J A_Redacted.pdf

HNC Control No.:

Procurement Sensitive

FOR OFFICIAL USE ONLY - IAW FAR 3.104

Justification Review Document

For Other Than Full and Open Competition

T-Systems EV Emergency Department Information Systems

San Antonio Military Medical Center (SAMMC) at Brooke Army Medical Center (BAMC)

Fort Belvoir Community Hospital (FBCH) William Beaumont Army Medical Center (WBAMC) Carl R. Darnell Army Medical Center (CRDAMC)

Authority: 10 United States Code 2304(c)(2) as implemented in Federal Acquisition Regulation 6.302-2(a)(2), When the agency’s need for the supplies or services is of such an unusual and compelling urgency that the Government would be seriously injured unless the agency is permitted to limit the number of sources from which it solicits bids or proposals, full and open competition need not be provided for.

Amount:

Prepared by:

Contracting Officer:

Technical Representative:

Requirements Representative:

Reviews: I have reviewed this justification and find it adequate to support other than full and open competition.

Program Manager:

Legal Counsel:

PARC-WIN CONCURRENCE:

HQ USACE Small Business:

HQ USACE Technical:

Special Advocate for Competition:

Justification and Approval

Other Than Full and Open Competition

1. CONTRACTING ACTIVITY: United States Army Corps of Engineers, Engineering and Support Center (CEHNC), 4820 University Square, Huntsville, AL 35816-1822.

2. DESCRIPTION OF ACTION: This after-the-fact unusual and compelling urgency justification and approval is for the procurement of four individual Firm Fixed Price (FFP) commercial contracts for T-Systems EV Emergency Department Information Systems (EDIS) using FY16 Defense Health Agency (DHA) Operations and Maintenance funds. (See Attachment 1 – Timeline MFR).

3. DESCRIPTION OF SUPPLIES OR SERVICES: T-Systems EV, an Emergency Department Information System, is an electronic documentation system which has decision matrices (Clinical Decision Support (CDS)) embedded that correspond to symptoms presented, facilitating evaluation and diagnosis, and provides clinical protocols, information on disease outbreaks and regulatory changes. The EDIS interfaces with Electronic Health Records (EHR) software systems.

Estimated Dollar Value:

4. AUTHORITY CITED: 10 United States Code 2304(c)(2) as implemented in Federal Acquisition Regulation 6.302-2(a)(2), When the agency’s need for the supplies or services is of such an unusual and compelling urgency that the Government would be seriously injured unless the agency is permitted to limit the number of sources from which it solicits bids or proposals, full and open competition need not be provided for.

5. REASON FOR AUTHORITY CITED: U.S. Army Medical Command (MEDCOM) has identified that patient safety is endangered with the current system of taking handwritten charting and notes, transcribing, and scanning them into EHR systems.

Patients treated based on records that were incorrectly transcribed or have other patients’ information erroneously scanned into their medical file result in sentinel events. A Sentinel Event is defined by The Joint Commission (TJC) as any unanticipated event in a healthcare setting resulting in death or serious physical or psychological injury to a patient or patients, not related to the natural course of the patient's illness. Sentinel events specifically include loss of a limb or gross motor function, and any event for which a recurrence would carry a risk of a serious adverse outcome. Due to ongoing litigation and Health Insurance Portability and Accountability Act (HIPPA) restraints, antidotal sentinel event information was provided verbally.

Military hospitals without EDIS have sentinel events occurring that have resulted in amputations, dangerous medication interactions, and deaths. As a result, MEDCOM requires all Emergency Departments (ED) to switch to an interim EDIS system by 01

Fort Belvoir Community Hospital William Beaumont Army Medical Center Brooke Army Medical Center Carl R Darnell Army Medical Center

TOTAL:

October 2016.

In 2015, MEDCOM banned all procurement of interim EDISs prior to the deployment of Medical Health Systems GENESIS, preferring an enterprise interim solution. The ban was rescinded 01 July 2016 as a single solution EDIS could not be identified which was compatible with each facilities’ unique IT architecture, had a certificate of net worthiness (CoN), and that was Defense Information Assurance Certification and Accreditation Process (DIACAP) or Risk Management Framework (RMF) compliant. Without an EDIS, military hospitals are left operating at significant risk of malpractice. (See Attachment 2 - EDIS Statements of Need)

The 1 Jul 2016 revocation of the ban left military hospitals to their own devices, attempting to conduct their own market research, draft course of analysis papers, gain required approvals, identify funds, prepare procurement packages and lastly, find a contracting agency willing to accept work late in the fourth quarter. The four hospitals which submitted requirement packages to USACE Engineering and Support Center Huntsville (HNC) requesting the T-Systems EV, Brooke Army Medical Center (BAMC) needs the system in place by 15 September 2016. BAMC provides all levels of Emergency Medicine Trauma services to 22 counties in south Texas and is one of only 31 hospitals in the United States that holds both Level I Trauma Certification and accreditation from the American Burn Association. BAMC operates the only Department of Defense Burn Center (the Army Burn Center), as well as the premier amputee treatment center (Center for the Intrepid). BAMC also serves as the premier Medical Readiness Training platform for both the Army and the Air Force, supporting medical care throughout the globe as military providers continue to deploy to combat zones. All of these concurrent missions make the BAMC Emergency Department a major intake point for complex and critical trauma, burn, and amputee patients transferred from both DoD and civilian facilities, in addition to the expected emergency department work-load found in a major medical center located in the heart of 7th largest city in the United States. In order to ensure that patient safety is optimized, and to reduce further risk of malpractice, the T-Systems EV must be delivered and operational by 15 September 2016. FBCH, WBAMC and CRDAMC must have the systems installed by 30 September 2016.

6. EFFORTS TO OBTAIN COMPETITION: Prior to the MEDCOM ban on procurement of interim EDIS systems, BAMC had conducted analysis on the EDIS systems available that were compatible with the hospital’s IT infrastructure: T-Systems EV which is compatible with the existing T-Sheets system already installed, and an Essentris EDIS, which is compatible with the existing Essentris EHR system. Testing between the two systems revealed that using Essentris required over four times as many clicks and over two to three times as long to input, depending on the Emergency Department scenario.

T-Systems was also less expensive. (See Attachment 3 - BAMC ED EHR Solution Business Case).

7. ACTIONS TO INCREASE COMPETITION: None. MEDCOM is leading the Defense Health Agency’s initiative to develop Department of Defense (DoD) Military Health System (MHS) electronic health record system called MHS Genesis. Genesis will replace all EHR systems including EDISs. MEDCOM has limited acquisition of Commercial Off The Shelf (COTS) EDISs as an interim measure until GENESIS is fielded. (See Attachment #4 Memorandum Interim EDIS).

8. MARKET RESEARCH: Prior to the MEDCOM ban on procurement of interim EDIS systems in 2015, BAMC independently conducted market research and analysis of COTS EDIS systems available that were compatible with the hospital’s IT infrastructure and met Joint Commission metrics and Clinical Decision Support. The two EDIS software analyzed were T-Systems EV, which is compatible with the existing T-Sheets system already installed, and an Essentris EDIS, which is compatible with the existing Essentris EHR system. In-depth analysis indicates that T-systems is technically superior and less expensive than Essentris. (See Attachment #3 BAMC ED EHR Solution Business Case).

Their analysis is congruent with a Peer60 report “The Future of Emergency Department Information Systems 2015” in which a study of 400 Emergency Departments found that, of the one third that will replace their EDIS systems, 49% will for ease of use and 33% will “adopt our EHR vendor’s EDIS”. (See Attachment 5 “The Future of Emergency Department Information Systems 2015”).

Additional market research was not conducted as this action is exempt from synopsizing per FAR 5.202(a)(2). The proposed contract action is made under the conditions described in 6.302-2 (or, for purchases conducted using simplified acquisition procedures, if unusual and compelling urgency precludes competition to the maximum extent practicable) and the Government would be seriously injured if the agency complies with the time periods specified in 5.203.

9. INTERESTED SOURCES: A Peer60 report “The Future of Emergency Department Information Systems 2015” identified COTS EDIS top competitors in the field are MEDITECH, Epic, Cerner, McKesson, MEDHOST, T-systems, Evident, Allscripts, Healthland, Optum, athenahealth, NextGen. However, not all EDIS software are compatible with existing military hospital IT architecture, have a CoN, and are DIACAP/RMF compliant.

10. OTHER FACTS:

a. Procurement history. None.

11. TECHNICAL CERTIFICATION: “I certify that the supporting data under my cognizance, which is included in the justification, is accurate and complete to the best of my knowledge and belief.”

12. REQUIREMENTS 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”

13. FAIR AND REASONABLE COST DETERMINATION: “I hereby determine that the anticipated cost to the Government for this contract action will be fair and reasonable based on both the IGE and the BAMC ED EHR Solution Business Case.

14. CONTRACTING OFFICER CERTIFICATION: “I certify that this justification is accurate and complete to the best of my knowledge and belief”

APPROVAL

Based on the foregoing justification, I hereby approve the procurement of T-Systems EV Emergency Department Information System on an other than full and open competition basis pursuant to the authority of 10 United States Code 2304(c)(2) Federal Acquisition Regulation 6.302-2(a)(2) Urgent and Compelling, subject to availability of funds, and provided that the services and property herein described have otherwise been authorized for acquisition.