JA AFDS Cont Education_FINAL_Redacted.pdf

Justification and Approval (J&A) for Other Than Full and Open Competition

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I. Contracting Activity.

Department of the Air Force Contracting Officer: Joe D. Wells IV Phone Number: 210-395-9841 AFICC 773 Enterprise Sourcing Squadron (ESS) 1517 Billy Mitchell Blvd, Bldg 954 San Antonio, TX 78236

II. Nature and/or description of the action being processed.

This is a Justification and Approval (J&A) for Other than Full and Open Competition pursuant to 10 USC 2304(c) as implemented by FAR 6.302-1(a)(2), required by FAR 6.303-2(b)(4). The US AF Dental Service (AFDS) requires Continuing Education (CE) services via email/on-line home study courses and helpdesk support for up to 3,000 active duty and civilian dental assistants and dental ancillary personnel, dental hygienists and dental laboratory personnel. The Dental Management Guide, paragraph 8.5., Enlisted Continuing Education, 25 July 2018, requires the maintenance of knowledge and skills through this CE. This is a one-year base period of performance starting on 20 Oct 22 with four (4) one-year option periods.

The American Dental Assistants Association (ADAA) is the only responsible source and no other source would satisfy the Government's requirement due to it unique and innovative capability further described in Section V.

III. Description of supplies/services required to meet agency needs.

The AFDS requires CE services to maintain and obtain dental assistant certifications to include ancillary personnel. Requirement shall include as follows:

- Provide on-line CE services to include at least 40 courses in the areas of Occupational Hazards, Infection Control, Disease Management, Dental Administration, Medical/Dental Emergencies, Preventive Dentistry, Digital Radiology, Dental Practice Management, Dental Specialties such as Oral Surgery, Prosthodontics, Orthodontics, etc.

- Provide a system for tracking certification currency, cumulative education hours, and courses completed.

- Site availability access 365 days a year 24/7.

- User access to print course completion certificates for all registrants.

- Generation of reports for military bases by the Command team.

- Certified as an approved PACE provider by the Academy of General Dentistry.

CE services shall include password protected on-line access to over 40 different CE dental related, home study accredited courses via e-mail/on-line that are available 24 hours a day, 7 days a week, 365 days a year through an on-line web site; on-line access to cumulative totals of CE hours; the ability to print course completion certificates for AFDS personnel; a toll free telephone help desk support; and on-line help desk support to assist members experiencing problems with on-line CE during normal

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IV. Statutory authority permitting Other than Full and Open Competition.

10 U.S.C 2304(c)(1), as implemented by FAR 6.302-1(a)(2), required by FAR 6.303-2(b)(4).

V. Demonstration that the contractor's unique qualifications or nature of the acquisition requires the use of the authority cited above (applicability of authority).

As required by 10 USC 2304(c)(1), implemented by FAR 6.302-1(a)(2), the AFDS must acquire this service from ADAA. ADAA is the only source allowing the AFDS dental ancillary personnel to choose a minimum 12 hours of CE over a 12 month period from their on-line library comprised of at least 40 courses that are pre-selected by the AFCFM. This 12 hour annual requirement is pursuant to the Dental Management Guide dated, 25 July 2018, under section 8.5., Enlisted Continuing Education. ADAA is the only known source that offers the AFDS's acceptable CE courses on an on-line basis.

The ADAA is a professional organization for dental assistants with a mission of advancing the careers of dental assistants and promoting the dental assisting profession in matters of education, legislation, credentialing and professional activities which enhance the delivery of quality dental health care to the public. ADAA is the only known source capable of meeting AFDS' required CE training, certification and centralized course tracking needs, and is also certified as an approved Program Approval for Continuing Education (PACE) provider by the Academy of General Dentistry. ADAA is a non-profit organization which is comprised of 14 districts representing all 50 states and each of the Armed Forces. ADAA offers unlimited on-line CE that supports AFDS personnel in obtaining and maintaining their state/national licenses and certification requirements. The ADAA is the only source capable of providing a one-stop experience for all AFDS dental ancillary personnel on a 24/7 basis. Additionally, ADAA provides a tool that ensures AFDS' centralized course tracking needs for individual dental ancillary personnel. Although there are sources that may be able to provide a few of the 40 courses, there are no known sources that have the capability of providing a tracking system. The course tracking from multiple CE cite sources would create a tremendous step backward in expending AFDS labor intensive man-hours compared to the efficiencies of utilizing the ADAA's current tracking system.

Acquiring this service from any other source would result in substantial duplication of costs and unacceptable delays that the Government could not recover through competition.

An AF Certified Dental Assistant (CDA) certification is obtained in a three part process as described in the following paragraphs.

