HCA Signed NCO 4 36C244-25-AP-4310 - JA OVER SAT CVAMC HCHV v3.4.pdf

VHAPG Part 806.3 OFOC Page 1 of 5 Revision: 03 Effective Date: 04/15/24 Acquisition ID#: _36C244-25-AP-4310_________________

DEPARTMENT OF VETERANS AFFAIRS

Justification and Approval (J&A) For

Other Than Full and Open Competition (>SAT)

Acquisition Plan Action ID:__ 36C244-25-AP-4310_______

1. Contracting Activity: Department of Veterans Affairs, VISN 04, Coatesville Medical

Center (CVAMC) Healthcare for Homeless Veterans (HCHV) Contract Residential Services (CRS). Purchase request number: 542-25-4-813-0077

2. Nature and/or Description of the Action Being Processed: The purpose of this contract is to obtain a contractor who can provide care and rehabilitation services to Veterans experiencing homelessness, to include Veterans diagnosed with severe mental illness and substance use disorders.

This contract is for a 5-year IDIQ for the estimated amount of $11,260,800.00. The current contract ends 09/14/2025 and a new award is required to avoid interruption in services.

3. Description of Supplies/Services Required to Meet the Agency’s Needs: The Veterans Health Administration (VHA) has been providing direct and specialized services for homeless Veterans for nearly 25 years. The Secretary of the VA has set a zero-tolerance policy for homelessness within the Veteran population. As part of the Plan to End Homelessness among Veterans announced in late 2009, the VHA has been increasing both the capacity of existing programs and services offered to program participants. The plan calls for utilizing new models of care not previously offered by the VHA.

Coatesville VAMC requires a Contractor to continue to provide emergency residential placement and treatment services through the HCHV program. The contract will serve up to a total of 45 homeless Veterans at any given time who need immediate placement in a safe environment with onsite rehabilitation and treatment services. The COR assigned is the homeless program coordinator for CVAMC and will be integral for managing this contract daily. She will utilize the details of the PWS and QASP to monitor census and performance standards. Many of these Veterans have comorbid conditions that include serious mental illnesses, substance abuse disorders, and other serious medical conditions. The goal of Contract Residential Services (CRS) is to rapidly stabilize Veterans’ medical, mental health, substance abuse and other psychosocial issues in order to place to place Veterans in other appropriate transitional or permanent housing within 30 to 90 days, but no more than 180 days. The Contractor will provide rapid placement of VA-referred Veterans in a safe, residential therapeutic setting while addressing the Veterans’ complex needs through on-site case management services. This housing must meet the criteria established both by HCHV clinical staff and VA fire and safety officials.

The 5-year IDIQ will begin September 15, 2025, through September 14, 2030. Task orders will be written against the IDIQ based on need.

4. Statutory Authority Permitting Other than Full and Open Competition:

VHAPG Part 806.3 OFOC Page 2 of 5

Acquisition ID#: _36C244-25-AP-4310_________________

(X ) (1) Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements per 41 USC §3304(a)(1) as implemented by FAR 6.302-1;

( ) (2) Unusual and Compelling Urgency per 41 USC §3304(a)(2) as implemented by FAR 6.302-2;

( ) (3) Industrial Mobilization, Engineering, Developmental or Research Capability or Expert Services per 41 USC §3304(a)(3) as implemented by FAR 6.302-3;

( ) (4) International Agreement per 41 USC §3304(a)(4) as implemented by FAR 6.302-4

( ) (5) Authorized or Required by Statute per 41 USC §3304(a)(5) as implemented by FAR 6.302-5;

( ) (6) National Security per 41 USC §3304(a)(6) as implemented by FAR 6.302-6;

( ) (7) Public Interest per 41 USC §3304(a)(7) as implemented by FAR 6.302-7;

5. Demonstration that the Contractor’s Unique Qualifications or Nature of the Acquisition Requires the Use of the Authority Cited Above (applicability of authority):

The current incumbent who has provided these highly specialized services since 2007 on the Coatesville VA Medical Center has unique and compelling knowledge to provide this highly specialized residential care to chronically homeless Veterans with serious mental illness.

These services are provided to a highly vulnerable population which struggles with receiving consistent services in order to achieve permanent, safe housing.

To open this contract for full competition would lead to a duplication of cost to the government that is not expected to be recovered through competition. In addition, to open for full competition would lead to unacceptable delays in fulfilling the agencies’ requirements for this highly specialized service. The current extension of task order ends on September 14, 2025. It would not benefit the government to open this contract for competition as it would lead to a possible lapse in highly specialized and prioritized services.

Accordingly, Fresh Start Now, INC. (Merakey) is the only firm capable of providing the supplies and services described in Section III above without the Veteran’s Health Administration experiencing substantial duplication of cost that could not be expected to be recovered through competition and unacceptable delays in fulfilling its requirements.

The incumbent contractor has performed successfully and is the only source with the necessary systems and processes in place pertinent to veteran eligibility, electronic patient records, diagnostic requests, invoicing, telemedicine, and other requirements to provide services in accordance with Joint Commission, OIG, and the Coatesville VAMC’s performance requirements.

It is in the best interest of the Government for the contractor to remain onsite at the current location. Award to other than the current Contractor would require transition of the entire requirement and would cause the Coatesville VAMC to incur costs that would not be recovered through competition. Additionally, this allows the Government to make use of existing onsite space, avoiding the cost a vendor incurs when they are leasing space in the community. More importantly this ensures that one of the VA's most vulnerable populations does not have any disruption to their care.

