points Technology, LLC located at 14900 Conference Center Drive, Suite 100 Chantilly, VA 20151 for the renewal of brand name Diameter Health, Inc. (DH)/Availity Data Quality Tool (DQT) solution comprised of software licenses, maintenance support, and operations support.

3. Description of the Supplies or Services: VA Office of Information and Technology (OIT) has a requirement for renewal of brand name DH/Availity Clinical Care Document (CCD) Analyzer Enterprise Bundle (DHCCDBN20161Y) DH/Availity Enterprise Operational Support Bundle (DHCCDA20223Y) support services. VA requires a Commercial-off-the-Shelf (COTS) software product that improves the quality of information provided by analyzing and validating the document’s syntactic structure and semantic meaning to determine both completeness and correctness of documents. VA requires a solution capable of analyzing over 800,000 documents per month, which are submitted through the Veteran Health Information Exchange (VHIE). Additionally, the requirement also includes installation and security ATO services for the software installed on the VA Enterprise Cloud and the VA Project One (VAPO) containerized operating environment. Lastly, VA requires a solution that is able to collect data from external healthcare systems through Cerner and allows VA resources to analyze that data and provide reports to external healthcare partners so they can address data deficiencies. Operational support services include, but are not limited to, set up of the environment, configuration services, software maintenance, and maintenance of Authority to Operate (ATO) for the hosting environment. VA requires a solution that is interoperable and supports a number of environments, including an already established externally hosted environment. VA requires a system hosted on contractor-provided Infrastructure as a Service (IaaS) within an approved Cloud Service Provider platform as mandated by the Federal Information Security Management Act (FISMA) high risk system. That IaaS requirement is not included under this effort, however the ATO support services must continue until the existing environment is transitioned into the VA Enterprise Cloud (VAEC).

VA receives millions of documents per year in its ongoing mission to provide care to the Veteran. As a critical requirement, VA requires an application programming interface (API) included in the solution set that allows Veteran and healthcare documents to be loaded immediately as opposed to manually loading documents. Specifically, to provide care for Veterans, VA must be able send documents to and receive documents from various third-party care providers. The quality of the documents exchanged has a direct impact on the cost and quality of Veterans’ care. These documents are based on industry standards developed by HL7 and the Healthcare Information Technology Standards Panel. Additionally, no other solution offers all the required functional features that VA requires. For instance, the DQT solution allows VA to develop and select specific scoring metrics that support analyzing the data and identify potential vulnerabilities in care provided. This unique functionality supports the functional requirement for a solution to have the ability to produce graded reports for batches of documents, to include ratings for document syntactical accuracy, semantic accuracy and completeness in aggregated manner, and allow VA flexibility in identifying the metrics/standards for that grading metric. Further, the solution has more than two million records and thousands of hours invested in modifying and/or adjusting the document quality/scoring rules to meet the specific needs of analyzing health records for VA data exchange with VA’s community care providers.

The required support services include maintenance and technical support services, which include telephone and online technical support during standard business hours (Monday – Friday, 9 am – 5 pm ET), as well as maintenance releases, including all upgrades, updates and fixes, and software problem diagnosis and resolution. The brand name support and maintenance services required includes the installation of software updates and modification to VA quality scoring rules. Additionally, the services include managing the performance of the system to meet VA requirements for the daily high-volume data loading. Much of this work is specific to how VA uses these products and VA security requirements. The services also include security activities for monitoring of the system, investigating security scan findings, maintaining the security documentation, and training for software updates and Fusion logic.

The total estimated value of the proposed action is , inclusive of one (1) 12-month base period and two (2) 12-month option periods.

4. Statutory Authority: Pursuant to Federal Acquisition Regulation (FAR) 16.505(a)(4), the following brand name requirement is being justified and approved as an exception to fair opportunity under the statutory authority of Section 41 U.S.C. 4106(c)(2) as implemented by FAR 16.505(b)(2)(i)(B), entitled “Only one awardee is capable of providing the supplies or services required at the level of quality required because the supplies or services ordered are unique or highly specialized.

5. Rationale Supporting Use of Authority Cited Above: Based on market research, as described in Section 8 of this justification, it was determined that only the brand name DH/Availity DQT solution detailed above is capable of supporting the technical and functional requirements of VA.

The DH/Availity DQT solution was granted an ATO by VA for use on an approved Cloud Service Provider platform for one of its production instances. Until the transition of the production environment to VAEC is completed, VA requires continued ATO support services to maintain and update the ATO. This information must be provided by the IaaS contractor, who is the proposed source. Any other source would have to recommence the ATO process, and during that time VA would have to cease its use of this solution. Based on historical information, for another solution to go through the ATO accreditation process would take 6-12 months to achieve, assuming the other solution could meet all the required technical and functional requirements that the DQT solution provides.

Furthermore, due to the proprietary nature of the product, the required maintenance and support services can be provided by only one authorized DH/Availity reseller.

Specifically, the required maintenance services will include development of upgrades, fixes, and patches to proprietary software. No source, other than the original software developer or its reseller, has access to this proprietary code. Patches or changes to the software provided by any other source could render the entire solution useless. The maintenance of the existing system is critical to support the high volume of Veteran health and related documents processed by VA. Therefore, these services must be provided by DH/Availity or its authorized reseller.

