FAR 13 Justification_Class_FY25 Memberships and Accreditations_Fully Signed_Redacted.pdf

PROCUREMENT SENSITIVE INFORMATION – FOR OFFICIAL USE ONLY

Justification and Approval for Other than Full and Open Competition under FAR Part 13

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 (USUHS), Acquisitions Directorate

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

Issuance of the Class Justification and Approval (J&A) to allow Contracting Officers to issue follow-on awards for new, firm fixed-price, commercial, single-source requirements for accreditations 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 the acquisition of accreditations and organizational memberships only. This J&A shall remain in effect until 31 December 2029.

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

The Uniformed Services University of the Health Sciences require certain accreditations and memberships 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 accreditation/membership fee for the periods of July 1st through June 30th.

Association for the Accreditation of Human Research Protection Program (AAHRPP): Annual accreditation/membership fee for the periods of January 1st through December 31st.

Accreditation Council for Graduate Medical Education (ACGME): Annual accreditation/membership fee for the periods of January 1st through December 31st.

Accreditation of Laboratory Animal Care International (AAALAC): Annual accreditation/membership fee for the periods of January 1st through December 31st.

Association of Schools and Programs of Public Health (ASPPH): Annual accreditation/membership fee for the periods of July 1st through June 30th.

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

Below are descriptions of the proposed professional organizations and accreditation agencies, highlighting their distinct qualifications. Each entity is the only viable option to satisfy USU requirements due to these unique attributes:

Association of American Medical Colleges (AAMC):

The AAMC 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. 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 membership allows for the continuation of accreditation of USU’s School of Medicine academic programs.

The AAMC represents all accredited medical schools in the United States and Canada that grant the MD degree and is the only known body which provides such membership.

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

Association for the Accreditation of Human Research Protection Program

(AAHRPP):

AAHRPP accreditation/institutional membership assists USU to meet the University’s goal of protecting human research participants in USU-conducted or supported research and being recognized as a competent research collaborating institution by providing an independent, rigorous analysis of our University-wide Human Research Protection Program (HRPP) that demonstrates that it upholds high ethical standards as validated by an external comprehensive assessment by the nationally recognized accreditation organization.

AAHRPP is the only known body which provides such accreditation. Therefore, AAHRPP is the only source reasonably available that meets USU’s requirements.

Accreditation Council for Graduate Medical Education (ACGME):

ACGME is the only recognized accreditation organization for graduate medical programs within 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 to receive graduate medical education funds from the federal Center for Medicare and Medicaid Services. Additionally, all residents must graduate from ACGME-accredited programs to be eligible to take board certification examinations and obtain physician licensure. This accreditation fee to ACGME will further the mission and responsibilities of the Graduate Medical Education (GME) Department and will allow USU to maintain the accreditation of its academic GME programs.

ACGME offers the only accreditation for graduate medical education (GME) in the United States, its territories, and possessions. Therefore, the ACGME is the only source that meets USU’s requirements.

Accreditation of Laboratory Animal Care International (AAALAC):

The AAALAC International accreditation program evaluates organizations that use animals in research, teaching or testing and is a requirement to comply with applicable local and national laws that regulate animal research.

AAALAC is the only known body which provides such accreditation. Therefore, AAALAC is the only source reasonably available that meets USU’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 known organization recognized by the USDE to accredit public health schools and programs. Therefore, ASPPH is the only source that meets USU’s requirements.

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

CUWMA is the recognized association of leading 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.

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 USU’s requirements.

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

COA is nationally recognized by the U.S. Department of Education 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. 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 USU’s requirements.

Middle States Commission on Higher Education (MSCHE):

MSCHE serves as an institutional accreditor recognized by the U.S. Department of Education; through its role as a voluntary, non-governmental membership association for higher education institutions across the United States, MSCHE verifies the quality of higher education through peer review, assessment, and evaluation. This process ensures that institutions meet established standards of educational excellence and quality assurance.

Accreditation is a 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 known source that meets USU’s 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

If the notice to the Governmentwide Point of Entry (GPE) will not be publicized, indicate which exception applies:

This requirement is under $25,000. No synopsis to the GPE is required. (FAR 5.101(a)(1))

The following exception under FAR 5.202 applies: None.

6. Determination by the Contracting Officer that the anticipated cost/price to the Government will be fair and reasonable.

During the annual renewal of each accreditation and membership, ACQ will review historical data about previously obtained accreditations and memberships, and accessible price lists or publicly available information.

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

Annual market research for previously procured accreditation and memberships did not identify additional qualified sources for the professional organizations included in this proposed Class J&A. Market research will continue to be conducted annually to ensure there are no other sources for these memberships, accreditations, and services are available.

In the event that additional potential sources arise, USU will conduct an evaluation to determine if competition for future needs is in the best interest of the Government.

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

None.