J&A for FBO_Redacted.pdf

Sole Source (Including Brand Name) Justification - Simplified Procedures for Certain Commercial Items

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Department of the Air Force, AFICC 773d Enterprise Sourcing Squadron (ESS) 3515 General McMullen, Suite 200, San Antonio, TX 78226-1865

773d ESS is requesting approval for a sole source J&A, pursuant to FAR 13.501, to proceed with a new contract to provide accreditation surveys and Tracers with Accreditation Manager Plus (AMP) software to 60 Air Force (AF) Medical Treatment Facilities (MTFs) throughout the Continental United States (CONUS) and Outside of the Continental United States (OCONUS). Accreditation surveys are currently being provided under contract FA805215C0010 to The Joint Commission (TJC) and will expire on 31 Dec 19.

This effort will be Firm-Fixed Price (FFP) procured as a Purchase Order (PO) pursuant to FAR Part 13 and will have an estimated value of $4,610,810.06.

The purpose of this effort is for the Air Force Medical Readiness Agency (AFMRA) to provide ambulatory accreditation surveys for the purpose of "Accreditation" by an accreditation source approved by the Assistant Secretary of Defense/Health Affairs (ASD(HA)).

Tracers with AMP is a unique TJC software that facilitates analysis of organizational reviews (now called intracycle monitoring; formerly known as Periodic Performance Reviews or PPRs) at the MTF, which is a Government minimum requirement. This includes prioritizing improvement efforts, assessing risk, increasing collaboration, and building automated reports.

Additionally, this effort will require annual subscription fees, manuals, handbooks, publications, education, and training to meet accreditation standards.

This unfunded requirement (UFR) for the brand-name component, while having been approved for the base year, may not materialize in the funds for the outlying years. Although there are not certified funds for the Tracers with AMP software in the outlying years, should funding not materialize for the Tracers with AMP option CLIN, the AF will revert back to manual tracers and ensure the QMs are prepared for the conversion.

This non-personal, non-performance-based professional services effort will consist of a base period and four (4) option periods. It is anticipated that the Air Force will transition to a centralized joint-service contract under the Defense Health Agency (DHA) with estimated date of award beginning 01 Jan 21. In preparation for the transfer to DHA's joint-service contract, the AF will coordinate with DHA to ensure a smooth transition and will not exercise the outlying option years.

The periods of performance and their respective values are broken out below:

Base Period: $924,216.30 / PoP: 01 Jan 20 - 31 Dec 20

Option Period 1: $822,945.46 / PoP: 01 Jan 21 - 31 Dec 21

Option Period 2: $995,515.66 / PoP: 01 Jan 22 - 31 Dec 22

Option Period 3: $987,613.03 / PoP: 01 Jan 23 - 31 Dec 23

Option Period 4: $880,519.61 / PoP: 01 Jan 24 - 31 Dec 24

The change in values across the years is proportional to the surveys being conducted at that time. The MTFs are scheduled across a 3-year rotation, meaning that some years (e.g. Option Period 1) no surveys are scheduled while other years (e.g. Option Period 2), surveys are required.

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The types of funds that will be used for this effort are Defense Health Program, Defense 97-0130. The following CLINs will be included in the contract:

CLIN 0001 Accreditation Surveys (CONUS) CLIN 0002 Annual Fees ("Subscription Fees") CLIN 0003 Annual Hardcopy Standards Publications and Updates (Manuals)/AKA Handbooks CLIN 0004 Multi-user Site License (Tracers with AMP) - annual CLIN 0005 OCONUS Surveys Alconbury & Croughton Bases (UK) CLIN 0006 OCONUS Surveys Spangdahlem & Geilenkirchen (GE) CLIN 0007 OCONUS Survey Ramstein Air Base (GE) CLIN 0008 OCONUS Survey Aviano (IT) CLIN 0009 OCONUS Survey Kunsan (SK) CLIN 0010 OCONUS Survey Kadena (JA) CLIN 0011 OCONUS Survey Incirlik (TK) CLIN 0012 OCONUS Survey Andersen AB (Guam) CLIN 0013 Education and Training (1/2 day) via Webinar (for option year) CLIN 0014 Education and Training (1/2 day) via QSPAR (for option year) CLIN 0015 Annual Education Program Travel (for option year) CLIN 0016 Re-surveying fee CONUS CLIN 0017 Re-surveying fee OCONUS, Europe CLIN 0018 Re-surveying fee OCONUS, non-Europe

AFFARS 5313.501 - 10 U.S.C. 2302b, Implementation of Simplified Acquisition Procedures (41 U.S.C. 1901)

There are a total of four (4) business cases justifying sole-source between the section of the Contractor's unique qualifications, and the nature of the acquisition. These business cases are split between each section.

