InterSystems FY26 JA 1_Redacted.pdf

CONTROL NUMBER VA-26-00003659

JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY

1. Contracting Activity: Department of Veterans Affairs (VA) Office of Procurement, Acquisition, and Logistics Technology Acquisition Center 23 Christopher Way Eatontown, NJ 07724

2. Description of Action: The proposed action is for a firm-fixed-price (FFP) delivery order to be issued under the National Aeronautics and Space Administration (NASA) Solutions for Enterprise Wide Procurement (SEWP) V Government-Wide Acquisition Contract (GWAC) for the procurement of Software Updates and Technical Assistance (SUTA) for brand name InterSystems Interoperable, Reliable, Intuitive, Scalable (IRIS) Software, InterSystems HealthShare Health Connect Software, InterSystems HealthShare Heath Information Exchange Software, HealthShare Health Insight, InterSystems Action Engine, and IRIS - Advanced Server.

3. Description of the Supplies or Services:

VA Office of Information and Technology (OIT), Product Delivery Service (PDS) Health Platform Services has a requirement for SUTA for brand name InterSystems unlimited use, perpetual enterprise license products in VA, which are InterSystems IRIS Software, InterSystems HealthShare Health Connect Software, InterSystems HealthShare Heath Information Exchange Software, InterSystems HealthShare Health Insight, InterSystems Action Engine, and InterSystems IRIS Advanced Server software. VA is purchasing SUTA support for the aforementioned InterSystems products. VA has purchased SUTA through an enterprise support model as this allows VA to scale instantly to support increasing utilization. All software shall be delivered via a VA-dedicated, contractor-provided, file transfer protocol site. Veterans Health Information Systems and Technology Architecture (VistA) health record resides on a database operating system and application platform called InterSystems IRIS. This system is required to be maintained as VA transitions to the Electronic Health Record Modernization (EHRM) solution as it houses Veteran health data and has integrations with VistA and VistA-related medical applications.

This action will also include optional tasks for Technical Support Services (up to 10 instances) which will be for integration and configuration technical services supporting

VA.

Electronic Health Record (EHR) database as VA transitions to a new EHR.

The period of performance shall be a base period of six months followed by nine six-month option periods and five optional tasks.

Control Number VA-26-00003659

4. Statutory Authority: Pursuant to Federal Acquisition Regulation (FAR) 16.505(a)(4), the following brand name requirement is being justified and approved as an exception to fair opportunity under the statutory authority of Section 41 U.S.C. 4106(c)(2) as providing the supplies or services required at the level of quality required because the supplies or services ordered ar

5. Rationale Supporting Use of Authority Cited Above: Based on extensive market research as described in Section 8 of this document, it was determined that limited competition is viable among resellers for the aforementioned brand name lnterSystems IRIS, HealthShare software products, Action Engine, IRIS - Advanced Server and associated maintenance support. This contract extends the SUTA bundle support which only the InterSystems brand can provide which are the engineering sustainment as well as traditional operational support services to the contract. Engineering sustainment includes system monitoring, performance management, health automation, resilience engineering, and security. Traditional operational support services include system administration, change management, interface management, capacity and resource planning, compliance readiness, scaling strategies, reporting, and governance.

VistA is which has been used throughout VA for over three decades and was developed using the Massachusetts General Hospital Utility Multi-Programming System (MUMPS) programming language. VistA consists of nearly 183 integrated software modules for clinical care, financial and other business functions and infrastructure. As the largest integrated health care system in the United States, VA provides care at over 1,380 health care facilities of varying complexity, conducting nearly 130 million patient encounters with more than

9.1 million Veterans per year supported by over 340,000 employees conducting VistA deployments spanning 13 time zones from continental U.S., to the Philippines, Guam, and Puerto Rico on a single electronic healthcare information network.

