EHRA Sustainment Training JnA FINAL.pdf

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

10 U.S.C. 2304(c)(5), Authorized or Required by Statute

Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by the Federal Acquisition Regulation (FAR) Subpart 6.3 and in accordance with the requirements of FAR 6.303-1, the justification for the use of the statutory authority under FAR Subpart 6.3 is justified by the following facts and rationale required under FAR 6.303-2 as follows:

1. Agency and Contracting Activity.

The United States Coast Guard (USCG), Office of Contract Operations (CG-912) proposes to enter into a contract on a basis of other than full and open competition.

2. Nature and/or Description of the Action being Approved.

The USCG Electronic Health Records Acquisition (eHRa) program has obtained an Electronic Health Record (EHR) solution. The USCG currently documents patient care using paper based health records. Federal regulations mandates the use of EHR platforms. The USCG, Department of Defense (DoD), and Veterans Affairs (VA) share beneficiary populations. DoD and VA are currently utilizing the Military Health System (MHS) GENESIS. The USCG must modernize to achieve full interoperability with DoD and VA EHR solutions. In June 2018, the eHRa Program Management Office (PMO) entered into an Inter-Agency Agreement (IAA) with DoD Defense Health Agency (DHA) to deploy MHS GENESIS as the USCG’s EHR solution to ensure the standardization that is needed in military health care record management. DHA has already deployed MHS GENESIS to a few locations, while the VA and USCG are currently implementing pre-deployment activities. The USCG is on schedule for deployment to four locations on 29 August 2020.

The USCG must sustain the EHR solution following initial deployment to the targeted end user population. Sustainment training support to the new and evolving end user population on the MHS GENESIS EHR system must be continuously provided.

The USCG intends to procure on a sole source basis Sustainment Training Services for the MHS GENESIS EHR system from the contractor below:

(a) Name and address of the contractor:

Seneca Global Services 1420 Central Park Blvd Suite 204 Fredericksburg, VA 22401

(b) Type of action: Firm-Fixed-Price Contract

(d) Estimated total value (including options): $5,605,000 broken down as follows:

Period Price

Base Year

12 mo.

$1,185,000

Option Year 1 12 mo. $2,180,000 Option Year 2 12 mo. $2,240,000

Total $5,605,000

(e) Type of funding: AFC-57 Operations and Maintenance funds.

(f) Year of funding: Fiscal Year 2020

(g) Solicitation Number: 70Z02320RPIT00500

3. Description of Supplies/Services.

The requirement is to obtain contractor support to provide MHS GENESIS EHR system sustainment training for the CG-9333 eHRa PMO. In June 2018, the eHRa PMO entered into an IAA with the DHA to deploy MHS GENESIS as the USCG’s EHR. MHS GENESIS currently is being deployed by the DHA, VA, and USCG, and will ensure the standardization needed in military health care record management.

The USCG has closely monitored the DHA implementation of MHS GENESIS since it was first deployed in February 2017. Post-deployment, DHA lessons learned indicated a need for sustainment training to provide end user training for the MHS GENESIS system.

This will ensure new medical support personnel who onboard post-MHS GENESIS deployment receive the necessary one-on-one training needed to learn the new EHR system. Based on the review of these lessons learned, the USCG requires Certified MHS GENESIS trainers to provide classroom instructor led training, over the shoulder training, training classroom set up and management, training surveys, and monthly reports.

Additionally, the sustainment training will provide Super User support to assist our medical staff with problems they may encounter using the system, which is the last line of defense before utilizing the DHA Help Desk.

4. Identification of Statutory Authority Permitting Other Than Full and Open Competition.

The statutory authority permitting other than full and open competition is 10 U.S.C.

2304(c)(5), implemented in FAR Subpart 6.302-5 (Authorized or required by statute). The Frank LoBiondo Coast Guard Authorization Act of 2018, Pub. L. No.

115-282, § 305(c), 132 Stat. 4192, 4246 (classified to 14 U.S.C. § 504 note) states the Commandant is authorized to procure support services necessary to ensure full integration with the DoD EHR systems, to include training support services.

Additionally, the authorization act states the procurement of an EHR system and support services shall be exempt from the competition requirements of section 2304 of title 10, United States Code.

5. Demonstration that the Proposed Contractor’s Unique Qualifications or the Nature of the Acquisition Require Use of the Authority Cited.

Through market research, Seneca Global Services was determined to be capable of supporting the MHS GENESIS sustainment training support requirements for the USCG.

