Valor_J A_Rev_3.docx

JUSTIFICATION FOR OTHER THAN

FULL AND OPEN COMPETITION

I. CONTRACTING ACTIVITY

Department of the Air Force, AFTC/PZIO, Eglin AFB, FL proposes to acquire the items described below with a “Justification for other than Full and Open Competition”. PR # F1T4AS4169A002.

II. NATURE AND/OR DESCRIPTION OF THE ACTION BEING PROCESSED

The use of other than full and open competition for the recurring interpretation and reporting of results of radiologic diagnostic images of the said items in section IV below is for the 96 SGCS/SGCR, Radiology Flight, Eglin AFB, Florida. This is a new requirement that we intend awarding on a Firm-Fixed-Price contract. This requirement has not been contracted at Eglin previously however historical data has been gathered from the Radiology Department at Eglin AFB Hospital to develop requirement figures. The estimated contract amount is approximately $1,287,285 (for a base plus 4 option years) for the recurring purchase of interpretation and reporting of results of diagnostics radiologic images generated on radiology equipment within the 96 SGCS/SGCR at Eglin AFB. The estimated award date for this contract is 29 September, 2014.

III. DESCRIPTION OF THE SUPPLIES/SERVICES REQUIRED TO MEET THE AGENCY’S NEEDS

The 96 SGCS/SGCR Radiology Department has the technician manning, patient orders, and radiology equipment to perform a number of exams/diagnostic imaging studies each duty day that routinely exceeds the capability of the radiologists to interpret and report within the DoD required timeframes per study. Outsourcing the demanded overflow will enhance the ability for physicians to appropriately treat the patient in a timely manner. Valor Network Inc. has the equipment capability and USAF authorization to electronically extract these radiological diagnostic imaging studies, the physician staff to interpret and report on the radiologic diagnostic imaging studies/exams and lastly the ability to place the patient reports into the DoD Composite Healthcare Computer System (CHCS). Access to CHCS allows Valor to input data in patient’s medical record in the same manner the Eglin radiologists would so that the ordering physician gets the results; maintaining continuity of care and patient reporting. Valor Network Inc. is the only USAF authorized vendor with this authorization and capability to seamlessly interface with the patient electronic medical record (CHCS), reference paragraph V below for more information on CHCS/DIACAP approvals. A certified PR has been received with 0130 (Defense Health Program funds) as the appropriation type. The below table depicts the estimated quantity of items being acquired. Quantities are based on historical data/yearly averages. Period of performance is 29 September 2014- 28 September 2019.

IV. STATUTORY AUTHORITY PERMITTING OTHER THAN FULL AND OPEN COMPETITION

10 USC 2304(c) as implemented by FAR 6.302-1(b)(1)(ii). The unique services needed by the agency are available from only one responsible source.

V. DEMONSTRATION THAT THE CONTRACTOR’S UNIQUE QUALIFICATIONS OR NATURE OF THE ACQUISITION REQUIRES THE USE OF THE AUTHORITY CITED ABOVE (APPLICABILITY OF AUTHORITY)

In accordance with 10 USC 2304(c), as implemented by FAR 6.302-1(b)(1)(ii), the following conditions preclude competitive full and open competition procurement: Valor Network Inc., a service-disabled veteran-owned small business, is the only company that can provide this service. Valor Network, Inc. can provide a unique capability service to Eglin Air Force Base because they are the sole domestic source for the interpretation and reporting on radiologic diagnostic images originating on USAF radiology equipment. While there may be many other companies capable of satisfying teleradiology services, Valor Network Inc. is the only vendor granted access by the Air Force Surgeon General’s Office to the USAF electronic patient medical record system (CHCS) with Department of Defense Information Assurance Certification and Accreditation Process (DIACAP) approval with the USAF. In order to reliably provide services to produce routine and urgent reports within required timeframe, remote connectivity must be established. Without approval and access to CHCS and DIACAP, the vendor will not be able to remotely connect to interpret and report on the patient’s medical records. No other vendors have received USAF permissions from the Air Force Surgeon General to electronically interface with CHCS for the purpose of interpreting and reporting on radiologic diagnostic images/exams.

The contemplated acquisition relates to the 96 SGCS/SGCR, Radiology Flight’s manpower deficiency. Although there is no current contract in place for teleradiology at Eglin Air Force Base, Valor Network Inc. is currently providing this service to both Mount Home Air Force Base as well as Nellis Air Force Base on a sole source basis. Therefore, this acquisition will be sole source to Valor Network.

Only One Responsible Source (FAR 6.302-1) – In the case of the unique capability services, the unacceptable delays in fulfilling the agency’s requirements will hinder the ability of the physicians to accurately assess the patients to determine the best treatment.

AFTC/PZIO believes that award to any other source would result in substantial unacceptable delay. The Air Force Surgeon General’s Office estimated that obtaining the appropriate CHCS and DIACAP authorizations required to perform this contract could take (at the very least) 6-12 months. The impact this delay would have on the patients could lead to further medical complications in the future by not receiving prompt radiological diagnostic interpretations. If the demand for radiological interpretations continues to exceed the capability of the radiologist staff, the patients will continue to be referred off base thus driving up cost lost to the private sector.

a. Accordingly, Valor Network Inc. is the only firm capable of providing the services described in Section III above without the U.S. Air Force experiencing unacceptable delays in fulfilling its requirements.