InterSystems IRIS. Veteran health records serviced by VA reside and are managed on this platform. It is, therefore, deemed a mission-critical platform. The application which operates on this platform is VistA. The requirements above support maintenance of the current infrastructure of the VistA platform and provide the VistA EHR database and runtime environment. The required InterSystems brand name software provides the database platform for storing, securing and retrieving Veteran patient data within this platform. Additionally, VA has committed to and is implementing numerous continuous updates to this platform supporting multiple initiatives including, but not limited to, Financial Management Business Transformation, Healthcare Environment and Logistics Management, EHRM, Veteran Health Information Exchange, VistA Read Only, Community Care and health care interoperability and exchange messaging integration amongst and between VistA instances, VA enterprise systems, and external partners such as Department of Defense, and Oracle Health Millenium.

In order to support the above-named initiatives, an alternative platform would require the products, to syntactically support MUMPS (or a MUMPS-like implementation) to preserve business logic, to handle structure, or provide validation transformation while maintaining interoperability with HL7, FHIR, X12, and all existing HIE connections while meeting all security, compliance, and performance requirements. The InterSystems HealthShare products support current and future VistA Architecture and Platform Development initiatives and replacement activities, specifically allowing for the seamless transfer of Veteran patient data to community care providers outside the VA healthcare network. Additionally, efforts to automate and streamline operations for VistA modernization are in process along with the need to support VHA business innovation initiatives which require integration with VistA using industry standards.

VA entered into a contract with Oracle Health in May 2018 to replace a portion of the existing EHR system as described in the preceding paragraph. Additionally, there are other projects currently underway to replace the administrative modules (including Finance/Billing and Engineering/Inventory) with anticipated completion over the next ten years.

While solution replacements are underway, it is imperative to keep existing VistA systems in a steady state operationally. Additionally, even after full implementation of the EHRM solution, the InterSystems platform would still need to run in tandem to the EHRM solution most specifically, to support Joint Legacy Viewer as well as non-migrated healthcare products/capabilities to keep VA hospitals running. These applications need to continue to run even after EHRM implementation. Migrating VistA's core from InterSystems IRIS to any other vendor presents both opportunities and challenges for VA. A pilot project, covering 10 sites, is estimated to cost $40 million and would require approximately 12 months from the start of the contract to completion. This option per the analysis is the only compatible alternative solution

-engineering to an Enterprise EHR and/or Platform solution supporting data, business logic, and interoperability components for enterprise. Key cost drivers include system development, data migration, integrating existing Health Level 7 (HL7) and Fast Healthcare Interoperability Resources (FHIR) interfaces, acquiring commercial support for any other vendor, and training developers. The primary risks involve potential system downtime during migration, the necessity for additional middleware to support FHIR Application Programming Interfaces (API), and the dependence on a diminishing pool of MUMPS developers while sustaining current EHR capabilities.

For a full production replacement across the entire VA enterprise, the estimated cost rises to $500 million with a minimum execution time of 16-60 months depending on the approach. This comprehensive effort would involve more complex system development, large-scale data migration, extensive interface integration, extensive training, and ongoing support and maintenance. The risks here are substantially higher, including significant operational disruptions, the need for enhanced service delivery models, and added middleware for complete FHIR and Consolidated Clinical

Document Architecture (CCDA) support, potentially hampering current EHRM actions.

A full-scale transition to another vendor would require careful management of internal resources, given the scarce availability of MUMPS developers and engineering expertise supporting both current EHR and EHRM programs. While this offers VA complete control over its EHR system, it also demands a robust modernization strategy and resources to maintain the system effectively. Both options, which are based on comprehensive market research efforts, would impede current EHRM deployment plans.

InterSystems supports all of VistA which is a Hospital Information system and not just an Electronic Health Record system. Though VistA replacement is currently underway, InterSystems functionality will still be required for at least several years after the full implementation of the Oracle solution. The Oracle solution replaces a part of EHR functionality, with functionality remaining in VistA at approximately 40% to 50% from a VistA package/function perspective. While there is a road map to replace some of those packages, there is not a road map to replace InterSystems in its entirety at this point. Further, the Oracle solution requires functionality that InterSystems provides to access patient data, even after full implementation of the Oracle system. Therefore, even as VA modernizes its electronic health record, InterSystems cannot be fully replaced by any system even across a seven-year time period.

