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FOR OFFICIAL USE ONLY - Source Selection Information – See FAR 2.101 and 3.104

JUSTIFICATION AND APPROVAL (J&A) TEMPLATE

for

Sole-Source (Including Brand-Name) Acquisitions of Commercial Items Conducted Pursuant to FAR Subpart 13.5

J&A Tracking No. 19-0150

1. Identification of the agency and contracting activity: Defense Health Agency (DHA), Professional Services Contracting Division, 7700 Arlington Blvd, Falls Church, Virginia, 22042.

2. Nature and/or Description of Action being approved: Approval is being requested under an individual justification for award of a Firm Fixed Price sole source order to System Improvements, Inc., for training services and software annual maintenance in support of the Joint Patient Safety Program as a follow-on contract.

3. Description of Supplies/Services: The Joint Patient Safety Program requires 3 additional years of use of TapRooT methodology including training, annual software license maintenance fees, course materials, Government instructor certification, and subject matter expert advisory services. Anticipated total period of performance is September 30th, 2019, to September 29th, 2022, including a base year and 2 option years. Estimated value of this contract is , including option periods. The contract base period will be funded using FY 19 Operations and Maintenance (O&M) funds.

4. Statutory Authority Cited permitting other than full and open competition: Acquisition of commercial item(s) conducted pursuant to FAR Subpart 13.5 in accordance with 41 U.S.C.

1901 Simplified Acquisition Procedures.

5. Rationale Justifying Use of the Statutory Authority Cited: Rationale Justifying Use of the Statutory Authority Cited: In 2003, TRICARE Management Activity, which later reorganized into the Defense Health Agency, purchased a site license for use of TapRooT® software at all Military Treatment Facilities (MTF) and clinics to conduct Comprehensive Systematic Analysis (CSA), specifically using Root Cause Analysis (RCA) methodology, for patient safety events and other risk evaluation. The TapRooT methodology—including software maintenance, manuals and instructor certifications—is exclusively available from System Improvements, Inc.

The agency is currently planning an expansion of the Joint Patient Safety Reporting (JPSR) system in a combined effort with the Veteran’s Health Administration (VHA) National Center for Patient Safety (NCPS). This expansion will include migration to a secure cloud environment and addition of modules for investigations, enterprise risk management and adverse actions.

This presents an opportunity to replace TapRooT and Joint Centralized Credentials Quality Assurance System risk management and adverse actions capabilities with a single system to support overall Clinical Quality Management. The contract awarded under this justification would allow the necessary timeframe to move from a legacy standalone application to a JSPR system that meets multiple needs for integration of patient safety data.

Were the Agency to seek a different capability for RCA, prior to expansion of the JPSR system, there is no methodology interchangeable with TapRooT. All such services typically align to a specific industry, type of activity, or type of human error, and also use varied sets of cause codes or other taxonomies to organize data input and reports. Over a period of years, the Agency developed procedures and worked with System Improvements, Inc., to tailor training for consistent use of the TapRooT methodology across the Military Health System. A change of RCA methodology at this point would initiate a transition of similar scope and duration, including 9,000 hours of training for facilitators drawn from 450 locations, only to restart upon release of the JSPR system expansion.

6. Efforts to Obtain Competition: On the completion of purchase order HT0011-13-P-0024 for TapRooT® services, the contracting officer tasked the requiring activity to present a plan for future RCA capability, including identification of competitive opportunities. Contract HT001118C0033 for 12 months of performance, continued services until this plan could be prepared. In that time, the DHA Deputy Assistant Director, Information Operations, (DAD- IO) committed to migration of the JPSR system to a cloud environment, enabling the addition of integrated modules for RCA and other capabilities. The JPSR system is based on Datix IQ, a proprietary commercial-off-the-shelf product. While the migration does not present a competitive opportunity for the JPSR system core application, DAD-IO intends to compete the integration effort for new capabilities.

7. Determination that Anticipated Cost to the Government will be Fair and Reasonable:

The estimated price is based on an Independent Government Cost Estimate (IGCE) using the labor categories and rates under which services were provided on previous award HT0011-13- P-0024 and current award HT001118C0033. Prices and rates on these instruments were determined to be fair and reasonable at the time of award. The contractor’s proposal will be evaluated against the IGCE.

8. Market Research: On April 23, 2019, the Agency posted RFI HT0011-19-RFI-0046 titled Root Cause Analysis Methodology and Tools for Patient Safety to Federal Business Opportunities (FBO) with a closing date of April 30, 2019. Three companies responded:

Press Ganey Associates, Inc.; Verge Health, LLC; and System Improvements, Inc.

(Incumbent). Reviewers found that the Press Ganey Associates, Inc., and Verge Health, LLC, applications would not be suitable replacements for TapRooT as both would require network or internet connections. This would necessitate lengthy cybersecurity certifications, in addition to training and procedure development, before they could be used to store or transmit sensitive unclassified Government information, including Protected Health Information.

The agency also conducted web and internet searches, identifying eleven other commercial providers and one Government source for Root Cause Analysis tools. The commercial products include Reason9, Visual Paradigm, Seebo, Intelex, Cause Mapping by ThinkReliability, EHS Insight by StarTex Software, LLC, RL6:RootCause by RL Solutions, Inc., PROACT by Reliability Center, XFRACAS by Reliasoft, Pathmaker by SkyMark, and CauseLink by Solologic. National Aeronautics and Space Administration additionally provides their Root Cause Analysis Tool at no cost to government agencies and government contractors. Each applies different methodologies and so are not interchangeable with TapRooT.

9. Other Facts: Failure to award this action would have an immediate impact on the Joint Patient Safety Program. For safer, reliable care, the Military Health System (MHS) utilizes root cause analysis investigation tools on a routine basis in order to understand and learn from both near-miss and adverse events.

10. Interested Sources: DHA received responses from Press Ganey Associates, Inc., Verge Health, LLC, and System Improvements, LLC, to the RFI addressed paragraph 8, above.

11. Actions to overcome barriers: The contracting officer reviewed the justification for the previous award and determined that the requiring activity met the actions to overcome barriers.

The requiring activity provided a plan, including additional market research, to reach an end other than competitive procurement of TapRooT. The agency intends to consolidate CSA using RCA, along with other capabilities, into the expanded JSPR within the next 3 years. A competitive award of a new RCA methodology is not in the Agency’s interests owing to the time required to train facilitators in use of a different tool and to develop new procedures for consistent implementation across the MHS. While the JSPR is based on proprietary software available from only one source, DAD-IO intends to compete the integration effort to incorporate new capabilities in a secure cloud environment.

COORDINATION:

12. Technical/Functional Representative: I certify that the information provided in this justification, is accurate and complete to the best of my knowledge and belief.

13. Requirements Certification: I certify that the information provided in this justification, is accurate and complete to the best of my knowledge and belief.

14. Fair and Reasonable Cost Determination: The estimated price is based on an Independent Government Cost Estimate (IGCE) using the labor categories and rates under which services were provided on previous award HT0011-13-P-0024 and current award HT001118C0033.

Prices and rates on these instruments were determined to be fair and reasonable at the time of award. The contractor’s proposal will be evaluated against the IGCE. Certified cost and pricing data are not required as the services to be procured meet the definition of commercial items. I have determined that the anticipated cost to the Government for this contract action is fair and reasonable.

Contracting Officer

Date

15. Legal Review: I have reviewed this justification and have found it to be legally sufficient.

APPROVAL:

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