FAR 13 Class Justification Accreditations Redacted.pdf

CLASS JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION (IAW FAR PART 13)

(Source Selection Information - See FAR 2.101 and 3.104-4)

In accordance with FAR 13.106-1(b), Contracting Officers may solicit from one source if the Contracting Officer determines that the circumstances of the contract action deem only one source reasonably available.

Per FAR 13.106-1(b)(2), this requirement is for supplies and services and exceeds the Simplified Acquisition Threshold (SAT) but is not greater than $7.5 million and the Contracting Officer reasonably expects, based on the nature of the supplies or services sought and on market research, that offers will only include commercial items.

1. Identification of the agency and the contracting activity:

Uniformed Services University of the Health Sciences (USU), Acquisitions Directorate (ACQ)

2. Nature and/or description of the action being approved:

Class justification and approval (J&A) to allow Contracting Officers to issue solicitations and awards for new, firm fixed-price commercial single-source requirements for accreditation and professional organizational memberships for USU, without the requirement to execute a J&A on a contract-by-contract basis. This class justification is authorized by FAR 6.303-1(d) “Justifications required by paragraph (a) of this section may be made on an individual or class basis”, and shall be approved in writing in accordance with FAR 6.304(c).

This class J&A applies to USU ACQ for the acquisition of accreditations and professional memberships only. This J&A shall remain in effect until 30 September 2027.

3. Description of the supplies or services required to meet the agency’s needs (including estimated value):

The USU, chartered by an act of Congress on September 21, 1972 as the nation’s only federal health sciences university, requires certain accreditations and memberships in order to maintain its status as institution of higher education and meet its mission requirements. Accreditations and professional organizational memberships covered under this class J&A include the following:

Association of American Medical Colleges (AAMC): Annual membership in a professional organization for medical colleges in the United States to include the Liaison Committee on Medical Education (LCME), the accreditation body for medical schools, during survey years.

Accreditation Council for Graduate Medical Education (ACGME): ACGME provides accreditation for United States graduate medical education (residency and fellowship) programs.

Association of Schools and Programs of Public Health (ASPPH): Annual membership with professional organization representing schools of public health and academic programs in the area of public health with medical colleges in the United States.

Council on the Accreditation of Nurse Anesthesia Educational Programs (COA): Annual membership and accreditation fee for nurse anesthesia programs within the United States.

Consortium of Universities of the Washington Metro Area (CUWMA): Annual membership fee for regional association for medical colleges and academic programs within the Washington metro area.

Middle States Commission on Higher Education (MSCHE): MSCHE is a regional accreditation agency recognized by the United States Department of Education (USDE) that serves as an independent voice in higher education. MSCHE establishes equitable standards for accreditation with member institutions that advance the impact of accreditation in the ever-changing landscape of higher education and promotes educational excellence through innovation across diverse institutions.

The above listed organizations each offer a unique membership and/or accreditation for which there is no equivalent that will meet the Government’s requirements.

The total estimated value of the class J&A is $2,560,880. ACQ calculated estimated totals by applying five percent escalation to FY22 totals for FY23 and subsequent fiscal years with an assumption of constant enrollment for those enrollment-based fees. The estimated yearly requirements by organization and totals per fiscal year and requirement are listed below:

4. Demonstration that the proposed contractor’s unique certifications or the nature of the acquisition requires use of the authority cited:

Descriptions of the proposed professional organizations and accreditation agencies and their unique qualifications, which makes each the only source reasonably available to meet USU requirements are listed below:

Association of American Medical Colleges (AAMC): Annual membership includes professional development for faculty and staff, policy and advocacy, data analysis and research, member capacity building programs, subject matter expertise, applicant and student services resources, publications, and Liaison Committee on Medical Education (LCME) assistance and accreditation services.

AAMC represents all accredited medical schools in the United States and Canada that grant the MD degree.

The AAMC and the LCME (established through joint sponsorship by the AAMC and AMA) is the recognized professional and accreditation organization for medical colleges within the United States, its territories and possessions, respectively. Institutional membership is required for the mission and responsibilities of F. Edward Hébert School of Medicine. AAMC membership allows for the continuation of accreditation of USU’s School of Medicine academic programs. Graduates of LCME-accredited schools are eligible for residency programs accredited by the Accreditation Council for Graduate Medical Education.

Therefore, AAMC is the only source reasonably available that meets the agency’s requirements.

Accreditation Council for Graduate Medical Education (ACGME):

ACGME sets standards for U.S. graduate medical education (residency and fellowship) programs and the institutions that sponsors them, and renders accreditation decisions based on compliance with these standards.

ACGME offers the only accreditation for graduate medical education (GME) in the United States, its territories, and possessions.