The InterSystems platform is built on a foundation that combines advanced data management, interoperability, and analytics capabilities. While detailed proprietary technical specifications are not publicly disclosed by InterSystems, we can discuss its architecture and components based on industry practices and available information.

A. Multi-model Database Engine: At its core, InterSystems IRIS uses a high-performance, multi-model database engine. This engine is designed to efficiently store and retrieve different types of data models such as relational, object-oriented, and key-value data. It leverages sparse data storage techniques, efficient indexing, and optimized query processing to deliver high performance and scalability.

B. Integrated Interoperability: Built into InterSystems platform is a comprehensive set of tools and frameworks for interoperability. This includes support for various data formats (such as XML, JSON), communication protocols (such as REST, SOAP), and messaging standards (such as HL7, FHIR in healthcare). The platform uses an internal messaging bus and adapters to facilitate seamless data exchange and workflow orchestration between disparate systems.

C. Analytics and Machine Learning: For analytics and machine learning, InterSystems platform incorporates an analytics engine that supports Structured Query Language (SQL), multidimensional queries, and business intelligence tools. It also provides integrated support for machine learning through built-in functions, and it can interface with external Machine Language (ML) libraries and frameworks. Data can be analyzed directly within the database, minimizing the need for data movement and duplication.

D. Scalability and High Availability: The platform is designed for horizontal scalability through sharding and vertical scalability with efficient multi-threading and caching mechanisms. High availability is ensured through features like mirroring, shadowing, and automatic failover to provide continuous operation and data protection.

E. Security: Security is a fundamental aspect of InterSystems platform, incorporating encryption (both at rest and in transit), authentication, authorization, and auditing capabilities to protect sensitive data and comply with industry standards and regulations.

F. Global Architectural Foundation: InterSystems platform is built to run on a global scale, supporting multi-language and multi-character set environments. This allows applications built on the platform to be deployed in diverse geographical and regulatory landscapes.

G. Development Environment: The platform includes development tools and APIs used by VA for building and deploying applications. It supports various programming languages such as ObjectScript (a proprietary language), Java, Python, and .NET, allowing developers to work in their preferred languages. Note: Objectscript follows grammatical syntax of MUMPS in support of legacy function.

InterSystems has been developing and refining its database and interoperability technologies for decades, and the platform represents the culmination of this experience, designed to address the complex challenges of modern data-intensive applications. The actual building of such a platform involves deep expertise in computer science, software engineering, data management, and domain-specific knowledge across various industries.

The HealthShare component is a healthcare development and informatics platform that currently is used at VA to aggregate and normalize data from multiple electronic medical record systems and enables the creation of longitudinal patient records. For VHA, InterSystems provides direct value (including but not limited) to delivery of patient care wherever the VA patient is seen, serves as the foundation for immunization reporting, prescription drug monitoring program reporting, adverse event reporting to the Federal Drug Administration Management team and pushes historical patient data from VistA to Oracle Health.

Without HealthShare the current EHRM sites would be unable to get historical Veteran healthcare data from VistA, which could significantly limit providers ability to make fully informed clinical decisions and, therefore, negatively impact patient care.

Finally, only lnterSystems and its authorized resellers can meet VA's needs for updates and services and ensure complete interoperability, compatibility, and continuity of operations. lnterSystems owns the proprietary source code and is the only source able to facilitate all lnterSystems license and service requirements.

lnterSystems has proprietary rights to the software source code for the lnterSystems software licenses requested an extension. until July 30, 2024, at the end of which the RFI yielded two responses submitted by InterSystems authorized resellers, Four Points Technology, a Service-Disabled Veteran Owned Small Business (SDVOSB) and All Points Logistics, LLC (Large Business).

On October 7, 2024 Stellar General Service Administration (GSA) price-list was obtained to determine cost comparisons for software licenses with the resellers responding to the InterSystems RFI - Four Points Technology and All Points Logistics, LLC.

