DRM JA Redacted.pdf

CONTROL NUMBER VA-26-00000202

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 firm-fixed-price task order to be issued under National Aeronautics and Space Administration (NASA) Solutions for Enterprise-Wide Procurement (SEWP) V Governmentwide Acquisition Contract (GWAC) Groups B, C, and D under NAICS code 541519 to certified resellers of Dental Record Manager (DRM) Plus and eDRM Support and Maintenance.

3. Description of the Supplies or Services: The proposed action is for the purchase of continued DRM Plus/eDRM software maintenance support and training for VA owned perpetual licenses inclusive of project management, software support bug fixes, patch preparation and release, correction of display, data or reporting inaccuracies, initiation, execution and maintenance of Veterans Health Information Systems and Technology Architecture (VistA) Integration Agreements, technical support and incident ticket management and resolution, workflow optimization minor software modification, VistA Imaging interface, and Personal Identity Verification (PIV) card 2 Factor Authentication Identity Access Management and Service Desk support for VA's 236 dental clinics currently using the DRM Plus/eDRM software deployed across multiple time zones in the United States and overseas including the Virgin Islands, Puerto Rico, American Samoa, Guam, and the Philippines. DRM Plus/eDRM is a software suite utilized by all Veterans Health Administration (VHA) sites hosting dental facilities. DRM Plus/eDRM software is utilized by VA dental staff to electronically capture meaningful use data for dental patient encounters as part of the normal examination and treatment workflow.

Under this effort, the contractor shall provide continued sustainment and software maintenance support for VA's instances of DRM Plus/eDRM which are presently owned by VA.

The contractor shall provide software maintenance and support for the current DRM Plus/eDRM system inclusive of all integrations with VistA/ Computerized Patient Record System (CPRS) and VA customizations via Service Desk support. The contractor shall provide a call-in number for an after-hours call and call back within four hours. The contractor shall monitor the VA Enterprise Service Desk ServiceNow incident ticket tool in addition to providing telephone and email support. The Contractor shall develop and deliver four formal training sessions annually for use of the DRM Plus/eDRM software, utilizing webinar-based conferencing methods.

DRM Plus/eDRM serves as an adjunctive graphic user interface (GUI) application to collect and maintain dental specific information over and above the information collected through CPRS. This additional information collected is vital for VA dental patient care because it records dental-specific diagnostic, treatment planning, and procedural data

DRM Plus/eDRM Support and Maintenance VA-26-00000202 such as tooth-level charting, periodontal measurements, and procedural workflow elements that are not inherently supported in VistA/CPRS. DRM Plus/eDRM does not replicate existing VistA/CPRS functions but instead enhances and expands them with a dental-focused user interface that enables efficient chairside documentation, decreases clinical error risk, and promotes better continuity of care. This "single-entry" process simultaneously records dental diagnostic data, and dental treatment planning data, using VA’s PIV Remote Procedure Call Broker call technology to communicate with VistA’s underlying Massachusetts General Hospital Utility Multi-Programming System (MUMPS) code, within the dental software package (DENTV) namespace imprinting data to VistA Patient Care Encounter, VistA Text Integration Utility, CPRS Problems List, CPRS Vitals Package, and VA Corporate Data Warehouse (CDW) databases, thereby eliminating duplicate entries into multiple systems. This single-entry process creates a more accurate, inclusive, efficient, and less costly data storage process. Since it is fully integrated with the regional VistA host system, DRM Plus/eDRM transfers data to the CDW for national aggregation, utilizing the common VistA extraction routines employed by the CDW. This capability allows for the establishment of a second-tier data warehouse based on the CDW dental domain which serves as the business intelligence and analytic repository for the Dental Reporting and Analytics System.

Ongoing support for DRM Plus/eDRM is vital to maintain system reliability and availability, reducing the risk of downtime that could hinder dental care delivery to Veterans. Regular maintenance, updates, and upgrades are needed to keep the system secure, compliant with health information technology standards, and capable of integrating with other VA systems. Additionally, optional training aims to ensure all users, from new staff to experienced personnel, are proficient in using DRM Plus to its full potential, thereby boosting user skills, reducing errors, and increasing overall productivity. As healthcare regulations, policies, and procedures continuously evolve, ongoing support will help facilitate timely adjustments and updates to DRM Plus, ensuring compliance with new regulations and VA policies. Furthermore, continuous support enables quick and effective responses to emerging needs or enhancements required by VA dental services, ensuring the system adapts to changing circumstances.

