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

Justification and Approval (J&A) for Federal Acquisition Regulation (FAR) Subpart 6.3

Other Than Full and Open Competition Title: Pharmacy Data Transaction Service

J&A Number:

Created By: Additional POCs:

Enter users separated with semicolons.

Users entered in this field will be copied on notification emails as well as have access to view and edit this J&A.

1. Identification of the agency and contracting activity:

Specify the contracting activity responsible for this action.

Managed Care Contracting Division

The Defense Health Agency (DHA), Managed Care Contracting Division (MC-CD) Aurora, Colorado.

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

State whether approval is being requested for a new contract or bridge action, and whether it is an individual or class justification.

(see DHA PGI 206.3) new contract modification to an existing contract

Individual

Class

Approval is requested under an individual justification for a bridge action, resulting in an award of a Firm Fixed Price (FFP) modification to extend the period of performance for 21 months or until March 31, 2023 for the CSRA LLC, Pharmacy Data Transaction Service (PDTS) task order for the management of TRICARE pharmacy transactions data repository. This bridge action will continue services supported under task order The original task order was competitively awarded on July 25, 2014, with a current expiration date of June 30, 2021 (which includes the base, all options, 6-months extension of services option, 12-months 1st bridge action and 8-months 2nd bridge action). This extension action is required to avoid a lapse in service o complete the Pharmacy Data Warehouse (PDW) build up, and time necessary to re-complete a follow-on requirement.

In 2019, the awarded a contract action for the migration and build of a new PDW to which was intended to replace the legacy, Contractor Owned Contractor Operated (COCO) Pharmacy Data Transaction Service (PDTS) program. was to design, develop and implement an Informatica Common Service (ICS) solution for the DHA as a Government Owned Government Operated (GOGO) version of the PDW, hosted in Defense Information Systems Agency (DISA's) capacity services environment. The development of the PDW replacement product was dependent upon the successful design, development, accreditation and deployment of the ICS solution. In September 2020, task order ended with neither ICS nor PDW efforts completed and no suitable path forward for transition or continuation of these efforts.

The legacy PDTS task order was extended in order to maintain the COCO pharmacy data warehouse and continue the PDW migration and build efforts. Separately, the DHA's Solution Delivery Division (SDD) continued efforts to support the PDW build.

Due to the urgent and abbreviated timelines associated with the end of task order coinciding with PDTS and PDW program Period of Performance (PoP) ending, there was little opportunity to obtain and transition knowledge from As a result, key assumptions about the progress were inaccurate and the requirements provided to CSRA for continuation of the PDW build effort were not complete.

Pharmacy Operations Division (POD) was notified of additional requirements between February-March 2021 to include the use of Informatica for coding translation. Informatica, the established Extract Transfer Load (ETL) tool, was not available to the SCRA's development team for several months after extension of the contract. DHA J6 requested new requirements for Informatica access in April 2021. This added an estimated 90 to 150 calendar days to the completion schedule. In addition, DHA J6 requested a new requirement for a full risk management framework (RMF) assessment and authorization (A&A) to obtain the Authority to Operate (ATO), resulting in an updated program schedule extending into January 2022.

This bridge action will provide 21 months (until March 31, 2023) of continued support beyond the current period of performance of the PDTS Data Warehouse to enable the requirement to be recompeted and transitioned out to a potential new awardee. The Government anticipates award of the follow-on requirement by 2Q22. Because of the volume of data required to transition, the requirements for systems access, and the coordination with the Government and outgoing contractor, this 21 month is inclusive of the12 months needed to transfer responsibilities following contract award.

Failure to extend the PDTS task order will create a disruption in services and patient safety issues affecting all TRICARE beneficiaries using the DHA Pharmacy Benefit by not being able to provide crucial commercial drug data to Government agencies in regards to a beneficiaries drug contradiction information, disproportionate drug use, and/or excessive prescriptions written by providers. Additionally, Military Health System (MHS) staff, the commercial pharmacy industry, DHA Program Integrity (PI), and Government agencies external to DHA will be negatively impacted because they rely on the data provided from the pharmacy data warehouse for analysis relating to Congressional reports involving pharmacoeconomics, utilization, trending, fraud waste and abuse, and, outcomes research.

Program Risks:

Inability for DHA to continue the congressionally mandated Federal Pricing Refund Program which has recovered in refunds to date;

Reduced ability for DHA to provide MHS Readiness tools and data used by the Military Treatment Facilities (MTFs) and deploying units;

Reduced ability for DHA to provide analysis relating to DHA Program Integrity investigations and Congressional reports on pharmacoeconomics, utilization, trending, Opioid utilization, fraud waste and abuse, as well as outcomes research; and Reduced ability for DHA to provide daily retail COVID-19 immunization data for the DHA Director and the Secretary of Defense.

3. Description of Supplies/ Services:

Describe the supplies and services. Provide the period of performance for the base and all options, and the estimated value by base, option, and the total, including any extension of services, as applicable. Include type of contract (e.g., Fixed Price or Cost Reimbursement), type of funds to be used, (Department of Defense, Veterans Affairs, Joint Incentive Fund-No Year (DoD/VA JIF-NY), Operations & Maintenance (O&M), Research, Development, Test & Evaluation (RDT&E), Other Procurement (OP), or Revolving Funds-NY) and, when applicable, the estimated share and ceiling arrangements, and fee and/or profit. If the requirement is for a repair part, address whether or not it has been screened. If the repair part has been screened, provide the Acquisition Method Code (AMC) and Acquisition Method Suffix Code (AMSC). Provide the approximate date the technical data package will be available.

Description of Supplies and Services:

This bridge action will provide 21 months (until March 31, 2023) of continued support beyond the current period of performance of the PDTS Data Warehouse to enable the requirement to be recompeted and transitioned out to a potential new awardee. The Government anticipates award of the follow-on requirement by 2Q22. Because of the volume of data required to transition, the requirements for systems access, and the coordination with the Government and outgoing contractor, this 21 month is inclusive of the 12 months needed to transfer responsibilities following contract award. The PDTS Data Warehouse is a centralized data repository that allows for processing of a common patient medication profile of beneficiaries regardless of the point of service utilized. The current price of PDTS service is The total estimated price of 21 months extension is Fiscal Year 2021-23 Department of Defense (DoD) Operation and Maintenance (O&M) programed funds will be used to cover this bridge action.

TOTAL Contract Value

POP: From 7/1/2021 to 3/31/2023

Estimated Value

BASE

POP: From to

Estimated Value

Type of Contract (Primary):

FAR 16.202 Firm-Fixed-Price OPTIONS - Check this box if there are options

Funding Type: Extension of Services - Check this box if there is an extension clause

DHA HEALTH.MIL TRICARE DHHQ

Administrator

Health Affairs DHA Health Care Administration Management/CAE Combat Support Locations Services MHS Transformation Transition PMO

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Operations & Maintenance (O&M)

4. Statutory and Regulatory Authority Permitting Other Than Full and Open Competition (see FAR 6.302), or the Specification of the Statutory and Regulatory Provision Providing Exception to 8(a) Program Competitive Requirements (see FAR 19.805-1):

10 U.S.C. 2304(c)(1) 6.302-1 -- Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements

5. Rationale Justifying Use of the Statutory Authority Cited:

Provide sufficient facts and rationale justifying use of the specific authority cited under Item 4 above (See FAR 6.302, FAR 6.303-2, and FAR 19.805-1).

CSRA is the current contractor performing data warehouse services. In accordance with (IAW) FAR 6.302-1(a)(2)(iii)(A-B), services may be deemed to be available only from the original source in the case of follow-on contracts for the continued provision of highly specialized services when it is likely that award to any other source would result in (A) substantial duplication of cost to the Government that is not expected to be recovered through competition or (B) unacceptable delays in fulfilling the agency's requirements. The process of a new competition and contract award to a contractor who is not the incumbent will require a lengthy transition period (12 months or longer) including but not limited to additional stand up and migration and increased management, resulting in duplication of costs to the Government that is not expected to be recovered through competition and cause unacceptable delays. It is in the Government's best interest to continue services with CSRA to not only avoid substantial duplication of efforts and costs and unacceptable delays, but also, to ensure services will continue without disruption until March 2023.

6. Efforts to Obtain Competition: Describe efforts made to ensure that offers are solicited from as many potential sources as is practicable, including whether a notice was or will be publicized as required at FAR Subpart 5.2 and, if not, which exception under 5.202 is applicable to the requirement. Justifications citing the authority at FAR 6.302-1 permitting the use of other than full and open competition, shall include the results of the request for information or sources sought notice posted in accordance with DFARS PGI 206.302-1 (unless the requirement to post has been waived);

and for non-competitive follow-on acquisitions of supplies or services previously awarded on a non-competitive basis, include a copy of the previous justification with the current justification review package to assist the approval authority in determining whether the planned actions to remove any barriers to competition cited on the previous justification were completed.

IAW FAR subparts 6.302-1(d) and 5.201, a notice of intent was posted on the Government point of entry (SAM.gov) on May 5, 2021, notifying the public of the Government's intent to award PDTS bridge action utilizing other than full and open completion with comments due no later than May 19, 2021. One (1) response was received.

The capability statement showed the contractor has extensive experience in data warehousing and cloud solutions. However, it was not clear if the contractor had any experience in pharmacy business management or pharmacy data warehousing functions. Additionally, the core competencies highlighted by the contractor assumed DHA currently has cloud data capabilities to replicate DHA data. DHA does not have the cloud data storage solution at this time. As such, the "plug and play" capability presented by the contractor may not be feasible in the near future. The contractor will not be able to stand up the PDW by 30 June 2021. Based on the Contracting Officer Representative's (COR's) analysis, it is impossible to stand up the COCO solution in less than 30 days and mitigate any disruption of services and will cause unacceptable delays.

7. Determination that Anticipated Cost to the Government will be Fair and Reasonable: Describe how the contracting officer determined or will determine that the anticipated cost to the Government will be fair and reasonable.

IAW FAR 15.404-1(b)(2)(iv), Comparison with Competitive Published Price Lists (from GSA contracts for similar services) is used to determine that the anticipated price of o the Government will be fair and reasonable.

8. Market Research: Describe the extent of the market research conducted and when conducted, method utilized, and results, or, if market research was not conducted, provide the rationale (see FAR Part 10 Techniques for Conducting Market Research). The market research conducted or rationale provided in this section should help support the rationale justifying the use of the Statutory and Regulatory Authority in Section 5 above.

A notice of intent to sole source was posted on May 5, 2021 in an attempt to identify other potential contractors that could provide PDTS services. Based on the rationale provided in section 5 and the information received in section 6, competition and even limited competition for this follow-on bridge action is not feasible. It has the potential to cause unacceptable delays due to the time it will take to procure and award a new contract, which would increase the risk of injury and financial risks by not being able to provide crucial commercial drug data to MHS staff, Industry, DHA Program Integrity (PI), and external Government agencies. It is in the Government's best interest to approve the bridge action J&A as it will minimize the time and administrative costs required to continue services through the interim period until the requirement is re-competed.

9. Other Facts: List any other facts supporting the use of other than full and open competition, such as an explanation as to why technical data packages, specifications, engineering descriptions, statements of work, or purchase descriptions suitable for full and open competition have not been developed or are not available.

PDTS Background: In 2015, DHA POD initiated efforts to consolidate and rationalize contracts that focus on sustaining detailed pharmacy claims information across all points of service (MTF, Retail, Theater and Mail Order) into a consolidated data warehouse. The initial action transferred the adjudication functions of PDTS to the contract. Collaboration with DHA J6 resulted in the migration of the Business Objects reporting capability from PDTS to the enterprise in 2018. Efforts to consolidate like functionality continued into 2019, which include the transfer of the as well as the initiation of PDW transfer to

The work required to migrate the PDW was originally estimated to take 12 months. However, due to the identified delays and contractor change, the project is currently in month 20 with an additional projection of seven (7) months for completion.

10. Interested Sources: Include a listing of the sources, if any, which have expressed, in writing, an interest in the acquisition.

A notice of intent to sole source was posted on May 5, 2021 in an attempt to identify other potential contractors that could provide PDTS Data Warehouse services. One (1) response was received. The capability statements did not demonstrate the company could meet the Government requirements in the limited timeframe provided.

11. Actions to overcome barriers: Describe the actions, if any, the agency may take, or is taking, to remove or overcome any barriers to competition before any subsequent acquisition for the supplies or services required.

The Government intends to re-compete the PDW requirements. As indicated in Section 2 above, several unexpected requirements were implemented during the GOGO PDW build that delayed completion of the project. To mitigate any delays from occurring again during the re-compete and follow-on contract action, POD will coordinate a requirements package with J-6 to address any future additional requirements before the solicitation is released to the public. Based on J-6 input, the POD will either specify the use of Informatica for coding translation or will allow potential contractors to propose alternative solution. The requirement for full RMF A&A to obtain the ATO will not be a part of the re-compete requirement as the follow-on contract action will be for a COCO and as such, ATO is not required.

Coordination & Approval

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.

Name: Title: Program Analyst, COR (Program Manager, Functional Service Manager, etc.)

Approved:

13. Requirements Certification:

I certify that the infiormation provided in this justification is accurate and complete to the best of my knowledge and belief

Name:

J Director (or designee)

Title: Team Lead, POD IIB (Responsible J Director)

J-Directorate Office: HCO

Approved:

14. Fair and Reasonable Cost Determination: Provide the basis for this determination (e.g., describe techniques utilized, or to be utilized, to determine cost/price fair and reasonableness, such as cost analysis, price analysis, audit, should cost, independent Government estimate). As part of this basis, indicate whether certified cost or pricing data will be required or if one of the exceptions in FAR Part 15.403 will apply. Contracting Officer to include the following determination:

I have determined that the anticipated cost to the Government for this contract action is fair and reasonable.

Name: Title: Contracting Officer, Managed Care Contracting Division

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CONTACT US: Web & Mobile Technology PMO | No FEAR Act | Accessibility/Section 508

CONTACT GSC: 800-600-9332 or Visit the Global Service Center site here: https://gsc.health.mil/

Approved:

15. Legal Review:

I have reviewed this justification and have found it to be legally sufficient. (Note: All J&As must be reviewed by Office of General Counsel (OGC)/Legal Review.)

Name: Title: Office of General Counsel

16. Contracting Officer: This certification shall be made by the contracting officer who will sign the contract resulting from this justification and approval (J&A). Include the following statement:

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

Name: Title: Contracting Officer, Managed Care Contracting Division

17. Competition Advocate: Based on the foregoing justification, I hereby approve the procurement of Pharmacy Data Transaction Service(state supplies/services being procured) on an other than full and open competition basis pursuant to the authority of 10 U.S.C. 2304(c)(1) 6.302-1 -- Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements, subject to availability of funds, and provided that the supplies and/or services herein described have otherwise been authorized for acquisition.

Name: Title: Competition Advocate (DAD-P&C)

18. Head of Contracting Activity (or designee): Based on the foregoing justification, I hereby approve the procurement of Pharmacy Data Transaction Service(state supplies/services being procured) on an other than full and open competition basis pursuant to the authority of 10 U.S.C. 2304(c)(1) 6.302-1 -- Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements, subject to availability of funds, and provided that the supplies and/or services herein described have otherwise been authorized for acquisition.

Name: Title: Head of the Contracting Activity (HCA) (DAD-P&C)

19. Director of Defense Health Agency, Senior Procurement Executive: (Authority is not delegable. except in the case of the Under Secretary of Defense for Acquisition, Technology. and Logistics, acting as the SPE for the DoD). Based on the foregoing justification, I hereby approve the procurement of Pharmacy Data Transaction Service(state supplies/services being procured) on an other than full and open competition basis pursuant to the authority of 10 U.S.C. 2304(c)(1) 6.302-1 -- Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements, subject to availability of funds, and provided that the supplies and/or services herein described have otherwise been authorized for acquisition.

Name: Title: Senior Procurement Executive (SPE)

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