HHS SSJ.pdf

Sole Source Justification (SSJ)

RFO - FAR 12.102(b) & 12.201-1

1. Acquisition Title: IHS Produce Prescription Pilot Program Support Contract (P4)

Division: IHS HQ/OCPS/Division of Diabetes Treatment and Prevention (DDTP)

Contracting Activity: Division of Acquisition Policy, Natasha Bitsoi, Contracting Officer

Author: Stacy Hammer, National Nutrition Consultant and Boone Denny, Management Analyst, CORIII

Basis for approval: Individual

2. Nature and/or Description of the Action being Approved: OCPS/ DDTP requests a sole source firm-fixed-price contract with the Center for Nutrition and Health Impact(CHN) Nebraska for a new requirement to support IHS’ Produce Prescription Pilot Program (P4). The Government projects award for September 25, 2026 using X-year funds.

Contractor: The Center for Nutrition and Health Impact Nebraska

Performance

Period

Dates/Duration Unit

Price/CLIN

Multiplier Total

Base Period 12 months $596,200.00 1 $596,200.00

3. Description of Supplies and/or Services:

Produce prescription programs have been shown to increase access to nutritious foods in communities at risk for food insecurity. These programs help meet the needs of individuals and families experiencing food insecurity and diet-related health problems by making fruit and vegetables more readily available to communities in need.

American Indian/Alaska Native (AI/AN) people are disproportionately impacted by food insecurity when compared to non-Native people. They are also more likely to live in areas with low or no access to fresh foods than any other racial or ethnic group. About one in four Native people experience food insecurity, compared to one in nine Americans overall. The higher rates of food insecurity amongst AI/AN people are worsened by water insecurity, loss of land, forced relocation, and environmental pollution, all of which have negatively impacted traditional healthy food practices.

To support Secretary Kennedy’s Make America Healthy Again (MAHA) goal of Putting Real

Food Back on the American Table, IHS began implementing a pilot produce prescription program in 2023 entitled “Produce Prescription Pilot Program (P4).” The aim of P4 is to demonstrate and evaluate the impact of produce prescription programs on AI/AN people and their families. More specifically, the overall goal is to improve health care outcomes by reducing food insecurity and improving overall dietary health by increasing consumption of fruits, vegetables, and traditional foods. In the initial pilot program, IHS awarded $2.5M in grant funding across five grantees with each grantee receiving $500K at a tribal site. The P4 pilot program has since shown some initial success and expanded in 2026 receiving an additional $7M to be awarded to new grantees adding more P4 sites.

Due to the program expansion of P4 in 2026 with additional funding and expanding the number of tribal sites where IHS grantees are implementing produce prescription programs, IHS is in need of specialized contractor support to develop and manage an evaluation framework for its multiple produce prescription sites to include data coordination for both existing sites and additional sites added to the program in 2026.

Required services include immediate operational ability to design and implement an evaluation framework to be used across all sites, existing and new, to support using consistent methods, tools, and definitions to collect data over time, continuity of measurement, comparative and longitudinal analyses, benchmarking, and interpretation of P4 outcomes. The work also includes conducting process and outcome evaluations; collecting, managing, analyzing, and reporting P4 data; and applying appropriate theory of change and measurement methodologies while adhering to Tribal

Institutional Review Board (IRB) processes, data sovereignty, and data governance requirements.

The contractor will also provide evaluation technical assistance and capacity building to P4 grantees, facilitate program and grantee meetings, coordinate nutrition security training, support communities of practice, and disseminate evaluation findings and resources to relevant stakeholders.

4. Statutory Authority Cited and Rationale:

a. This sole source acquisition is being conducted under RFO – FAR 12.201-1 simplified procedures for covered actions > SAT, ≤ $9 million pursuant to 41 U.S.C. 1901.

The contracting officer has determined that only one source is reasonably available based on the following rationale:

Only one source, CHN Nebraska, is reasonably available to satisfy the Government’s requirements for this contract. An award to another vendor would result in substantial duplication of costs to the

Government that is not expected to be recovered through competition and would also result in unacceptable delays in fulfilling the Government’s requirement.

Under an existing, separate government funding grant mechanism with the United States

Department of Agriculture (USDA), CHN Nebraska, developed an evaluation framework specifically to address Produce Prescription grantees under the USDA Gus Schumacher Nutrition

Incentive Program (GusNIP). It developed this framework within its role serving as the national coordinating center for training, technical assistance, and evaluation (NTAE). 154 and 122

Nutrition Incentive grantees. The 154 Produce Prescription grantees from numerous sites include nonprofit organizations, government agencies, Tribal organizations, and universities implementing Produce Prescription and nutrition incentive projects in communities nationwide.

CHN Nebraska maintains an accumulated multi-year dataset for USDA associated with the

GusNIP grantees, including 154 Produce Prescription grantees.

