HQ-2661-JOFOC YRTC Portland IHS Comp AD approved_Redacted.pdf

Justification for Other than Full and Open Competition

(JOFOC) RF

1. Acquisition Title: Youth Residential Treatment Center (YRTC) services

Division: Office of Clinical Support

Contracting Activity: Indian Health Service, Portland Area Indian Health Service

Author: Sean Wease, COR Specialist and Ashley Tuomi, OCS Director, Sheila Sells, Contract Specialist

2. Nature and/or Description of the Action being Approved:

The Youth Regional Treatment Center (YRTC) program was established to provide high-quality, comprehensive, and culturally responsive residential treatment services for American Indian and Alaska Native (AI/AN) youth experiencing alcohol and/or substance use disorder and to support their families throughout the treatment process. The primary purpose of the YRTC Program is to provide specialized treatment designed to address alcohol and/or drugs and substance misuse, reduce or eliminate physical and psychological dependence, and promote sustained recovery and overall well-being.

An integral component of the YTRC Program is assisting youth in developing and implementing individualized aftercare plans that support continued sobriety and successful reintegration into their families and communities following discharge. A distinguishing feature of the YRTC model is the integration of AI/AN culture throughout the treatment process. Culturally responsive services may include reinforcement of cultural norms supporting sobriety; recognition of responsibility to the Tribe, village, band, and/or clan;

culturally appropriate clinical care; family involvement; alcohol and substance use evaluation; food services; recreational activities; and other supportive services designed to promote recovery and wellness.

YRTC facilities identified on the Indian Health Service (IHS) website are IHS-funded and provide eligible AI/AN youth and their families access to treatment services at no cost. These facilities serve designated geographic regions and provide specialized treatment that incorporates the cultural, clinical, and development needs of AI/AN adolescents.

The Portland Area Indian Health Service, Office of Clinical Support, requires specialized residential behavioral health and substance use disorder treatment services for eligible AI/AN adolescents through the IHS YRTC program. To ensure continuity and availability of these recurring services, the anticipated contract will consist of one 12-month Base Year and four (4) 12-month Option Years. The table below provides the estimated dollar value for each performance period, including the potential 6-month extension.

The Independent Government Cost Estimate and above table coincide with the Base Plus Option Years amounts and as solicitation clauses identifies FAR 52.217-8, Option to Extend Services. The Government is noting additional funds for 6-months, increasing the total estimated contract value to

Statutory Authority Cited and Rationale:

This acquisition is conducted pursuant to Only One Responsible Source, as implemented by HHS and IHS acquisition policies. Based on the Government’s market research and capability assessment, the Native American Rehabilitation Association of the Northwest (NARA NW) Youth Regional Treatment Center (YRTC) is the only responsible source identified that can satisfy the Government’s complete minimum requirements for specialized residential behavioral health and substance use disorder treatment services.

NARA NW is an IHS-supported YRTC located in Oregon and provides specialized 24-hour residential behavioral health and substance use disorder treatment services for eligible American Indian and Alaska Native (AI/AN) youth. Its established program provides the residential infrastructure, qualified clinical resources, culturally responsive treatment model, and integrated services necessary to address the clinical, cultural, developmental, and recovery needs of the population served.

Of particular significance, NARA NW is currently providing residential treatment services to twelve (12) AI/AN youth. These youth are actively receiving care and are engaged in established individualized treatment plans, therapeutic relationships, clinical services, medication management and referrals as applicable, family and Tribal coordination, and other ongoing treatment and recovery services. The Government’s requirement is therefore an immediate and continuing direct patient care need, not a prospective requirement for a program that has yet to be established.

The Government requires more than general behavioral health services, healthcare staffing, or access to a conventional residential facility. The requirement is for an established and fully operational residential treatment program capable of providing the complete continuum of specialized YRTC services identified in the PWS. Any alternative source would need to demonstrate that it possesses the required licensed residential treatment infrastructure, qualified clinical staffing, culturally responsive AI/AN treatment capabilities, and operational capacity to assume the complete requirement while maintaining continuity of care for youth currently receiving treatment.

Transitioning the twelve (12) youth currently in residential treatment to another provider would involve substantially more than an administrative change in contractors. It could require the transfer and reestablishment of treatment plans, clinical and therapeutic relationships, medication management and referrals, patient records, family and Tribal coordination, and other essential care functions. Such a transition could introduce risks of delays, gaps in services, and disruption to ongoing treatment. The Government’s market research did not identify another responsible source that demonstrated the existing facility, clinical capability, culturally responsive treatment model, and operational capacity necessary to assume and perform the complete requirement within the required service area.

