DEPARTMENT OF VETERANS AFFAIRS

Office of Procurement, Acquisition and Logistics (OPAL)

Strategic Acquisition Center (SAC) 10300 Spotsylvania Ave, Suite 400

JUSTIFICATION AND APPROVAL

FOR OTHER THAN FULL AND OPEN COMPETITION

(1) Identification of the agency and the contracting activity, and specific identification of the document as a "Justification for Other Than Full and Open Competition."

This Justification and Approval (J&A) for Other Than Full and Open Competition is executed by the Strategic Acquisition Center (SAC), on behalf of the Department of Veterans Affairs (VA), Veterans Health Administration (VHA), Chief Strategic Office

(CSO).

(2) Nature and/or description of the action being approved.

This activity intends to modify and extend the current Actuarial Support Services bridge contract 36C10G25C0006, held by the contractor, Milliman, Inc., which was awarded on a sole source basis on March 31, 2025, to provide continued Actuarial Support Services and to prevent a lapse in critical services in support of VHA, CSO while the follow-on acquisition is competitively procured. The current contract will expire on March 31, 2026. The proposed extension of the Actuarial Support Services bridge contract will support the CSO which continues to require a wide range of health care actuarial demand for VA health care, and associated expenditures to support the VA medical care budget, strategic, capital, and workforce planning, and policy analysis. The added period of performance for this action covers up to 12 months of additional options covering: Option 6, April 1, 2026, through July 31, 2026 (four months), Option 7, August 1, 2026, through October 31, 2026 (three months), Option 8, November 1, 2026 through December 31, 2026 (two months), Option 9, January 1, 2027 through February 28, 2027 (two months), and Option 10, March 1, 2027 through March 31, 2027 (one month), if needed.

The contractor shall continue to provide actuarial consulting, modeling, and analytical services to assess the impact of an evolving VA health care system and broader environment on Veteran demand for VA health care. These services promote twenty-year projections of Veteran enrollment, utilization, and expenditures at a very detailed level for each fiscal year. The resulting projections are central in the development of the VA medical care budget, strategic planning, capital and workforce planning, and policy analysis.

(3) A description of the supplies (including the estimated value).

The purpose of the current Actuarial Support Services bridge contract held by Milliman is to provide actuarial consulting, modeling, and analytical services to assess the impact of an evolving VA health care system and broader environment on Veteran demand for VA health care. The VA Enrollee Health Care Projection Model (EHCPM) produces twenty- year projections of Veteran enrollment, utilization, and expenditures at a very detailed level for each fiscal year. The cost estimates are fundamental to the development of approximately 90 percent of the VA Medical Care Budget. The resulting projections are central in the development of the VA medical care budget, strategic planning, capital and workforce planning, and policy analysis. Tasks that support development of the EHCPM involve collaboration between VHA, program offices, and contracted actuaries to maintain, enhance, and annually update the EHCPM with new data from the most recently completed fiscal year and other newly available data.

The CSO and the actuarial consultants serve the quantitative and analytical needs related to Veteran enrollment and demand for VA health care to support the requirement of various local/regional, national, and federal stakeholders, including but not limited to VA health care facilities, Veteran Integrated Service Networks (VISNs), the VHA Under Secretary for Health, VHA Office of Finance, VHA program offices, the Secretary of Veterans Affairs, VA Office of Management, Office of Management and Budget, Department of Health and Human Services, Indian Health Service, Congressional members, staff and committees, Government Accountability Office, includes producing model projections that provide critical support to the federal budget process, VHA strategic, capital, workforce planning, and the ad hoc requests of stakeholders.

The estimated value of the additional five option periods for a total of one year is approximately . This estimated value represents the anticipated contractual usage in the additional five option periods, which is based upon the IGCE prepared for this updated 12-month effort that analyzed spend in the previous 12 months of this current contract. This current Actuarial Support Services bridge contract total award dollar value is for a Base and Five Option Periods, totaling 12 months of performance.

(4) An identification of the statutory authority permitting other than full and open competition.

The statutory authority permitting other than full and open competition is 41 U.S.C.

§3304(a)(2), as implemented by Revolutionary FAR Overhaul (RFO) Subpart 6.103-2

(5) nature of the acquisition requires use of the authority cited.

Milliman has been providing these services to VHA for the past six years (2019-current), most recently under this bridge contract award 36C10G25C0006 issued on March 31, 2025.

Contract follow-up competition efforts began in September 2023 with an anticipated award date of February 2026 but based on the cancelation and non-award of the recent solicitation efforts, a new acquisition package needs to be put together and processed for proposal and awarding efforts, with an anticipated award date being estimated around the end of the calendar year 2026. With no follow-up contract award in place, and with less than 45 calendar days left in the current Actuarial contract life, this produces a risk of having gaps of coverage in providing projections that are central in the development of the VA medical care budget, strategic planning, capital and workforce planning, and p Modifying and extending the bridge contract will enable continued actuarial support to VHA until a new contract is in place.