In the long term, this proactive approach, along with regular maintenance and training, leads to cost savings by preventing major system overhauls, minimizing downtime, and reducing emergency interventions.

The period of performance for this effort will be a 12-month base period and 4 12-month option periods. There is also an optional task for additional training, which may be exercised up to 12 times annually, at the Government's discretion. The total estimated price of the proposed action, inclusive of options, is $30,266,753.36.

4. 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”.

$30,266,753.36.

5. Rationale Supporting Use of Authority Cited Above: Based on extensive market research, as described in Section 8 of this justification, it was determined that only brand name DRM Plus/eDRM can meet VA’s requirements. Over the past 20 years, DRM Plus/eDRM has been continuously enhanced, customized, and integrated with VA systems. Specifically, DRM Plus/eDRM has a tightly integrated software interface which was developed by Document Storage Systems (DSS) to communicate with both VistA, VA’s 40-year-old Electronic Health Record (EHR) and its CPRS GUI front end application.

Only brand name DRM Plus/eDRM software maintenance will satisfy VA’s requirements. Only DRM Plus/eDRM meets VA’s requirements due to its Dental software capabilities and integration with VistA and CPRS, as described in Section 3 above. DSS owns the Technical Data Package (TDP), Intellectual Property (IP) rights and proprietary source code for the DRM Plus/eDRM software and the highly customized and tightly integrated DRM Plus/eDRM interface with VistA/CPRS. Any other vendor/source providing software sustainment and maintenance for DRM Plus/eDRM would need access to the inner workings of the DSS DRM Plus/eDRM TDP, IP and source code to provide updates, modifications, enhancements, and security patches to the software. Due to the high level of technical complexity, the Government does not possess the capability to develop comparable source code and software, nor an adequate competitive TDP.

The VHA Office of Dentistry (OOD) implemented the DSS DRM software product throughout VA in 2001. In 2003 and 2004, DRM was significantly enhanced and thus renamed DRM Plus/eDRM. At that time, it was reclassified as a VistA Class I Enterprise software product. VistA Class I software products are considered essential components of the VistA suite of applications and are nationally deployed. Class I software is subject to standardized rigorous development, testing, and deployment processes. Since Class I software products are an essential component of the VistA suite, they must be maintained and remain current with all other software configuration management and product baselines in production VistA systems. DRM Plus/eDRM, as currently deployed throughout VA, is an adaptation of the Discus Dental Clinical Vision commercial off the shelf software and has been highly customized and modified for use in the VA healthcare environment. It is installed in all VHA sites hosting dental facilities and used in over 7,000 dental patient encounters daily.

For the following reasons, only DRM Plus/eDRM software sustainment and maintenance support meets the Government's requirements for interfacing with VistA/CPRS. DSS ensures compatibility with VistA and the CPRS GUI by maintaining both the VistA MUMPS database dental package namespace (specific application where the program code resides and executes) and the DRM Plus/eDRM application executable (instructions file that allows DRM Plus/eDRM to run on a user’s computer workstation operating system). The DRM Plus/eDRM software was customized specifically and uniquely for VA to be used and integrated with VistA/CPRS. DRM Plus/eDRM is the only known dental records software with the ability to push and pull information and data from VistA/CPRS. Utilizing any other software product other than DRM Plus/eDRM would require significant recoding, retesting, and recertification to establish a VistA/CPRS interface. Based on historical information, establishing a new interface would require at least a four-year development timeframe based on similar historical development efforts and discussions with other providers in industry. During this development timeframe, dental specific diagnostic findings, standardized examinations, and care plans would not be available and would negatively impact both patient care quantity and quality. Additionally, utilizing any other software may result in a disruption to clinical operation, interoperability issues, and a loss of patient records.

Dental provider productivity would be reduced, and essential dental-specific operational reporting would not be possible. To transition to a different software while minimizing these significant disruptions would require solutions to be deployed in parallel, this along with the development and deployment costs are estimated to be $25 million in duplicative costs that would not be recuperated through competition. These estimates are based on previous acquisitions.

Proper sustainment and maintenance of DRM Plus/eDRM is critical to VA clinical patient care and national dental operations.

Sustainment and maintenance support of the DRM Plus/eDRM software is essential, as configuration management and product baseline changes are made to VistA/CPRS, and as the VistA MUMPS database data structures are modified to support CPRS and ancillary VistA packages, the DRM Plus/eDRM product baseline must be synchronized with these configuration management changes. If DRM Plus/eDRM and VistA/CPRS are not kept synchronized, access to dental specific diagnostic findings, standardized examinations, and care plan information and data may not be available to the provider at time of treatment. Additionally, the contractor shall provide software security updates, bug fixes, service desk support, training, workflow optimization, software modification, minor enhancements, and technical support services are required. These services are required to ensure operational availability of the DRM Plus/eDRM software, resolve end-user technical issues and ensure efficient operation of the software in VA’s healthcare setting.