Accordingly, based on the totality of the market research, the specialized nature of the YRTC requirement, and the immediate need to maintain continuity of treatment for the twelve

(12) AI/AN youth currently receiving residential care, NARA NW is the only responsible source identified that can satisfy the Government’s complete minimum requirements without introducing unnecessary risk of disruption to essential patient care.

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

Not Applicable.

6. Actions to Increase Competition:

a. A Notice was Published:

Contracting published Sources Sought Notice No. 75H71326Q00070 on SAM.gov on 07/22/2026 through 07/28/2026 to identify potential sources capable of providing the specialized residential behavioral health and substance use disorder treatment services required under the IHS YRTC Program.

The requirement is critical to the Government’s mission and supports the continued availability of specialized direct patient care treatment, and referral services for eligible AI/AN youth. The response period for the Sources Sought Notice was established in consideration of the recurring nature of the requirement, the need to maintain continuity of essential patient care services, and the results of previous acquisition planning and market research. Previous Sources Sought Notice for this requirement were publicized for longer periods, including an 11-day response period, without receiving responses from interested vendors.

The 2026 Sources Sought Notice was publicized through the Government’s designated procurement portal in accordance with applicable acquisition requirements to determine whether additional responsible sources existed that could satisfy the Government’s specialized YRTC requirements.

In addition, the Government intends to publish a Notice of Intent to Sole Source, as applicable, to provide potentially interested parties an additional opportunity to identify themselves and demonstrate their capability to satisfy the Government’s requirements.

Contracting will evaluate all timely capability statements, proposals, or other responses received in accordance with the terms of the applicable notice.

For future acquisitions, Contracting will seek to provide expanded response periods when acquisition timelines permit. Sources Sought Notice will generally be publicized for at least 10 calendar days, with consideration given to a 15 calendar day response period based on the estimated dollar value, complexity, and circumstances of the requirement. These actions are intended to maximize opportunities for capable sources to identify themselves and participate in future acquisitions.

b. Responses were Received:

Two responses were received to Sources Sought Notice No. 75H71326Q00070: 1 from a small business and 1 from an Indian Small Business Economic Enterprise (ISBEE). Both responses were forwarded to the appropriate technical/program subject matter experts for evaluation against the Government’s minimum requirements as identified in the

PWS.

This represented a change from prior market research efforts, during which no interested parties submitted capability information. Because no responses were received during those earlier efforts, the Program was unable at that time to evaluate whether alternative vendors possessed the facilities, experience, resources, and specialized capabilities necessary to perform the complete YRTC requirements.

For the current acquisition, the Government evaluated the information submitted by both respondents to determine whether either source demonstrated the ability to provide the required residential treatment facility and comprehensive YRTC services.

Neither respondents demonstrated the capability to satisfy the Government’s minimum requirements.

c. Sources Expressing Interest:

The Government received two (2) responses to the Sources Sought Notice. The capability information submitted by both respondents was evaluated against the complete requirements of the PWS.

Business Staffing of America, Inc., d/b/a PsyPhyCare, a small business located in Addison, Illinois, demonstrated experience providing healthcare staffing and licensed healthcare professionals in federal and regulated environments. However, its submission did not demonstrate that the firm operates or has access to a qualifying residential treatment facility within Oregon or the required service area, nor did it demonstrate the integrated clinical infrastructure and culturally responsive treatment program necessary to provide the complete YRTC requirement.

BHPE, located in Oklahoma City, Oklahoma, identified itself as an SDVOSB, VOB, and IEE.

The information reviewed primarily demonstrated capabilities in construction, facility repair, industrial services, equipment, furniture, and medical supplies. The information did not demonstrate access to a qualifying residential treatment facility or the specialized clinical and culturally responsive treatment capabilities required by the PWS.

Based on the Government’s evaluation, neither respondent demonstrated the facilities, clinical capabilities, culturally responsive treatment model, or operational capacity necessary to perform the complete YRTC requirement within the required service area.

The capability submissions and Government evaluation are maintained in the contract file.

d. Actions to Foster Competition for Future, Similar Requirements:

The Government will continue to conduct market research and publicize appropriate notices to identify additional qualified sources and promote competition to the maximum extent practicable. Market research will not be limited to future follow-on acquisitions; the Government will also conduct and document additional market research prior to exercising contract option periods to determine whether market conditions have changed, additional responsible sources have become available, or the circumstances supporting the current limitation on competition continue to exist.

Future market research efforts may include publication of Sources Sought Notices through SAM.gov and other appropriate federal acquisition platforms; use of GSA eBuy and Unison, when appropriate to the acquisition strategy; outreach through Buy Indian Industry Days and other industry engagement events; engagement with Indian Economic Enterprises and other socioeconomic business communities; and coordination with other IHS Areas and facilities that acquire or utilize similar YRTC or residential behavioral health services.