The actuarial support VA obtains includes support for budget formulation, strategic analyses on new and changing laws and regulations. Delays in producing materials or failure to produce materials would have significant negative impacts on VA. Here are several examples of how VA uses the information supplied with actuarial support.

outputs. Delaying or failing to provide the necessary budget scenarios to the VHA Office of Finance for budget formulation, which is submitted to OMB, would result in an inaccurate or incomplete understanding of resources needed for VA to provide health hospitals and health care settings to provide health care; insufficient resources would direc if the VA system is not resourced to accommodate the volume of care needed, it will lead to higher wait times for Veterans.

The actuarial support and analytical work that produces the EHCPM enables delivery of

Planning Application (HSPA), VHA Support Service Center (VSSC), and the quadrennial Market Area Health Systems Optimization (MAHSO) process, required by the MISSION Act; workforce planning activities; and Strategic Capital Investment Plan (SCIP) processes to calculate space needs and gaps and request new leases and construction in Prospectuses for the budget submission. The actuarial services contract is required to produce these data and deliverables through the EHCPM. Delaying or failing to provide updated strategic projections of future workload would result in an inaccurate or incomplete understanding of anticipated system needs, significantly impeding appropriate planning for the future to meet the health care needs of Veterans.

The EHCPM and other actuarial models are used to assess the impact of proposed new laws, regulations, or internal policies that impact Veteran enrollment, utilization of VA for health care, and the cost of that care. Without the support of the actuaries, VA would be unable to use updated and accurate actuarial models to assess these impacts. This lack of information would mean that decision-making around adopting or changing policies would be ill-informed; VA leadership needs a full and accurate assessment of system impacts to make sound decisions that can affect Veterans and their access to VA health care.

Office of Management and Budget (OMB) as well as Congressional leaders in the House and Senate Veterans Affairs Committees and Appropriations Committees are thoroughly familiar with these approaches and expect budget submissions to reflect them, as evidence-based and analytically formed foundations for resource requirements. Absent this approach, budget submissions will be subject to serious questions and concerns from these stakeholders, jeopardizing the timely and sufficient appropriation of funds that provide resources for VHA facilities to deliver care to Veterans. Approval of this bridge co ability to provide and support world-

(6) A description of efforts made to ensure that offers are solicited from as many potential sources as possible, including whether a notice was or will be publicized as required by part 5 and, if not, which exception under part 5 applies.

Notice of this J&A will be publicized in accordance with RFO Part 5. As this is a bridge contract, no efforts to solicit potential sources for this action were conducted. However, the effort to award a fully competitive action for these services is going to be underway within the Integrated Project Team (IPT).

(7) A determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable.

Proposal analysis will be conducted in accordance with (IAW) RFO 15.404-1(b)(2) - Price Analysis by comparing the proposed prices to historical prices paid; and independent Government cost estimates. Prior to awarding this sole source extension, a determination will be made by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable. The Contracting Officer will utilize the historical pricing information from the current Actuarial Support Services bridge contract in addition to independent Government cost estimates.

(8) The market research conducted (see part 10) and the results or a statement of the reason market research was not conducted.

Market research was not conducted due to the absence of a follow-up contract award and with less than 45 calendar days remaining in the current Actuarial contract term.

This situation poses a risk of coverage gaps in providing projections that are crucial for the development of the VA medical care budget, strategic planning, capital and workforce planning, and policy analysis, all of which impact future Veterans' healthcare.

The authority being utilized in this effort is based on unusual and compelling urgency, which should allow for the market research step to be bypassed in this instance. Efforts to solicit a new fully competitive action will be undertaken to maximize competition. An IPT will be implemented to include all stakeholders.

(9) Any other facts supporting using other than full and open competition, such as:

(ii) When 6.103-2 is cited, data, estimated cost, or other rationale as to whether and how much the Government would be harmed.

With less than 45 days left in the current Actuarial contract, the absence of a follow-up contract poses a significant risk of coverage gaps in providing essential projections critical to developing the VA medical care budget, strategic planning, workforce planning, and policy analysis. Such gaps could severely affect future healthcare for Veterans. Extending the bridge contract will ensure continued actuarial support for VHA, which is vital for budget formulation, strategic planning, and policy analysis. Delays or failures in producing actuarial outputs would result in inaccurate budgets, impede strategic planning, and hinder policy decision-making, all of which could adversely affect the allocation of resources and Veterans' access to care. Furthermore, key stakeholders, including the Office of Management and Budget and Congressional committees, expect evidence-based budget submissions that rely on these actuarial models. Approval of the extension to the bridge contract