ACGME currently oversees the post-graduate education and training for all MD and DO physicians in the United States. Residency programs must be ACGME-accredited in order to receive graduate medical education funds from the federal Center for Medicare and Medicaid Services. Residents must graduate from ACGME-accredited programs to be eligible to take their board certification examinations and obtain physician licensure. Therefore, the ACGME is the only source that meets the agency’s requirements.

Association of Schools and Programs of Public Health (ASPPH):

ASPPH is the recognized membership association representing schools of public health and academic programs in the area of public health within the United States, its territories and possessions through its Council on Education for Public Health (CEPH). CEPH is an independent agency recognized by the United States Department of Education (USDE) to accredit schools of public health and programs in public health.

ASPSPH represents schools and programs accredited by CEPH and CEPH is the only organization recognized by the USDE to accredit public health schools and programs. Therefore, ASPPH is the only source that meets the agency’s requirements.

Council on the Accreditation of Nurse Anesthesia Educational Programs (COA):

COA is nationally recognized by the USDE and the Council for Higher Education Accreditation (CHEA) as an accrediting agency for the accreditation of institutions and programs of nurse anesthesia at the post-master’s certificate, master’s, or doctoral degree levels in the United States, and its territories, including programs offering distance education. Moreover, the COA is the only recognized accreditation organization for nurse anesthesia programs within the United States, its territories and possessions.

COA program accreditation is necessary in order for USU graduates of the USU Daniel K. Inouye Graduate School of Nursing (GSN) to practice as Certified Registered Nurse Anesthetists (CRNA).

Therefore, COA is the only source that meets the agency’s requirements.

Consortium of Universities of the Washington Metro Area (CUWMA):

CUWMA is the recognized association comprised of the premier educational institutions in the National Capital Region. The Consortium represents a cross-section of private universities, state public universities, community colleges, and minority-serving institutions, as well as federal universities and the Smithsonian Institution.

CUWMA provides exclusive and innovative opportunities to highlight and advance institutions through collaboration, knowledge sharing, professional development, best practices, experiential education, strategic advocacy, leading-edge solutions and more. Membership with CUWMA allows GSN PhD students to take courses at CUWMA membership universities not offered at USU. Membership also provides visibility on the Washington Metro area higher education issues and initiatives.

There are no other professional education organizations specific to institutions in the National Capital Region that provide the aforementioned services. Therefore, CUWMA is the only source that meets agency requirements.

Middle States Commission on Higher Education (MSCHE):

MSCHE is an institutional accreditor recognized by the USDE. As an institutional accreditor, MSCHE requires evaluation of all aspects of the institution holistically, including modality of instruction, and everything done in the name of the institution, including all academic programs and services, fall within their scope of accreditation.

MSCHE verifies the quality of higher education through peer review, assessment, and evaluation.

MSCHE is an active partner in quality assurance through its service as a voluntary, non-governmental, membership association for institutions of higher education throughout the United States as well as globally.

Accreditation is mission- essential for USU to retain standing and recognition of its undergraduate and post-graduate academic programs. MSCHE, is the recognized accreditation source by the USDE association for universities, colleges, medical colleges and other licensed academic programs in the Mid-Atlantic region and pursuing accreditation through another regional accreditation agency is not practical. Therefore, MSCHE is the only source that meets agency requirements.

5. Procedures of FAR 13.5 were or will be used in accordance with 41 USC 1901 or the authority of

41 USC 1903 (including publicizing required justifications): X Yes No

6. Description of market research conducted and the results, or a statement of the reason market research was not conducted:

In addition to notices posted in accordance with FAR 5.201, ACQ conducted yearly market research for each accreditation and professional organization membership. Market research included online research by key terms for each accreditation or organization, review of other Government-wide acquisition contracts, mandatory sources in accordance with FAR Part 8, and review of previous contract awards and market research for the same or similar supplies and services.

The annual market research for each accreditation agency and professional organization did not identify additional qualified sources. Market research will be conducted annually to ensure there are no other sources for these memberships, accreditations, and services.

7. A determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable.

The Contracting Officer will determine the anticipated price to the Government of the services covered by this class J&A will be fair and reasonable for each contract action under this class J&A. Techniques to determine fair and reasonable pricing include but are not limited to those listed at FAR 13.106- 3(a)(2). Certified cost or pricing data shall not be required based on the exception for commercial services per FAR 15.403-1(b)(3).

8. Any other facts supporting the use of other than full and open competition:

A summary of the procurement history for each accreditation agency or professional organization is provided below. All prior awards were other than full and open competition using the authority in FAR 13.106-1(b) or 13.501(a)(1)(ii).

The acquisition history provided covers the last three years from fiscal years 2020 to fiscal year 2022.

USU did not make an award to COA in fiscal year 2020. In fiscal year 2022, USU made two separate awards to the AAMC, as the AAHC merged with that organization (AAMC). As noted, going forward USU will make one award to AAMC.