Commission on Dental Accreditation (CODA). The AF Dental Assistant Program is nationally accredited by the CODA. CODA serves the public and profession by developing and implementing accreditation standards that promote and monitor the continuous quality and improvement of dental education programs. CODA is the accrediting body operating under the American Dental Association (ADA) to establish accreditation standards for dental

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Dental Assisting National Board, Inc. (DANB). DANB is the nationally recognized, premier certification and credentialing agency for dental assistants. DANB provides high standards for testing and dental assistant certification, ensuring the public receives quality dental care from qualified individuals.

Institution Accreditation. Graduation from an accredited program is almost always stipulated by state law and is an eligibility requirement for licensure and/or certification examinations.

Accreditation of a school or program is a dental assistant student's most important source of independent validation the program has at least enough educational value to be “approved” by a credible (expertise-based), independent (free of outside influence), reliable (consistently applied standards) organization that has the U.S. Department of Education's approval. Not only does accreditation offer the highest education standard for our dental assisting students, it also maintains a standard for AF dental technical school instructors who must meet the Community College of the Air Force (CCAF) requirements and maintain CODA to the highest standard. A certified instructor requires the following CODA guidelines: pass CDA and Basic Life Support (BLS) instructor certification and attain an Associate's degree in dental assisting.

Infection Control Exam (ICE) and Radiation Health and Safety (RHS) Certifications Obtained and Maintained in Three (3) Parts. The AF's accreditation program sets AF dental assistant airman apart from the other services enabling our airmen while still in training, the ability to challenge the first two exams of the DANB: ICE and RHS. Upon completion of one (1) year of on-the-job training (OJT) at their gaining base they are able to challenge the third component of the DANB, General Chairside, is maintained by 12 reoccurring hours annually to maintain their CDA certification. Pursuant to Training Message 13-31, 4Y051A CDC Volume 1 Exemption, all 4Y0X1 personnel that complete and pass both the DANB Infection Control and Radiation Health & Safety competency examinations are exempt from completing 4Y051N (edit code 04) Dental Assistant Journeyman, Volume 1: Infection Control and Radiology CDC.

The Air Force Career Field Manager (AFCFM) guides and counsels AF personnel on all matters related to training, utilization, and sustainment of dental ancillary personnel.

VI. Description of efforts made to ensure that offers are solicited from as many potential sources as practicable.

A request for sources sought was posted on sam.gov website on 4 March 2022, resulting in no responses. Market research (MR) was performed via the Internet, in search of commercially available sources that provided the same or similar services. In addition to the ADAA, the following seven (7) organizations were found and considered: American Dental Education Association (ADEA), Academy of General Dentistry (AGD), National Dental Assistants Association (NDAA), Continuing Education Studies (CES), American Dental Association (ADA), Procter & Gamble Distributing LLC and Dent-Ed Solutions, LLC. Analysis of these companies' capabilities revealed none are currently capable of fully meeting AFDS's specific requirements. The findings for each of these companies is

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In reviewing other CE programs and course work required for dental assistant certifications, the Academy of General Dentistry's (AGD) PACE offers a directory of AGD PACE approved providers.

The CE programs available from the PACE approved programs are fragmented, thus creating additional demands on AFDS personnel to track certification currency.

VII. Determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable.

A price analysis, in accordance with FAR 15.404-(b)(2)(ii) and (vi), will be performed in order to determine the price fair and reasonable. This determination will be made by the Contracting Officer based upon comparison of similar CE programs obtained through market research as well as a comparison on the historical prices paid for this CE service.

In canvassing the other commercial sources in above section, the minimum charge was at least $8.00 per credit hour. Based on an estimated 3,000 AFDS personnel requiring the 12 CE hours annually at the $8.00 rate, the Government would spend approximately $288,000.00 annually from other sources, These sources are far less inclusive in their selection of courses that do not have a tracking system, as opposed to an estimated $75,000 annually from ADAA that can meet all the needs of the Government.

The ADAA is a commercial source, providing their on-line CE services to dental assistants on the open market as well as Government personnel, therefore the ADAA services and pricing are considered commercially available.

VIII. Description of the market research conducted and the results, or a statement of the reasons market research was not conducted.

Market research, in accordance with FAR Part 10, was conducted by performing Internet searches and by posting a request for information. The request for sources sought to identify alternative sources resulted in one vendor response received from ADAA. This further demonstrates the unique capability of the source.