IHS’s new requirement for program expansion of P4 in 2026 requires rapid design and implementation of a produce prescription evaluation program for its existing and new grantees.

The program also requires technical assistance and capacity building for P4 grantees as described in Section 3. Through its USDA GusNIP work, CHN Nebraska, possesses unique knowledge of the produce prescription evaluation frameworks, training, implementation processes, evaluation methodologies, stakeholder relationships, and Community of Practice infrastructure. Effective performance of IHS’ P4 support contract requires design and implementation and training under a compressed timeline. For example, the 2026 P4 grantees have been selected and awaiting Secretary

Kennedy’s announcement. Once the announcement is made by the Secretary, the grantees for 2026 will need immediate support.

While other vendors may possess general evaluation design, implementation and technical assistance capabilities, they do not possess the necessary intellectual property nor do they have the needed familiarity with the existing NTAE evaluation framework, the implementation approach, or the relationships established with tribal stakeholders. The existing frameworks and methods used to develop the GusNIP NTAE framework is proprietary and not publicly available or transferable to another contractor.

Award to another source would result in substantial duplication of cost and effort to the

Government. Without access to the underlying NTAE evaluation framework, a new vendor performing this requirement would essentially have to recreate a new framework and training program and then further tailor it to IHS’ produce prescription program. It would also have to re-establish stakeholder relationships within the existing Indian community and become familiar with the nuances of collecting data from native tribes; work that was conducted by CHN Nebraska over a five-year period to fully develop (USDA grant no. 2019-70030-30415) at a cost of $31M.

The Government estimates that award to another contractor would result in at least $6M in duplicated development costs. This estimate is derived from the base period value of the grant

2019-70030-30415 with CHN Nebraska and covers the initial design of the framework and does not include capacity building and training. The current requirement is a tailoring of the originally-developed NTAE evaluation framework and related data infrastructure to support a streamlined development and implementation effort for the required IHS P4 evaluation framework.

CHN is the only contractor who can utilize the existing evaluation framework and standing relationships with Tribal Organizations to tailor the anticipated IHS evaluation framework to the

IHS P4 program. Because another contractor would not have access to the existing evaluation framework, an alternative source would be required to engage in significant development and re-work to recreate or establish a workable solution before it could provide the required level of quality evaluation support.

The IHS P4 program requires the evaluation contractor support to begin by end of September 2026.

Award to a contractor other than CHN Nebraska would likely result in substantial delays in implementing a tailored prescription produce evaluation and support program. Based on market research, there is no alternative contractor that has established the necessary evaluation framework, or has the ability to, navigate applicable Tribal and the IHS Institutional Review Board

(IRB) and data-governance processes, and establish the capabilities necessary to perform the required evaluation activities. Any delay in the ability to properly evaluate the IHS P4 grantees would result in IHS’ inability to provide the P4 services and guide the intervention and objectives of overall P4 programs in the AI/AN communities. CHN Nebraska's existing evaluation framework infrastructure allow these activities to begin within the government's required performance timeframe and at the required quality level and to continue with the required support activities throughout the anticipated period of performance of one year.

CHN Nebraska is able to begin activities in a compressed timeline because it can leverage the pre-existing NTAE evaluation framework and infrastructure to support activities and sustain the activities that support produce prescription programs at multiple sites across IHS. If another vendor were chosen to perform the present requirement, it would be impossible for it to design and implement an evaluation framework and gain the necessary expertise in the time frame allotted for the performance of this requirement.

In addition to CHN Nebraska’s ability to leverage the existing NTAE infrastructure, CHN

Nebraska possesses experience directly relevant to successful performance of the IHS P4 requirement. CHN Nebraska has more than five years of experience designing, implementing, and evaluating Produce Prescription programs across healthcare and community settings, including work with Tribal-serving healthcare organizations and federally qualified health centers. CHN

Nebraska also has experience providing national training, technical assistance, performance monitoring, and evaluation for Produce Prescription program grantees at multiple IHS sites to include navigating Tribal Institutional Review Board processes, Tribal data sovereignty requirements, and data-governance considerations and has existing working relationships with

Tribal organizations and Urban Indian health systems – all capabilities necessary to support timely implementation and stakeholder engagement for IHS P4. These qualifications and relationships make CHN Nebraska uniquely qualified and well-positioned to implement the IHS P4 evaluation program.

5. Special Considerations for Certain Contract Extensions or Bridge Contracts:

Not Applicable. The Government does not anticipate a bridge contract.

6. Actions to Increase Competition:

The Government issued a Notice of Intent to sole source to for this requirement to give potential offerors an opportunity to express interest in the requirement. The Government also issued a

Sources Sought Notice to review the capabilities of ISBEE/IEEs and/or small businesses. Details of each action are as follows:

a. A Synopsis Was Published: A Notice of Intent (NOI) to sole source was published on

SAM.gov on 8/17 and closed on 8/27, as required by RFO - FAR subpart 5.1.

b. Responses Were Not Received: No response was received in response to the NOI.