Note: The Joint Commission (TJC), Accreditation Association for Ambulatory Health Care (AAAHC), and Joint Commission Resources (JCR) are Contractors and not Government organizations.

Unique Qualifications

The following two (2) business cases describe the unique qualifications to proceed sole-source with brand-name elements:

Business Case #1: Enhance Patient Safety and Accreditation Compliance

The AF is using an antiquated system for accreditation standard compliance assessment that does not permit corporate standardization of processes. Additionally, the current status quo increases staff workload, and has resulted in a repetition of accreditation findings as documented in the AF annual corporate summation report.

The Tracers with AMP software facilitates efficient and effective analysis of organizational performance;

prioritizes improvement, assesses risk, increases collaboration and builds automated reports. This allows the AF to enhance patient safety by delivering performance at the speed of relevance by leveraging state-of-the-art technology and processes to identify, mitigate, and prevent issues that would endanger accreditation and patient safety. Tracers essentially permit assessment of systems and processes and compares them to the actual experiences of patients. Additionally, TJC has an AF critical minimum requirement that AAAHC currently does not possess: annual Periodic Performance Reviews (PPRs), which allows organizations to conduct a compliance assessment, identify areas that need improvement, and then develop plans of action with TJC that ensures measures

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Business Case #2: Demand Savings

Demand savings will accrue as a result of reduced consumption, through improved technology, or spending less because we need less. These savings include eliminating demand, reducing consumption, changing product mix, or using technology that creates a reduced resource requirement. The anticipated demand savings from this acquisition are from using technology that creates a reduced resource requirement. Based on the methodology (Attachment 1 - Demand Savings) the AF anticipates the following benefits with procuring this software:

1) An estimated 3,685.50 hours of productivity of Government employees saved across 5 years.

Explanation: Tracers with AMP software will eliminate the current AF manual process and will reduce the processing time to create, execute, and analyze, results from the Tracer. A Tracer allows surveyors to identify performance issues in one or more steps of the process, or interfaces between processes. This software will also allow for proactive identification of standard deficiencies, reducing the repetition of accreditation findings, and sharing of information across the Air Force Medical Services (AFMS) preventing duplication of deficiencies and improving quality. It will also help reduce the staff workload because the Tracer will be created centrally at AFMRA and launched AF wide electronically. Results will be loaded directly into the Tracer software and collated, identifying gaps and trends. Results can be produced both on a local and AFMS wide corporate level.

The 63 Quality Managers (QM) will no longer be required to manually create a Tracer, execute the Tracer on pencil and paper, and then upload it on an excel spread sheet. They will not have to manually analyze the results and identify gaps and variations. They can build a Tracer questions bank, based on a system, patient, or process and keep it for use in the future or they can run the same Tracer and specific intervals for standard compliance. Below is the breakdown between manual and automated Tracers:

Current AF Manual Process:

30 min. = create a Tracer.

30 min. = execute a Tracer.

45 min. = to analyze a Tracer and populate data in excel spread sheet.

1.75 hr. = Total Tracer.

Minimum requirement of 1 Tracer a week. Given that there can be additional safety events, we can calculate an average of an additional .5 per week = 1.5 Tracers/week.

1.75 hrs x 52 weeks x 1.5 Tracers = 136.5 hrs. per QM/annually x 63 QMs = 8,599.50 hours/annually.

Tracers with AMP Automated Process:

20 min = create a tracer with the ability to save questions within the repository.

30 min. = execute Tracer; no manual population of spread sheet.

10 min. = to set report parameters and run report, with the ability to run different types of reports such as deficiency reports gap analysis reports.

1 hr. = Total Tracer.

Minimum requirement of 1 Tracer a week. Given that there can be additional safety events, we can calculate an average of an additional 0.5 per week = 1.5 Tracers/week.

1 x 52 x 1.5 = 78 hrs. per QM/annually x 63 QMs = 4,914.00 hours annually.