On November 27, 2024 the following information was sought from the resellers:

Products / Quantity / and Groups, made for (License Keys) in the past Fiscal Year 2024 (October 1, 2023 - September 30, 2024).

requirement, the proposed concurrent user capacity of approximately 267K was in question; therefore, on January 22, 2025, a second RFI was posted to NASA SEWP V to better determine whether there were resellers available who could provide SUTA services needed by the VA. The RFI closed on February 2, 2025, and two responses were submitted by InterSystems authorized resellers, Four Points Technology (SDVOSB) and All Points Logistics, LLC (Large Business). The technical experts determined the resellers could meet VA requirements.

Furthermore, market research was conducted on April 15, 2025 on GSA via a third RFI that closed on April 22, 2025 and no responses were received. Then, a fourth RFI was posted on SAM.gov on April 24, 2025 and closed on April 30, 2025 to reach a wider audience. In response to the April 24, 2025 RFI on SAM.gov, the Government received two responses from GSA contract holders SRR International, Inc. (Women-Owned Small Business) and Aurelius Tech & Talent Solutions (SDVOSB). The technical experts determined that the responses received provided irrelevant information that did not address specific requirements, so were not considered. All Points Logistics LLC (Large Business) replied late on April 20, 2025, and their response was considered technically acceptable. No alternative solutions were proposed.

Finally, a fifth RFI posted on NASA SEWP by VA on May 22, 2025, and closed on June 6, 2025, with the addition of technical support services component to the requirements.

VA determined that technical support services are now required due to the current shifting nature of the workforce and the need to add engineering sustainment (health, performance and resilience) as well as traditional operational support services to the contract. Two responses were received from Four Points Technology and All Points technical experts, and it was determined that

Currently, limited competition is expected for this proposed action on NASA SEWP V

GWAC.

Additionally, the Government s technical experts performed additional market research through web-based research, revalidation of previous RFIs, and testing in a sandbox environment during April and May 2025 to consider other similar commercial products. It significant disruption to current operations/requirements, as detailed above.

As detailed above, market research indicates that at least two NASA SEWP V GWAC contract holders are interested and capable of providing the brand name InterSystems software products/services. The Government did not identify two or more small businesses capable of supporting this requirement, and as such, this effort could not be set aside to SDVOSBs, VSOBs, or small businesses. Accordingly, the proposed action will be issued for a FFP delivery order issued to all contract holders in NASA SEWP V GWAC Groups B, C and D.

9. Other Facts: None

Technical/Requirements Certification I certify that the supporting data under my cognizance, which are included in this justification, are accurate and complete to the best of my knowledge and belief.

Fair and Reasonable Cost Determination I hereby determine that the anticipated price to the Government for this contract action will be fair and reasonable based on anticipated competition. Additionally, SAM.gov has already determined the prices on contract to be fair and reasonable. Finally, the successful quote will be compared with the Independent Government Cost Estimate.

Contracting Officer Certification/Approval I certify that this justification is accurate and complete to the best of my knowledge and belief.

Office of General Council (OGC) Review I have reviewed this document and find it legally sufficient, based on the representations set forth in the documents and, if any, attachments. The SPE approval is an independently supported decision not wholly reliant on the legal sufficiency determination.

HCA Concurrence In my role as interim Head of the Contracting Activity, based on the foregoing justification, I hereby concur with the acquisition of SUTA for brand name InterSystems IRIS Software, InterSystems HealthShare Health Connect Software, InterSystems HealthShare Heath Information Exchange Software, InterSystems HealthShare Health Insight, InterSystems Action Engine, and InterSystems IRIS Advanced Server, pursuant to the authority cited in Section 4 above, subject to availability of funds, and provided that the services herein described have otherwise been authorized for acquisition.

Senior Procurement Executive Approval In my role as Agency Senior Procurement Executive, based on the foregoing justification, I hereby approve the acquisition of SUTA for brand name InterSystems IRIS Software, InterSystems HealthShare Health Connect Software, InterSystems HealthShare Heath Information Exchange Software, InterSystems HealthShare Health Insight, InterSystems Action Engine, and InterSystems IRIS Advanced Server on an other than fair opportunity basis pursuant to the authority cited in Section 4 above, subject to availability of funds, and provided that the property and services herein described have otherwise been authorized for acquisition.