ILER FY25-0148 LSJ_Redacted.pdf

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Control Number: FY25-0148

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Source Selection Information - See FAR 2.101 and 3.104-4

OCT 2024

Limited Sources Justification (LSJ) Federal Acquisition Regulation (FAR) Part 8.405-6(c)

1. Identification of the Agency and Contracting Activity:

Defense Health Agency Contracting Activity (DHACA), Professional Services Contracting Division, plans to place an order, on a limited source basis.

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

This is an individual LSJ, under the authority of the Multiple Schedule Program, 41 U.S.C. 152(3) Competitive Procedures in accordance with FAR 8.405-6. The government intends to award a Firm Fixed Price (FFP) order against a General Services Administration (GSA) Federal Supply Schedule (FSS) contract to Concept Plus, LLC for the continued sustainment and development of Individual Longitudinal Exposure Record (ILER).

3. Description of Supplies or Services and Estimated Value:

The DoD has identified an immediate and urgent requirement to the continued need to improve ILER�s effectiveness, enable further integration with Electronic Health Records, and address brain health risks resulting from Blast Over Pressure (BOP) exposures.

ILER represents the complete and authoritative data source for all Occupational and Environmental Health Surveillance (OEHS) data to include hazardous Environmental Health Surveillance (OEH) exposures to Service members in theater, as well as to critical non-theater OEH exposures that impact on DoD and Veterans Affairs (VA) medical care and disabilities, including ergonomics, hazardous noise, Occupational Safety and Health Administration substance specific standards, etc. ILER is a highly specialized, unique, complex, multi-component system that consists of multiple point-to-point interfaces, complex bidirectional data exchanges with internal and external systems, a robust data warehouse, and a customizable application layer to support over 23,000 direct users and 65,000 indirect users to support toxic exposure clinical examinations, occupational and environmental health surveillance (OEHS), public health surveillance, health risk management, operational risk assessments, force health readiness and mission planning, disability determinations, claims adjudications, multiple legislative requirements, and as of 01 October 2024 serves as the Congressional mandated Airborne Hazards and Open Burn Pit Registry.

This action also addresses the urgent need to continue optimizing ILER�s effectiveness and integration with joint electronic health records, manage brain health risks associated with Blast Overpressure (BOP), in alignment with DoD policies and directives, and support legislative

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Source Selection Information - See FAR 2.101 and 3.104-4

OCT 2024

4. Authority Cited:

FAR 8.405-6(a)(1)(i)(B): Only one source is capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialize.

5. Rationale Justifying Use of Authority Cited:

a. ILER is the established systems for tracking occupational and environmental health exposures across the DoD. Its existing framework is uniquely suited to meet the specific legislative requirements, under aggressive timeline constraints set by Assistant Secretary of Defense for Health Affairs, without duplicating efforts or risking delays.

The ILER requirement was competed as a Small Business Set-Aside and won by with contract HT0015-19-F-0160. has direct institutional knowledge, technical expertise, and proprietary understanding of ILER, the legislative requirements, and supporting interfaces making them the only vendor capable of delivering the necessary functionality efficiently and without risks. Only the incumbent can meet this requirement without unacceptable costly, disruptive, and potential destructive impacts. While other vendors may possess the experience to provide the services and technical support to operate the ILER requirements, the tasks are too complex and require a sufficient transition-in period the government does not have to overcome the steep learning curve incurred with a new vendor.

b. Transitioning to a new contractor unfamiliar with ILER, coupled with ninety (90) day average onboarding time, would introduce critical knowledge gaps, and schedule delays resulting in a failure to deliver time-sensitive solutions required by DoD policy and law.

Furthermore, the new BOP monitoring functionalities actively being fielded by DoD service components must integrate seamlessly within ILER �s infrastructure to maintain accurate service-related exposure reporting being used to support ongoing Warfighter Brain Health studies by the National Academies of Sciences, Engineering, and Medicine and Traumatic Brain Injury Center of Excellence. ability to deliver timely and compliant enhancements makes them the best choice sole provider capable of meeting these requirements without compromising current studies.

The PACT Act, Section 803, requires The Secretary of Defense to provide Service Members and Veterans access to ILER as well as provide a means to update their records as necessary to reflect toxic exposure events during their time in service. The Joint Executive Committee

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Source Selection Information - See FAR 2.101 and 3.104-4

OCT 2024

has incorporated the ability to access and update ILER, into the Joint Strategic Plan. Any delay jeopardizes the ability to meet this objective by 31 DEC 2025.