In order for another vendor or solution to provide this requirement, the entire solution must be replaced. However, based on the extensive market research noted in Section 8, there is no other alternative solution currently available can meet all of VA’s requirements. However, even if there were such a source or solution that could meet this requirement, there would be multiple duplicative costs and schedule constraints that would render it infeasible for use. With respect to the API interface, which is critical to this solution, VA estimates that it would cost approximately to develop and test with the existing software tied to the current system interface. Further, it would take approximately six months to write the software as it would have to be customized specifically for the system to support VHIE leading to an additional to make these modifications. Both of these estimates are based on historical information and engineering estimates. Additionally, it would take several months (varying from 6-12 months) to achieve a security ATO for a replacement software package. To achieve the ATO, VA estimates this would add approximately in costs to complete these services. These ATO costs are based on previously priced contractual task support and historical pricing. The redevelopment of the existing software costs and the included ATO duplicative costs associated with procuring a new product and modifying the existing HIE environment, are estimated at approximately and up to two years before VA could have a functioning solution. As a result, these additional costs would exceed any value in recompeting as these costs would not be recouped through competition. The above does not take into account additional critical activities such as populating and validating the database of clinical scoring rules which would be required if any other solution could meet all of VA’s functional requirements and VA could pivot.

Additionally, transition to a new solution would lead to loss of current stored data which would be detrimental to the Government and would have unacceptable risks to the validation of health documents exchanged with VA partners. Specifically, the data is extrapolated into a database, and the data would be lost because the original HL7 documents are not preserved. The incoming documents are read into a proprietary database schema specifically to allow the data to be analyzed. Finally, VA would have to have the maintain the existing DQT solution in parallel as VA cannot be without this functionality, increasing costs further.

Failure to renew this effort as proposed will significantly impact the quality of care that VA can provide the Veteran. This system finds data interoperability problems that would otherwise cause VA clinicians to manually communicate to get clarifications about the data, which delays providing real time care, resulting in potential life-threatening risks.

Without a mechanism to automatically process this information, potential risk of having clinical care documents missing information or incorrect information is greatly increased.

Due to the surging demand in the VA clinical environment, the benefits of the DH/Availity program, which allow clinicians to handle the increased workload in response to Veterans’ care, are imperative. The clinical care documents contain information about the medical diagnosis, treatments, procedures, test results, medications, and travel histories of the person receiving the care. It is critical to ensure continuous operations of the DH/Availity program for VA to continue to make efficiency enhancements in the clinical environment and avoid repeated medical testing and manual validation of data which may lead to errors and potential harm to the Veteran.

To summarize, while other solutions can provide some general capabilities, such as analytical capability or data curation, only the proposed solution can accomplish the necessary data fusion, analytics of Health Level Seven (HL7) data and processing on the scale in which VA requires. This is the only brand name DH/Availity DQT solution detailed that meets VA requirements. Finally, no other solution is configured for processing of HL7 data.

6. Efforts to Obtain Competition: Market research was conducted, details of which are in Section 8 of this justification. This effort did not yield any additional sources that can meet the Government's requirements, even among resellers. In accordance with FAR 16.505(a)(4)(iii)(A)(1), this justification will be provided with the solicitation to all appropriate NASA SEWP V GWAC holders. Furthermore, in accordance with FAR 5.301, 16.505(b)(2)(ii)(D), and 16.505(a)(4)(iii), the award notice for this action will be synopsized on the Federal Contract Opportunities website and this justification will be made publicly available within 14 days after award.

7. Actions to Increase Competition: The Government will continue to conduct market research to ascertain if there are changes in the marketplace that would enable future actions to be competed.

8. Market Research: The Government’s technical experts conducted market research in January and February 2025 and reviewed similar software from alternative manufacturers, including ClinReview, Model-Driven Health Tools (MDHT), and Office of National Coordinator for Health Information Technology’s (ONC) C-CDA Scorecard.

Additionally, Market Research was conducted by the Contract Specialist (CS) on March 21, 2025, by releasing two Requests for Information (RFIs). Specifically, RFI 36C10B25Q0217, under the Contracting Opportunities page under SAM.gov, and a concurrent SEWP Request #338996, under the NASA SEWP V GWAC, to determine if there were alternative solutions available and/or if limited competition was available among Service-Disabled Veteran Owned Small Businesses (SDVOSBs) and Veteran Owned Small Businesses (VOSBs). Included with this RFI was the draft Product Description that included salient characteristics in order to identify for both alternative solutions and for potential resellers. Both RFIs closed on March 28, 2025, with one response received from a Veteran Small Business Certification (VetCert) verified SDVOSB, Four Points Technology, Inc. (Four Points) under SEWP and one response received from a Veteran Small Business Certification (VetCert) verified SDVOSB, Aurelius Talent Solution LLC (Aurelius) under Contract Opportunities. The Government technical experts determined that Four Points, was technically capable of providing a responsive bid. Next, the Government technical experts reviewed Aurelius’s proposal for an alternate solution to brand name DH/Availity Solution. The Government technical experts determined Aurelius’s alternate solution capability statement did not provide a solution which would be interoperable with VA’s current system. Furthermore, the CS confirmed that Four Points is the only authorized reseller for DH/Availity. As such, there not an expectation of competition, even in a limited capacity and the solicitation will be released under NASA SEWP V GWAC.

9. Other Facts: None.