VI. DESCRIPTION OF EFFORTS MADE TO ENSURE THAT OFFERS ARE SOLICITED FROM AS MANY POTENTIAL SOURCES AS DEEMED PRACTICABLE

A special notice (F1T4AS4169A002) was posted to the Government Point of Entry (Fedbizopps) with intent to award sole source to Valor Network Inc. on 25 July, 2014 for 15 days. The Government considered all responses received within 15 days of publication. Five companies responded with interest in potentially competing for this requirement stating they had similar qualifications as Valor Network Inc. Their information and certifications were routed to the Medical Logistics Flight Commander who obtained confirmation from both the Office of the Surgeon General as well as the Deputy Chief Information Officer for the Medical Information Systems Flight that there is no supporting documentation for any other vendors who state they have systems that are DIACAP approved to connect and operate on the Air Force Network. On 22 August, 2014 a Presolicitation Notice (notice of contract action/NOCA) was posted to FBO as a follow-up to the above mentioned special notice (numbered FA2823-14-R-6025), stating the Government’s intent to award Sole Source to Valor Network Inc. The notice was left open for five days (until 27 August, 2014 at 1100 am). During this time, one company showed an interest in obtaining appropriate certifications however; they are currently not certified and did not provide a proposal.

VII. DETERMINATION BY THE CONTRACTING OFFICER THAT THE ANTICIPATED COST TO THE GOVERNMENT WILL BE FAIR AND REASONABLE

The Contracting Officer will determine the acquisition cost to be fair and reasonable based upon receipt and evaluation of the contractor’s quote, utilizing price analysis. TRICARE payment rates for similar studies will be used for the price analysis. Also, an analysis of recent Government contracts awarded to Nellis AFB, NV and Mountain Home AFB, ID for same/similar rates for teleradiology services will be used.

VIII. DESCRIPTION OF THE MARKET RESEARCH CONDUCTED AND THE RESULTS, OR A STATEMENT OF THE REASONS MARKET RESEARCH WAS NOT CONDUCTED

As described in Section VI above, market research, in accordance with FAR Part 10, was conducted by advising industry of the pending acquisition and soliciting information from the 96 MDG/SG Program Manager. An examination of the acquisition history, and experience with the marketplace under previous acquisitions for the same or similar items was conducted to include analysis of recent Government contracts across multiple facilities and bases to determine commerciality, sole source justification, and price reasonableness. Results yielded that teleradiology services have been awarded Sole Source to Valor Network Inc. by U.S. Air Force (Nellis and Mountain Home), Pensacola NH, and Department of Veterans Affairs as a Small Business set aside. Based on the fact that Valor Network Inc. is the only company granted authorization to access CHCS and have DIACAP approval, they are the only vendor being considered for this requirement. In addition, information was requested from the contracting office at Nellis and Mountain Home regarding their determinations for sole source. They noted that it was confirmed by the radiology consultant to the AF Surgeon General that Valor is the only company that has DIACAP certification along with access to CHCS. The DIACAP is a process by which information systems are certified for compliance with DoD security requirements and accredited for operation by a designated official. DIACAP provides visibility and control for the secure operation of DoD information systems. Ultimately, DIACAP is in place to protect patient personal identifiable information (PII), the information being processed, and the systems being used to process this information. Valor Network Inc. is the only teleradiology services company that has been granted access to CHCS by the Air Force which is imperative to access our secure firewalls to input information into the patient’s electronic medical records. Without these two certifications, the company would be unable to provide the teleradiology services required by 96 SGCS/SGCR.

IX. ANY OTHER FACTS SUPPORTING THE USE OF OTHER THAN FULL AND OPEN COMPETITION

The demand for patient services exceeds the capability of the radiologist staff to interpret and report. Currently, overflow examinations and interpretations are being performed by the civilian sector as a referral service, and the MDG is paying to outsource the examinations. Without the DIACAP ATP the images and examinations are interpreted by outside radiologists and a report is sent back to Eglin AFB as a courtesy, upon request. These records are then scanned and uploaded into AHLTA, resulting in a duplication of work and payment of referral purchased care fees.

X. LIST OF SOURCES, IF ANY, THAT EXPRESSED INTEREST IN THE ACQUISITION

See Section VI above

XI. 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

Because of the nature of this unique capability and authorization by the USAF it was neither cost effective nor achievable to foster competition. Currently, steps required to obtain appropriate DIACAP approvals have been requested from the head of teleradiology at Air Force Medical Operations Agency (AFMOA) so that this information can be relayed to prospective vendors; thus expanding potential future competition. The contract is anticipated for a base plus four option years in consideration of the lengthy timeframe for obtaining certifications required for DIACAP/CHCS. Purchase through any other vendor will unacceptably delay services by over a year.

XII. CONTRACTING OFFICER’S CERTIFICATION

The contracting officer’s signature on the Coordination and Approval Document evidences that he/she has determined this document to be both accurate and complete to the best of his/her knowledge and belief (FAR 6.303-2(b)(12)).

XIII. TECHNICAL/REQUIREMENTS PERSONNEL’S CERTIFICATION

As evidenced by their signatures on the Coordination and Approval Document, the technical and/or requirements personnel have certified that any supporting data contained herein, which is their responsibility, is both accurate and complete (FAR 6.303-2(c)).