The Government will also continue to assess changes in the marketplace, including the establishment, expansion, or availability of residential treatment facilities capable of providing the complete scope of specialized services required for AI/AN youth. Any potential sources identified through these efforts will be evaluated against the Government’s minimum requirements, including residential treatment infrastructure, clinical staffing and licensing, specialized behavioral health and substance use disorder treatment capabilities, culturally responsive services, geographic requirements, and the complete scope of services identified in the applicable PWS.

Prior to exercising an option period, the Contracting Officer will review the results of updated market research and determine whether continued restriction of competition remains appropriate or whether the acquisition strategy can be modified to increase competition while maintaining continuity of essential patient care. These continuing efforts are intended to expand the Government’s knowledge of the marketplace, encourage participation by qualified sources, and promote competition for future requirements and option periods whenever practicable and consistent with the Government’s patient care and programmatic requirements.

7. Market Research:

The Government conducted comprehensive market research to determine whether responsible sources other than the Native American Rehabilitation Association of the Northwest (NARA NW) could provide the complete Youth Regional Treatment Center (YRTC) requirement for eligible American Indian and Alaska Native (AI/AN) youth and their families.

The market research included SAM.gov searches under NAICS Code 623220, Residential Mental Health and Substance Abuse Facilities; review of Native American and other socioeconomic business concerns; publication of Sources Sought Notice No.

75H71326Q00070; evaluation of capability information submitted by interested parties;

review of Indian Health Service (IHS) information concerning federally operated and tribally operated YRTCs; and consideration of prior acquisition history and market research associated with this recurring requirement.

On July 22, 2026, the Government conducted a SAM.gov search under NAICS Code 623220 and identified 61 firms, including eight (8) 8(a) Native-owned firms. Although the search identified firms registered under the applicable NAICS code and socioeconomic categories, registration alone did not demonstrate that the identified firms possessed the complete combination of licensed residential treatment infrastructure, qualified clinical staffing, specialized behavioral health and substance use disorder treatment capabilities, culturally responsive AI/AN youth services, geographic availability, and operational capacity necessary to satisfy the Performance Work Statement (PWS).

To further assess the capability of the marketplace, the Government published Sources Sought Notice No. 75H71326Q00070 on SAM.gov from July 22, 2026, through July 28, 2026.

The notice resulted in two (2) expressions of interest. One respondent primarily demonstrated experience providing healthcare staffing services, while the second primarily demonstrated capabilities associated with construction, facility repair, industrial services, equipment, furniture, and medical supplies. Following review of the capability information by the Program Office, neither respondent demonstrated the combination of established residential treatment infrastructure, specialized clinical capability, culturally responsive AI/AN youth treatment services, and operational capacity necessary to perform the complete YRTC requirement.

The Government also considered prior acquisition-related market research. A Sources Sought Notice issued in July 2020 for the recurring YRTC requirement resulted in no responses from interested parties demonstrating the capability to provide the complete specialized residential behavioral health and substance use disorder treatment services required by the YRTC Program. The results of the prior and current Sources Sought Notices, when considered together with the additional SAM.gov research, demonstrate a limited pool of sources that have shown the capability to perform the complete specialized requirement.

The Government also reviewed available IHS YRTC Program information. NARA NW is identified as an IHS-supported YRTC located within Oregon and the Portland Area service region. NARA NW possesses established residential treatment infrastructure, specialized clinical capabilities, and experience serving AI/AN communities. NARA NW also maintains the clinical staffing, applicable certifications and licenses, treatment infrastructure, and established service capability necessary to perform the required services in accordance with the PWS.

The Government's requirement extends beyond the provision of healthcare personnel or a residential facility. The YRTC requirement is an integrated residential treatment program requiring specialized clinical care, qualified personnel, established treatment protocols, appropriate residential infrastructure, culturally responsive services, and coordination with families, Tribal communities, IHS, referral sources, and other healthcare providers. These integrated capabilities are necessary to support the behavioral health, substance use disorder treatment, residential, cultural, and recovery needs of eligible AI/AN youth.

Continuity of care is also a significant consideration in the Government's acquisition planning. At the time of this market research, NARA NW is actively providing residential treatment services to twelve (12) AI/AN youth who are currently engaged in established treatment plans, therapeutic relationships, clinical services, care coordination, and culturally responsive support services. Transitioning the requirement to another provider would involve substantially more than an administrative change in contractors. A new provider would need to demonstrate the ability to assume the complete residential treatment requirement, provide or establish appropriate licensed treatment infrastructure and qualified clinical staffing, coordinate the continuation of treatment plans and patient information, address medication management and clinical referrals, establish relationships with patients and families, coordinate with Tribes and IHS programs, and provide culturally responsive services while maintaining continuity of ongoing patient care. The Government's market research did not identify another source that demonstrated an existing capability to assume these responsibilities and provide the complete required services within the required geographic service area.