There will be a difference of 3685.50 (57.14%) of processing hours between manual and automated Tracers.

2) An estimated $787K in total life-cycle savings across 5 years. The total life-cycle savings are calculated at a GS-11*, Step 3, Rest of U.S., 2019 annual rate of $66,386.00. This rate is then increased by 31.20%; a figure recommended by the FY 2019 DoD Civilian Personnel Fringe Benefits Rates. The total annual burdened rate is $87,098.43, with an annual burdened rate of $41.73 ($87,098.43 / 2087).

*GS-11 is the predominant grade across the 63 QMs. Step 3, Rest of U.S. was selected as a reasonable step

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Nature of the Acquisition

The following two (2) business cases describe the nature of the acquisition to proceed sole-source with brand-name elements:

Business Case #1: Synergize Jointness and Defense Health Agency (DHA) Transition

Software is available via the "Tracers with AMP” tool, a Joint Commission Resources (JCR) proprietary product that is currently being used by the Army and Navy, obtained via a non-competitive sole-source procurement, to apply efficient processes and procedures. The DHA and Tri-service accreditation representatives are also currently writing this requirement into their DoD centralized contract request for proposal. The Tracers with AMP tool will standardize AF processes, permit dissemination of data across the enterprise and pro-actively identify risk areas. It will align the AF with the Army and Navy, and simplify the AF MTFs transition to DHA process and procedures, thereby increasing accreditation readiness and sustainment.

While the AF could procure Tracers with AMP as a separate requirement under JCR, which is not an approved AO, this does not eliminate the other components of this J&A and does not provide any additional efficiencies.

It is in the best interests of the AF to acquire the software and accreditation requirements with TJC to reduce administrative burden.

Business Case #2: Limited Market Does Not Unreasonably Harm Industrial Base

The accreditation market is largely voluntary and is completely managed by a grouping of professional non-profit associations that each provide a systematic, multidisciplinary inspection of the physical and organizational structure of either the facility or the program. Additionally, the organization inspects the functioning of organization's component parts. Several accreditation sources exist within the market, with TJC accrediting approximately 77% of nation's hospitals (not all hospitals are required to accredit) and maintaining approximately 88% of the total accreditation market. Nonetheless, many organizations exist to include:

Accreditation Association for Ambulatory Health Care (AAAHC)

American Association for Accreditation of Ambulatory Surgery Facilities (AAAASF)

American Osteopathic Association/Healthcare Facilities Accreditation Program (HFAP)

Institute for Medical Quality (IMQ)

These organizations, or "Accrediting Organizations" or "AOs" develop their own manuals, handbooks, and training materials. Much of the accreditation market is also influenced by the Human and Health Services (HHS) Centers for Medicare & Medicaid (CMS), which sets the deemed status of AOs. Those AOs that go above and beyond as having standards and a survey process that meets or exceeds Medicare and Medicaid requirements achieve deemed status under CMS. CMS has identified 11 AOs that have been designated as deemed AOs. The list of the AOs can be found here: https://www.cms.gov/Medicare/Provider-Enrollment-and- Certification/SurveyCertificationGenInfo/Downloads/Accrediting-Organization-Contacts-for-Prospective- Clients-.pdf

Conclusion:

TJC is the only AO that offers the resources, tools and software (Tracers with AMP) essential for accreditation sustainment, organization risk assessment, collaboration, and process improvement, all essential elements of a "high reliability organization”. No other ambulatory AO offers any software for continuous standard compliance assessment. Currently, no other healthcare AO offers software for self-assessment and tracer

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A thorough search and comparison of Ambulatory AOs tools and resources was completed via an Internet search (see below):

Health Facilities Accreditation Program (HFAP) resources: manuals, quality reports and links. No accreditation sustainment tools or software

Accreditation Association of Ambulatory Health Care (AAAHC) resources: webinars and manuals. No accreditation sustainment tools or software.