The USCG implementation of MHS GENESIS aligns with the DoD and VA, but with one major difference: the small and geographically dispersed location of USCG clinics and sickbays, versus DoD and VA large regionally located facilities. Seneca is teaming with Right Factor, which currently manages mobile training teams and is currently providing MHS GENESIS sustainment training services to DoD Military Treatment Facilities. In addition, Seneca has a well-documented plan to provide training to the USCG geographically dispersed clinics and sickbays, has over 150 certified trainers, with an ability to begin providing sustainment training support immediately upon award, whereas another vendor may likely have to source the trainers. Seneca also stays abreast of MHS GENESIS application updates and revises training as appropriate. As a result, Seneca is well-positioned to provide sustainment training support services to the USCG. By utilizing the same vendor that provides MHS GENESIS sustainment training to DHA, the USCG can ensure that they are receiving the same sustainment training as the DoD and further fully integrate into the DoD electronic health record system.

6. Description of Efforts Made to Ensure that Offers are Solicited from as Many Potential

Sources as is Practicable.

(a) APFS entry F2020049296 was published on 30 March 2020.

(b) A Sources Sought Notice was posted on 13 February 2020 under both the

Government Point of Entry (GPE) website www. beta.SAM.gov and the General Services Administration (GSA) e-Buy tool in order to ensure submissions were solicited from as many potential sources as practicable.

7. Determination by the Contracting Officer that the Anticipated Cost to the

Government will be Fair and Reasonable.

The Contracting Officer anticipates that the price will be fair and reasonable based on conducting a price analysis in accordance with FAR 15.404-1(b)(2)(v), comparison of proposed prices with the Independent Government Cost Estimates, and FAR 15.404- 1(b)(2)(ii), comparison of the proposed prices to historical prices paid for the same or similar items, as contract labor rates from the MHS GENESIS Sustainment Trainer Task Order were obtained from DHA Health Informatics Contracting Officer Representative as a basis of comparison.

8. Description of Market Research.

In accordance with FAR Part 10, market research was conducted from December 2019 through March 2020. Market research was conducted by posting a Sources Sought notice and the draft Statement of Work (SOW) on the GPE website www. beta.SAM.gov and the GSA e-Buy tool on 13 February 2020, with responses due no later than 28 February 2020.

The USCG received a total of eight (8) submissions in response to the sources sought notice and analyzed each submission to determine if the interested party demonstrated the experience necessary to meet the requirements in the SOW. On 6 March 2020, after review of the submissions, additional information was requested from four of the eight vendors in order to determine if they are capable of performing the required services. All four vendors submitted additional information, as requested. The USCG selected the vendor that is capable of supporting the USCG requirements and is currently providing MHS GENESIS Sustainment Training Support Services to DHA.

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

As indicated above, the Frank LoBiondo Coast Guard Authorization Act of 2018, Pub. L.

No. 115-282, § 305(c), 132 Stat. 4192, 4246 (classified to 14 U.S.C. § 504 note) exempts the USCG from competition requirements in the procurement of support services, to include training support.

The USCG is currently conducting MHS GENESIS pre-deployment activities and needs to ensure sustainment training is in place and ready to provide sustainment training services to its healthcare providers to continue to allow for full integration with DoDs EHR system.

Seneca Global Solution’s has the knowledge and expertise to fulfill the USCG MHS GENESIS sustainment training requirements immediately upon contract award, ensuring full integration with the DoD electronic health record system.

10. A Listing of the Sources, if Any, that Expressed, in Writing, an Interest in the Acquisition.

The following vendors responded to the Sources Sought notice posted on 13 February 2020:

METCOR/LSI MicroHealth LLC Deloitte Joint Technology Solutions Seneca Global Services Nolij Consultion Cerner HRS Consulting, Inc.

Of the eight respondents to the Sources Sought Notice, four vendors are capable of supporting the requirements:

• Cerner

• Seneca Global Services

• Nolij Consulting

• MicroHealth LLC

11. A Statement of the Actions, if Any, the Agency May Take to Remove or Overcome Any Barriers to Competition Before Any Subsequent Acquisition for Supplies or Services Required.

The USCG is utilizing the exemption to competition provided by the Coast Guard Authorization Act in order to ensure that the USCG’s EHR sustainment training execution is in alignment with the DoD. A follow-on contract for these requirements may be competed in the future if the USCG is unable to establish an in-house sustainment training methodology prior to the expiration of this contract.

12. Contracting Officer’s Certification.

I certify that the data supporting the recommended use of other than full and open competition is accurate and complete to the best of my knowledge and belief.

Lakaiha Davis Date

CG-9123

Contracting Officer

13. Technical/Requirements Personnel Certification.

I certify that this requirement meets the Government’s minimum need and that the supporting data, which forms a basis for the justification, is accurate and complete.

Arthur Martin Date

CG-9333

Technical Representative/COR

14. Legal Review and Concurrence:

I have reviewed this justification and find it legally sufficient.

Talbot Nicholas Date

CG-0949

Legal Counsel

APPROVAL:

Maria L. Kersey, CPACA Date