Based on the totality of the market research and procurement history, the Government has not identified another responsible source that demonstrated the capability and existing capacity to satisfy the complete YRTC requirement within the required service area. The market research therefore supports limiting competition and proceeding with a sole-source acquisition to NARA NW. This approach supports continuity of essential direct patient care for the twelve (12) AI/AN youth currently receiving residential treatment, minimizes the risk of disruption to ongoing clinical and therapeutic services, and ensures the continued availability of specialized and culturally responsive YRTC services necessary to meet the mission requirements of the Portland Area IHS.

The Government recognizes its continuing responsibility to promote competition to the maximum extent practicable. Accordingly, the Government will continue to conduct market research during the period of performance to identify additional qualified and responsible sources and determine whether the circumstances supporting the current limitation on competition continue to exist. Prior to exercising Option Period II, the Contracting Officer will reevaluate the marketplace and acquisition strategy to determine whether additional capable sources have become available and whether the restriction on competition can be reduced or eliminated while maintaining continuity of essential YRTC patient care services.

8. Procurement History:

Beginning in early 2015, the nine (9) Tribes, in coordination with the State of Oregon, Portland Area Indian Health Service (IHS), and other key stakeholders, undertook substantial efforts to identify an appropriate facility and service provider capable of delivering Youth Regional Treatment Center (YRTC) services to eligible American Indian and Alaska Native (AI/AN) youth.

Following extensive coordination, planning, and evaluation of available resources, the nine (9) Tribes, NARA NW, and the Portland Area IHS Office of Clinical Support determined that the Native American Rehabilitation Association of the Northwest (NARA NW) was a viable provider capable of meeting the program’s specialized residential treatment requirements. This collaborative effort established the foundation for NARA NW’s continued delivery of YRTC services within the Portland Area service region.

Contract No. HHSI248201500012C was subsequently awarded to NARA NW on September 18, 2015, with a period of performance from September 28, 2015, through September 27, 2020, and a total value, including options, of $5,327,492.00. The acquisition was awarded on a sole-source basis pursuant to FAR 6.302-5(a)(2)(i). Following completion of the 2015 contract, Purchase Order No. 75H71320P00155 was awarded to NARA NW on September 10, 2020, with a total value, including all options, of $7,626,921.50. The acquisition was also awarded on a sole-source basis pursuant to FAR Subpart 13.501.

The procurement history demonstrates that NARA NW has continuously supported this specialized YRTC requirement since 2015 and has established the residential treatment infrastructure, clinical services, culturally responsive treatment program, and operational relationships necessary to support eligible AI/AN youth. When considered with the Government’s current market research, Sources Sought results, and capability review, this history provides additional context regarding the limited availability of sources that have demonstrated the capability to perform the complete YRTC requirement. The current acquisition strategy is based on the Government’s present requirements and current market research and is not based solely on NARA NW’s incumbent status or prior sole-source awards.

9. Additional Information or Other Facts:

NARA NW is the only source identified through the Government's market research as capable of providing the complete services required by the PWS within the required geographic service area. Award to NARA NW is not expected to result in substantial duplication of costs to the Government because the requirement represents recurring, direct patient care services that must continue to be available to eligible AI/AN youth and their families.

The requirement is highly specialized and involves substantially more than the provision of general behavioral health services or healthcare staffing. Successful performance requires an established residential treatment environment capable of providing comprehensive behavioral health and substance use disorder treatment to adolescents while incorporating the culturally responsive services and program components required by the IHS YRTC model.

NARA NW is one of the 13 YRTCs supported through the IHS YRTC Program and is the YRTC identified within Oregon and the Portland Area service region. Its location and established treatment capability provide eligible AI/AN youth access to specialized residential treatment within their region while supporting continuity of care, family involvement, culturally appropriate treatment, and coordination of recovery and aftercare services.

The Government's market research, including the evaluation of responses to the Sources Sought Notice, did not identify another vendor that demonstrated the facilities, clinical resources, specialized experience, cultural treatment model, and overall organizational capability necessary to satisfy the Government's complete requirement.

Accordingly, based on the information presently available to the Government, NARA NW is the only responsible source identified as capable of satisfying the Government's minimum requirements without compromising the required scope, quality, continuity, accessibility, or culturally responsive nature of the services provided to eligible AI/AN youth and their families.

10. Technical or Requirements Program Management 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.

CAI MEMORY…