Therefore, the notice did not identify any additional sources capable of meeting the

Government’s requirements.

c. Sources Expressing Interest: A Sources Sought Notice was published on SAM.gov from

August 5 through August 14, 2026 to identify capable Indian Small Business Economic

Enterprise (ISBEE), Indian Economic Enterprise (IEE), and Service-Disabled Veteran

Owned Small Business (SDVOSB) sources. Two sources responded: CHN Nebraska and

Bravia Services. Neither respondent was an ISBEE. Following the Program Office's review of both capability statements against the PWS requirements, only CHN Nebraska demonstrated capabilities in alignment with the PWS.

Actions to Foster Competition for Future, Similar Requirements: For future similar requirements, IHS will conduct market research on an annual basis to try to identify additional capable sources and assess opportunities to increase competition. IHS will also consider whether future requirements can be structured to reduce barriers to competition while continuing to meet the Government's programmatic and technical needs.

7. Market Research:

In accordance with RFO FAR 10, IHS conducted market research appropriate to the circumstances for the requirement. Market research methods included industry outreach through the issuance of a Sources Sought Notice (SSN), review of mandatory and required sources, available Government-wide acquisition vehicles, historical procurement information, Government procurement databases, and a Notice of Intent to Sole Source (NOI). A SSN was issued to see if capability exists among ISBEE/IEEs for a set-aside in accordance with the Buy Indian Act (first priority) or among small businesses (second priority). IHS did not receive any ISBEE/IEE response to the SSN or from small businesses. In either case, there was not a reasonable expectation of two or more

ISBEE/IEEs/SBs and thus the requirement was not set aside. The SSN was posted on SAM.gov from August 5 through August 14, 2026, and received two responses; CHN Nebraska (dba Center for Nutrition and Health Impact) and Bravia Services.

Based on the Program Office's review of the capability statements against the PWS, CHN

Nebraska was determined capable. CHN Nebraska demonstrated its capability in the design, implementation and evaluation of Produce Prescription programs through its USDA produce prescription project called “GusNIP NTAE” with USDA which used multi-year datasets encompassing 276 GusNIP grantees, including 154 Produce Prescription grantees, which aligns with the PWS requirement for multi-year, multi-site evaluation data and infrastructure. Bravia

Services did not demonstrate the capability to fulfill the PWS requirements and was determined not capable. Neither respondent is an ISBEE. A NOI to Sole Source was subsequently posted on

SAM.gov from August 17 through August 28, 2026, and no additional responses were received.

Based on the results of market research, CHN Nebraska was identified as the only source available with access to the existing multi-year, multi-site Produce Prescription and infrastructure necessary to support evaluation activities such as continuity of measurement, comparative and longitudinal analyses, benchmarking, and interpretation of IHS P4 outcomes. No other source identified through market research demonstrated capability to meet the PWS' critical data infrastructure and evaluation requirements. Accordingly, in accordance with RFO FAR 12.102(b) and 12.201-1, citing 41 U.S.C. 1901, a sole source acquisition with CHN Nebraska is recommended, subject to approval of the required sole source justification, BIA Deviation, and a determination that the proposed price is fair and reasonable.

8. Procurement history:

This is a new requirement in size (dollar value), scope and complexity and does not have a previous procurement history.

9. Additional Information or Other Facts: Not Applicable

10. Technical or Requirements Program Management Certification: I certify that the supporting data under my cognizance which are included in the justification is accurate and complete to the best of my knowledge and belief.

X Right-Click "Signature Setup"

Stacy Hammer

National Nutrition Consultant Signature &

Date:

12. Fair and Reasonable Price Determination: As the contracting officer, I hereby determine that the anticipated price to the Government will be fair and reasonable, based upon the following:

☐ (1) Price reasonableness based on competitive quotations or offers.

☒ (2) If only one response is received, include a statement of price reasonableness in the contract file. The contracting officer may base the statement on—

☐ (i) Market research.

☒ (ii) Comparison of proposed price with prices found reasonable on previous purchases.

☐ (iii) Current price lists, catalogs, or advertisements. However, inclusion of a price in a price list, catalog, or advertisement does not, in and of itself, establish fairness and reasonableness.

☐ (iv) A comparison with similar items in a related industry.

☐ (v) The contracting officer’s personal knowledge of the item being purchased.

☒ (vi) Comparison to an independent Government estimate.

☐ (vii) Any other reasonable basis, as follows:

13. Contracting Officer (CO) Certification and Approval: I hereby certify that this justification is accurate and complete to the best of my knowledge and belief.

X Right-Click "Signature Setup"

Natasha Bitsoi

Contracting Officer Signature &

Date: