FAR-Part6-JA - Signed_21Jan21_Redacted.pdf

Control No: 21-003 Contractor: Innovative Information Solutions, LLC

Program: Credentialing and Priveleging Services

FAR Part 6 Justification and Approval for Other than Full and Open Competition

1. Contracting Activity: National Guard Bureau (NGB), Operational Contracting Division (NGB-AQ), 111 South George Mason Dr., Arlington, VA 22204-1382.

2. Description of Action: The Army National Guard (ARNG) Chief Surgeon’s Office (CSG) requests a firm-fixed-price contract with Innovative Information Solutions, LLC (IIS). The anticipated action will provide continuity of critical services while NGB continues to procure these services through the approved acquisition strategy. The Government projects award for 27 Jan 2021 and fiscal year 2021, Army Operations and Maintenance funds will be used.

3. Description of Supplies/Services: This action provides centralized credentialing and privileging services to the ARNG Office of the Chief Surgeon (ARNG-CSG). These non-personal services include; (1) establish, process, and posture initial entry provider credential files (PCF’s) for presentation to the Centralized Credentialing & Privileging Preparation (C2P2) Board for approval and recommendation to the State Surgeon to grant and privileges; (2) conduct systematic reviews of PCF’s for expiring documents and interchange with current documents, to ensure the file remains current at all times and for presentation to the C2P2 board for reaccreditation every two years; (3) initiate PCF’s for electronic transmittal of privileged provider credentials, known as an Inter-facility Credentials Transfer Brief (ICTB’s), which is the act of transferring a provider’s active privileges from the ARNG to a designated Military Treatment Facility (MFT).

Period Dates Estimated Value Base Period 27 Jan 2021 to 26 May 2021 $ Option 1 (3-month period) 27 May 2021 to 26 Jul 2021 $ Option 2 (3-month period) 27 Jul 2021 to 26 Sep 2021 $ Exercising of the -8 option 27 Sep 2021 to 26 Mar 2022 $

TOTAL $

4. Authority Cited: 10 U.S.C. 2304(d)(1)(B), as implemented by FAR 6.302- 1(a)(2)(iii)(B), Only one responsible source and no other supplies or services will satisfy agency requirements.

5. Reason for Authority Cited: As described at FAR 6.302-1, when the supplies or services required by the agency are available only from one responsible source, or for DoD, NASA and the Coast Guard, from only one or a limited number of responsible sources, and no other types of supplies or services will satisfy agency requirements, for which full and open competition need not be provided.

The only responsible source capable of providing the services is Innovative Information Solutions LLC (IIS) and no other source will satisfy agency requirements. Any other

Program: Credentialing and Priveleging Services source would result in unacceptable delays in fulfilling the agency’s requirements (10 U.S.C. 2304(d)(1)(b), as implemented by FAR 6.302-1(a)(2)(ii)(B)).

Individual Soldier health readiness is the foundation of the Army National Guard combat and State mission readiness. At the center of maintaining this medical mission readiness is the requirement that the 2500-3000 uniformed and full-time federal Government civilian medical health care providers to be credentialed and privileged per Army Regulation (AR) 40-68 and Department of Defense Instruction (DoDI) 6025.13. This credentialing and privileging compliance has a direct impact on Soldier Deployability and the readiness of ARNG units. The continuous daily processing of health care provider information under the Credentialing and Privileging contract ensures this compliance.

On 21 Jan 2020, NGB issued Request for Proposal W9133L-20-R-1000 (hereinafter the “Solicitation”) on the Government-wide Point of Entry (GPE) for centralized Credentialing and Privileging services. Following evaluation and award of IDIQ contract W9133L-20- D-1000 on 05 May 2020, two separate post-award protests were filed with the Government Accountability Office (GAO). The second protest (B-418749.2) was dismissed by GAO on 24 November 2020 pending corrective action by NGB which entails conducting discussions with offerors, re-evaluating proposals, and issuing a new source selection decision. The Government has estimated this process could take up to 120 days to complete. Only the current vendor providing Credentialing and Privileging services, IIS, is capable of continuing the services past the current contract end date of 26 January 2021 without a critical impact to Government mission.

The transition of these services to any other vendor would incur estimated transition delays of 30-60 days based upon the need to initiate new system access for the new source, Common Access Card (CAC) issuance, familiarizing any new vendor with all applicable processes, and transitioning contractor employee personnel. Each day of delay would result in credentialing and privileging backlogs. These delays would have the real-world impact of degrading the centralized credentialing and privileging program, increasing the number of Soldiers that are non-deployable, and reducing unit readiness levels and ability to deploy for Federal or State Missions. This would result in the agency being non-compliant with current DoD and Army regulations.