On June 5, 2017, VA announced its decision to replace legacy VistA with the Cerner Millennium EHR solution to align with the Department of Defense Military Health System GENESIS EHR. This strategy aims to create a single, accurate, lifetime health record that will facilitate the seamless transition of Active-Duty service members to Veteran status and promote meaningful use and sharing of health data with community partners.

The use of any other dental software solution would present major program issues and an unacceptable increase in program risk to the VHA OOD and VA EHR Modernization effort. At this time, VA does not anticipate that the Millennium EHR solution will ultimately replace eDRM.

For the reasons stated above, only DSS can provide the DRM Plus/eDRM software interface at the quality level required because VA must keep its mission-critical software products synchronized, stable, and maintained. The sustainment and maintenance of the DRM Plus/eDRM software interface are unique and highly specialized.

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 could meet the Government’s requirements. There is no competition anticipated for this acquisition. In accordance with FAR 5.301 and 8.405-6(a)(2) the award notice for this action will be synopsized on the Contracting Opportunities website and this justification will be made publicly available within 14 days of 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. Specifically, the Government will continue to monitor the marketplace to determine whether other software maintenance support and sustainment services could integrate into VA's existing DRM Plus/eDRM and Electronic Dental Records Management applications.

8. Market Research: VA technical experts conducted market research in November 2024 through internet searches for products and services similar to DRM Plus/eDRM and found the following two top rated commercial dental software packages, Dentrix and EagleSoft. The research concluded that although other dental record products exist, no alternative products have the proprietary software interface that would be required to glean and imprint information on VA patient records in VistA/CPRS, nor would they be able to support the capacity required by the vast VA Healthcare Network.

As noted above, integration with VistA/CPRS is a significant requirement for VA dental records, and acquiring the necessary coding, testing, and approval to integrate a new product to VistA/CPRS is anticipated to take a minimum of four years. Additionally, VA technical experts reviewed the maintenance services provided by other commercial software providers. No alternative vendor has the ability to provide sustainment and maintenance support services for the highly customized and tightly integrated DRM Plus/eDRM software interface with VistA/CPRS, due to proprietary data rights.

A VA technical expert attempted to determine if the Government might be able to attain the necessary IP rights to the DRM Plus/eDRM software interface. As a part of market research efforts technical experts contacted DSS in June 2025, asking if DSS would consider allowing the Government to acquire the proprietary source code/technical data package for DRM Plus/eDRM. DSS stated that they are not willing to sell the source code.

Based on the extensive market research set forth above, VA’s technical experts have determined that only brand name DRM Plus/eDRM software maintenance support services can meet all the Government's technical requirements, as DSS is the developer. VA identified multiple DSS resellers through the NASA SEWP V GWAC, therefore DRM Plus/eDRM will be solicited to NASA SEWP resellers, where limited competition is expected.

9. Other Facts: None.

Technical/Requirements Certification I certify that the supporting data under my cognizance, which are included in this justification, are accurate and complete to the best of my knowledge and belief.

Scott A. Trapp Date Deputy Director for Dentistry Veterans Health Administration

Best Value Determination I hereby determine that the proposed contract action will represent the best value based on limited competition and comparison with commercial catalogue prices.

Matthew Newell Date Contracting Officer Technology Acquisition Center

Department of Veterans Affairs

Contracting Officer Certification/Approval I certify that this justification is accurate and complete to the best of my knowledge and belief.

Matthew Newell Date Contracting Officer Technology Acquisition Center

Office of General Counsel (OGC) Review I have reviewed this document and find it legally sufficient, based on the representations set forth in the documents and, if any, attachments. The Head of Contracting Activity approval is an independently supported decision not wholly reliant on the legal sufficiency determination.

Lolitha McKinney Date Office of General Counsel

HCA Approval In my role as Head of the Contracting Activity, based on the foregoing justification, I hereby approve the acquisition of DRM Plus/eDRM software maintenance support, training, and service desk support pursuant to the authority cited in Section 4 above, subject to availability of funds, and provided that the services described herein have otherwise been authorized for acquisition.

Mr. Jeffrey C. Neill Date Head of the Contracting Activity Technology Acquisition Center