The DoD has mandated immediate compliance with BOP risk management policies to protect service members from potentially irreversible brain injuries. Any delay jeopardizes military readiness and personnel well-being. The DoD Instruction 6055.01 and subsequent policies mandate immediate tracking and mitigation of BOP exposures. Noncompliance would compromise service members� safety and risk legal and operational consequences for the DoD.

The NDAA requirements for ILER integration must be met to ensure service members and veterans have access to exposure data for healthcare and disability evaluations. Any delays would severely impact DoD�s ability to meet legal, medical, and operational commitments, creating unnecessary risks for exposed personnel.

6. Market Research:

Market research was conducted between 14 January 2025 and 12 February 2025 by reviewing a combination of online searches, vendor capability assessments, and service reviews of vendors listed on the GSA Advantage and eLibrary platforms. Further market insight was gained by analyzing historical and current data of same/similar requirements and current market conditions.

Other vendors have the resources required per the requirements of this contract but cannot overcome the complex learning curve require to award the follow-on bridge contract in sufficient time. Therefore, it is in the best interest to award this follow-on bridge contract to the incumbent.

has provided satisfactory services throughout the term of the current contract and can provide continued services for the tasks outlined in the Performance Work Statement of the contract. and their direct institutional knowledge, technical expertise, and proprietary understanding of ILER, the legislative requirements, and supporting interfaces makes them the only vendor capable of delivering the necessary functionality efficiently and without risks in the mandatory delivery time frame.

The learning curve to understand the applications and provide adequate support in the short term of this bridge contract makes it highly unlikely that any other company could do so without presenting unacceptable risk to the application and its users. Soliciting this requirement for full and open competition would not be in the best interest of the government since the tasks being performed on this contract are highly complex and unique. Additionally, this effort will be awarded as part of the next iteration of the Surveillance & Readiness Sustainment and Development Contract however, that acquisition and contract strategy approach is still pending.

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Source Selection Information - See FAR 2.101 and 3.104-4

OCT 2024

Awarding this bridge contract to provides the best possible value and lowest risk to the government.

Other Facts:

Procurement history.

Is this a new requirement? No

If 7.a.(1) is No, was the action just prior to this one competed? Yes, this action was previously competed and awarded on a best value basis as FFP contract, HT001519F0160.

If 7.a.(2) is Yes, what has changed where this action cannot be competed? Due to the late submission of the requirements package, the action could not be competed in time. As a result, there was an unintended break in service. A competed follow-on contract is now planned with an estimated award date of 1 May 2026.

Additional Information. This effort was be awarded as part of the next iteration of the Surveillance & Readiness Sustainment and Development Contract; however, that acquisition and contract strategy approach is still pending.

Actions to Remove or Overcome any Barrier to Competition:

This requirement was not competed due to a late submission of the requirements package, triggering a need for a follow-on sole source bridge contract. To avoid limiting competition in the future, the PMO will engage early with stakeholders across the board � technical, programmatic, legal, and contracting � to align on requirements per required milestones to make a competed contract award. A recompete contract for this requirement is expected to be awarded 1 May 2026.

9. Technical Certification:

I certify the supporting data under my cognizance, which are included in the justification, are accurate and complete to the best of my knowledge and belief.

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Source Selection Information - See FAR 2.101 and 3.104-4

OCT 2024

10. Requirements Certification:

I certify the supporting data under my cognizance, which are included in the justification, are accurate and complete to the best of my knowledge and belief.

11. Best Value Determination:

Consistent with FAR 8.404(d) Pricing and supplemental Department of Defense requirements, I hereby determine the action described herein represents the best value to the Government.

Basis for Determination: The Contracting Officer will determine that the anticipated cost of the order to the Government will be fair and reasonable through analysis of same/similar services, information of GSA Multiple Award Schedule price listings, historical prices paid on contracts for the same or similar items/services, the independent Government Cost Estimate, open market cost, and vendor�s price proposals.

12. Legal Review:

I have reviewed this justification and have found it to be legally sufficient.

OCT 2024

13. Contracting Officer Certification:

I certify this justification pursuant to the authority of FAR 8.405-6(a)(1)(i)(B) is accurate and complete to the best of my knowledge and belief.

Review

I have reviewed this justification and find it adequate to support limited sources.

Approval

Based on the foregoing justification, I hereby approve limiting sources in the acquisition of ILER Support Services estimated valued at $4,291,267.91pursuant to the authority of FAR 8.405- 6(a)(1)(i)(B):, subject to availability of funds, and provided that the services and property herein described have otherwise been authorized for acquisition.

Source Selection Information - See FAR 2.101 and 3.104-4