6. Efforts to Obtain Competition: Following the issuance of a sources sought and the required synopsis under FAR 5.201, the Credentialing and Privileging Services solicitation (W9133L20R1000) was issued 21 Jan 2020. The Government obtained adequate competition and award was made 05 May 2020. As part of the Government’s planned corrective action to GAO protest 418749.2, the Government will be entering discussions with eligible vendors within the competitive range. Because this short-term bridge is a sole source action, effective competition is not applicable.

7. Actions to Increase Competition: No additional steps will be taken to increase competition as the Government obtained effective competition as outlined in paragraph 6 above. This short-term bridge contract will ensure that services continue while the original competitive effort is completed and new contract issued.

Program: Credentialing and Priveleging Services

8. Market Research: Market research was originally completed by ARNG-CSG on 18 November 2019 for solicitation W9133L-20-R-1000. The market research identified 17 potential vendors, both large and small, that were capable of performing the Credentialing and Priveleging work.

In accordance with Defense Federal Acquisition Regulation Supplement (DFARS) 205.205-71, DFARS 206.302-1(d), and DFARS Procedures, Guidance and Information (PGI) 206.302-1(d), a sources sought was posted to www.beta.sam.gov on 22 August 2018 and 20 September 2019. Each sources sought was posted for 30 days.

The 22 August 2018 request for information received responses from five vendors indicating their capability to perform the work. The 20 September 2019 sources sought received 12 additional responses from industry.

The updated market research conducted on 01 December 2020 identified no additional sources than those already identified below.

9. Interested Sources: The below firms expressed an interest in the acquisition and were respondants to the sources sought notices. There are no known vendors that indicated interest in the requirement outside of those on this list and the four vendors that submitted proposals in response to the W9133L-20-R-1000 solicitation.

Firm Location Envision Unlimited Solutions Vienna, VA Palmetto GBA Columbia, SC Soft Power Solutions Manassas, VA Integral Consutling Services, Inc. Gaithersburg, MD RV Global Solutions, Inc. Trenton, NJ Terra Firma Solutions, Inc. Ponca City, OK Spectrum Health Resources, Inc. St. Louis, MO Resource Metrix Alexandria, VA Razor Consulting Solutions, Inc. Fargo, ND PSI (IIS) Arlington, VA Muscogee Staffing Services Okmulgee, OK Micro Health, LLC Vienna, VA Fed Pro Services, LLC Jackson, MS GMP Wimberley, TX Broadleaf, Inc. Manassas, VA Arrowpoint Corporation McLean, VA Apprio, Inc./JTS Washington, D.C.

10. Procurement History:

Contract Period of Performance Type award W9133L-20-D-1000 TBD * Competitive, 100% SB set-aside

Program: Credentialing and Priveleging Services

W9133L-15-C-0039 27Jul15 – 26Jan21 Competitive, 100% SB set-aside W9133L-10-F-0173 16Jun10 – 15Jun15 Competitive, Full & Open FSS order

* This contract was originally protested at GAO and protest lifted pending agency corrective action. Final award period of performance start date is anticipated as May 2021.

11. Technical Certification: I certify that the supporting data under my cognizance which are included in the justification are accurate and complete to the best of my knowledge and belief.

12. Requirements Certification: I certify that the supporting data under my cognizance which are included in the justification are accurate and complete to the best of my knowledge and belief.

Program: Credentialing and Priveleging Services

13. Fair and Reasonable Cost Determination: I hereby determine that the anticipated cost or price to the Government for this contract action will be fair and reasonable.

This determination will be made using the following: cost analysis price analysis should cost IGCE audit: other:

As a part of this basis, certified cost or pricing data:

will be required.

will not be required and the following exception applies (FAR 15.403):

A commercial item is being acquired.

14. Contracting Officer Certification: I certify that this justification is accurate and complete to the best of my knowledge and belief.

Program: Credentialing and Priveleging Services

Approval

Based on the foregoing justification, I hereby approve the procurement of Credentialing and Priveleging Services for the estimated amount of $ on an other than full and open competition basis pursuant to the authority of 10 U.S.C.2304(c)(1), subject to availability of funds, and provided that the services or property herein described have otherwise been authorized for acquisition.