VHAPG Part 806.3 OFOC Page 3 of 5

Acquisition ID#: _36C244-25-AP-4310_________________

6. Description of Efforts Made to ensure that offers are solicited from as many potential sources as deemed practicable: In accordance with FAR 6.302-1 Only One Responsible Source and No Other Supplies or Services Will Satisfy, it would not be conducive to switch to another vendor who will not have the knowledge or capability to provide the highly specialized services. Market research was conducted on performance and there is no reason to believe that the incumbent will not be able to continue satisfactory or higher services.

Market research from the new 5-year IDIQ award for the same services, conducted in 2021 through present was also reviewed and found to be applicable to this sole source award.

Because the agency requires continuity of healthcare services at the current location, only the incumbent contractor will be solicited for this contract. As indicated above, only the incumbent contractor has the necessary systems and processes in place to ensure continuity of healthcare services at the physical site in accordance with Joint Commission, OIG, and the Coatesville VAMC’s performance requirements.

7. Determination by the CO that the Anticipated Cost to the Government will be Fair and

Reasonable: The anticipated cost will be determined fair and reasonable based upon historical contracts and existing contracts for HCHV services located within the same region.

The incumbent had slightly increased pricing from the contract ordering period that expired 09/30/2023. The rate of $110 per Veteran per day estimated is slightly increased ($3.00 more) than the current extended task order 36C24424D0040. Pricing was determined fair and reasonable at the time of that award based off the average census, the rise in salaries, and rise in prices over the last few years. Prices will also be compared to the most recent IGCE submitted by the subject matter experts. This newer IGCE considers a yearly inflation adjustment is consistent with market prices for the same or similar services in the Coatesville VAMC catchment area.

8. Description of the Market Research Conducted and the Results, or a Statement of the Reasons Market Research Was Not Conducted: CVAMC (Coatesville VAMC):

Coatesville VA Medical Center (CVAMC), located in Coatesville, Pennsylvania, has offered an HCHV CERS shelter to street homeless Veterans and Veterans who are at imminent risk of homelessness since its initial requirement in 2011. This is the only facility that offers shelter for Veterans exclusively, as the surrounding Chester/Delaware County shelters lack adequate intensive case management for homeless individuals and operate from 4pm-5am nightly, whereas this service requirement offers a 24/7 facility with intensive case management, discharge planning and connects Veterans to medical and mental health services at CVAMC. Montgomery County (another county in CVAMC catchment area), does not currently have an emergency shelter outside of Code Blue declarations.

City shelters provide a nightly per-diem rate to their contractors, which is aligned with the Government’s practice of providing payment for each unit, or Veteran utilizing the shelter bed per night. CMCVAMC Homeless Programs’ CERS/LDSH Liaison is the COR responsible as well as provides clinical oversight and linkages between the Veteran and CMCVAMC for medical/mental health services. Procedures have been set forth for HCHV within VHA Directive 1162.08 for the administration, monitoring and oversight of HCHV-funded services through VHA Handbook 1162.09: Health Care for Homeless Veterans (HCHV) Program.

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Acquisition ID#: _36C244-25-AP-4310_________________

As described in Section 6 above, market research, in accordance with FAR Part 10, was conducted by synopsis of the proposed acquisition, advising industry of the pending acquisition and soliciting inquiries from interested parties.

9. Any Other Facts Supporting the Use of Other than Full and Open Competition: Not Applicable.

10. Listing of Sources that Expressed, in Writing, an Interest in the Acquisition: None.

11. 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: A recent extension to current task order 36C24424D0040 36C24425N0359 has been issued to cover the period of 07/01/2025 through 09/14/2025 to ensure that these highly specialized services are kept in place.

12. Requirements Certification: I certify that the requirement outlined in this justification is a Bona Fide Need of the Department of Veterans Affairs and 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.

VHAPG Part 806.3 OFOC Page 5 of 5

Acquisition ID#: _36C244-25-AP-4310_________________

Maura Marchese Date HCHV Social Work Supervisor Coatesville VAMC

13. Approvals in accordance with the VHAPM Part 806.3 OFOC SOP:

a. Contracting Officer Certification (required): I certify that the foregoing justification is accurate and complete to the best of my knowledge and belief.

Benjamin Grogg Date Deputy Director NCO4

b. One Level Above the Contracting Officer (Required over SAT but not exceeding $750K): I certify the justification meets requirements for other than full and open competition.

Daniel Shea Date Division Chief, NCO4

c. VHA RPO HCA Review and Approval: I have reviewed the foregoing justification and find it to be complete and accurate to the best of my knowledge and belief and recommend approval (if over $75 million) or approve ($750K to $75 million) for other than full and open competition.

Gerald F. Jacobs Date VHA Head of Contracting Activity Executive Director, RPO-East

08/15/2025

MAURA

MARCHESE

Digitally signed by

MAURA MARCHESE

Date: 2025.08.15 08:37:19 -04'00'

DANIEL SHEA Digitally signed by DANIEL SHEA Date: 2025.08.18 14:43:03 -04'00'

BENJAMIN GROGG

Digitally signed by BENJAMIN

GROGG

Date: 2025.08.18 16:02:41 -04'00'

GERALD JACOBS

Digitally signed by GERALD

JACOBS

Date: 2025.08.27 14:47:07 -04'00'