Accreditation Commission for Health Care (ACHC) resources: webinars and manuals. No accreditation sustainment tools or software

Additionally, a Sources Sought announcement was posted on FBO on April 28, 2019. Deadline to submit responses was June 11, 2019 and only two responses were received:

Response 1 - Hildebrand Healthcare Consulting, LLC: On 29 May 2019, in response to the posted Sources Sought, Hildebrand identified a potential Organizational Conflict of Interest (OCI). Specifically, it was identified that there there is a possible conflict of interest in that the provision of manuals, tools, annual meetings, education and software (developed by JCR; an affiliate to TJC) is considered consultative rather than survey activity. In coordination with the Mission Partner, Legal, and TJC, 773d conducted fact-finding on this issue and concluded that this OCI did not exist as the firewall in place, divesting JCR from TJC, has been in place for at least a decade with only a handful of critical staff at the enterprise-level maintaining the capability of cross-organizational communication and coordination. Hildebrand does not have the capabilities to provide Ambulatory accreditation services and is not an approved AO source.

Response 2 - Nash Consulting & Associates, L.L.C: Nash, founded by a former surveyor who branched off from TJC to form their own company, provides proper guidance and instruction on how to obtain and keep accreditation requirements along with survey preparation, mock surveys, and completing assessments of compliance. Nash does not have the capabilities to provide Ambulatory accreditation services and is not an approved AO source.

On 25 Oct 19, a Notice of Contract Action (NOCA) to award Sole Source was posted on FBO for a period of 12 days. The deadline to submit responses was 06 Nov 19. No responses were received.

These commercial services have been contracted since at least 2006 between two respective vendors: AAAHC and TJC.

With both CONUS and OCONUS MTFs, the Contracting Officer anticipates leveraging current contract prices made competitively by Full & Open Competition (adjusted for market and economic factors), and other than certified cost or pricing data as required.

Specific cost drivers include, but are not limited to: MTF location, size, and operations tempo (number of patients annually).

TJC has or currently accredits 22,000 healthcare organizations within the CONUS representing a diverse portfolio of hospital location, size, and operations tempo. Their pricing is anticipated to match commercial pricing within the CONUS.

OCONUS pricing should be similar, with location predominantly driving price differentiation as compared to CONUS due to international components (visas, flights, etc.) The Contracting Officer will conduct price analysis IAW FAR 15.404-1(b) to determine the anticipated cost to the Government will be fair and reasonable.

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Market research consisted of searches for companies that could perform Accreditation Surveys for Ambulatory MTFs using the Small Business Search website: http://dsbs.sba.gov/dsbs/search/dsp_dsbs.cfm, Ability One website http://www.abilityone.gov, and http://www.gsaelibrary.gsa.gov rendering no results. Also, market research was conducted by calling and visiting the websites of the two companies, TJC & AAAHC. TJC responded by email and a phone call stating that they can meet the requirement. The Director of Accreditation at AAAHC stated that they could not provide all the required items; however they provided pricing for only the items they could offer.

From the responses received from the Sources Sought announcement, a possible OCI brought to the attention of the AF by the Hildebrand Healthcare Consulting, LLC consulting was addressed.

On 25 Oct 19, a Notice of Contract Action (NOCA) to award Sole Source was posted on FBO for a period of 12 days. The deadline to submit responses was 06 Nov 19. No responses were received.

TJC is the only AO that offers the tools, resources, and software (Tracers with AMP) and PPRs necessary for continuous accreditation readiness and sustainment. The Army and Navy currently use the Tracers with AMP.

Cambridge International Systems, Inc: On 26 April 2019, Cambridge reached out to the 773d ESS inquiring about information found on GOVWin in regards to the new requirement for the Ambulatory requirement.

Cambridge provides a varied suite of IT services, to include: Systems development, Systems sustainment, Command, Control, Communications, Computers, Intelligence, Surveillance, and Reconnaissance (C4ISR) within the realm of the DoD. Cambridge did not provide a response to the posted Sources Sought and a review of its portfolio identified that this vendor does not have the capabilities to provide Ambulatory accreditation services.

The Government will continue to analyze the market to determine if any other sources enter the market that would have the capabilities to provide ambulatory accreditation services and any software that provides similar benefits to TJC's proprietary software. In 2006, the AF submitted and received approval from ASD(HA) to procure ambulatory services from AAAHC. However, due to new emerging technologies, the AF has the capability to standardize AF processes, permit dissemination of data across the corporation, and pro-actively identify risk areas. This approach would also ensure standardization with the DoD as DoD MTFs begin to align under DHA.

As evidenced by my signature above, I have determined this document to be both accurate and complete to the best of my knowledge and belief.

As evidenced by my (our) signature(s) above, I (we) certify that any supporting data contained herein, which is

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