Research conducted on the Internet yielded seven (7) additional sources. However, none of the other sources came close to offering all of the required services. Only ADAA can provide these services. All the sources below to include ADAA are non-profit organizations. The information found on each of these sources follows below:

(1) American Dental Education Association (ADEA)

655 K St NW Suite 800 Washington, DC, 20001-2385 http://www.adea.org

(202) 289-7201 CAGE Code: 00TT1, DUNS: 068590330

The ADEA is an organization focused on academic dentistry, with an overarching focus on improving dental education, research, leadership, and recognition. The CE offerings by ADEA are specific to a variety of education providers for various schools offering education in Doctors of

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Dental Medicine and Doctors of Dental Surgery. The focus and mission of ADEA and the CE offered is not aligned with certification requirements for dental assistants. ADEA is not certified as a PACE provider.

(2) Academy of General Dentistry (AGD)

560 W. Lake St., Sixth Floor Chicago, IL 60661-6600 www.agd.org

(888) 243-3368

The AGD administers the PACE credentialing process for CE service providers offering coursework for a variety of careers within the field of dentistry. It does not offer specific CE programs for dental assistants. AGD offers six free webinars, but no Internet-based CE service delivery is offered. The CE is specific to a variety of Doctors of Dental Medicine and Doctors of Dental Surgery. AGD does not offer institutional memberships and they have no organizational reporting capabilities as required by the AFDS. The CE offered is not centralized and not aligned with the certification requirements for dental assistants. AGD is certified as an approved PACE provider, a requirement of the AFDS.

(3) National Dental Assistants Association (NDAA)

6411 Ivy Lane, Ste. 703 Greenbelt, MD 20770 www.ndaonline.org

(240) 241-4448

The NDAA is an auxiliary organization of the National Dental Association that is also the parent organization for the NDAA. The objective of NDAA is to promote the education of the dental assistants and staff to improve and sustain the profession of dental assisting and to contribute to the advancement of the dental profession and the improvement of public health. The NDAA offers CE via the Dental Education Center and offers shareable materials for dental providers about common dental issues. The CE offerings are not aligned with certification requirements for dental assistants and they are not certified as a PACE provider.

(4) Continuing Education Studies (CES)

900 South Washington St., Suite G-13 Falls Church, VA 22046 www.continuingedstudies.com

(703) 237-8616

CES is an American Dental Association (ADA) Continuing Education Recognition Program (CERP) recognized provider for the delivery of CE studies and offers dental CE courses for dentists, hygienists, and dental assistants. Online CE delivery is available. Although they offer a limited number of classes online and the CE is not aligned with certification requirements for dental assistants. Consolidated organizational reporting of an individual's progress is not available, therefore, CES cannot provide organizational reporting capabilities as required by the AFDS. Next to ADAA, CES was the most capable with regard to providing online CE services, however they

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(5) American Dental Association (ADA)

211 East Chicago Ave.

Chicago, IL 60611-2678 www.ada.org

(312) 440-2633

The ADA provides members with CE. The program is oriented for graduates of dental schools.

The CE is specific to individuals that are pursuing or have already obtained Doctors of Dental Medicine and Doctors of Dental Surgery. The CE offerings are not specific to the field of dental assistants and are not aligned with the certification requirements. The ADA has no organizational reporting capabilities nor are they certified as a PACE provider.

(6) Procter & Gamble Distributing LLC 1 Procter and Gamble Plaza Cincinnati, OH 45202

CAGE Code: 74188, Unique Entity ID: LMLHENSX2W97 www.us.pg.com

(513) 983-1100

The Procter & Gamble company is an ADA CERP Recognized Provider and is designated as an Approved PACE Program Provider by the Academy of General Dentistry for Fellowship, Mastership, and Membership Maintenance Credit. Also, Procter & Gamble is designated as an approved Provider by the American Academy of Dental Hygiene, Inc. and offers dental CE courses for dentists, hygienists, and dental assistants. Online CE delivery is available however, consolidated organizational reporting of an individual’s progress is not available, therefore, they cannot provide organizational reporting capabilities as required by the AFDS.

(7) Dent-Ed Solutions, LLC P.O. Box 1397 Clifton, NJ 07015-1397 https://dent-edsolutions.com

(973) 777-9600

Dent-Ed Solutions, LLC is designated as an Approved PACE Program Provider by the Academy of General Dentistry. The formal continuing education programs of this program provider are accepted by AGD for Fellowship, Mastership and membership maintenance credit and service dentists, hygienists, and dental assistants. Online CE delivery is available however, consolidated organizational reporting of an individual’s progress is not available, therefore, they cannot provide organizational reporting capabilities as required by the AFDS.

(8) American Dental Assistants Association Inc. (ADAA) 180 Admiral Cochrane Dr Ste 370, Annapolis, MD 21401 USA CAGE Code: 1W7L7, Unique Entity ID: L6NEFY6VFL25

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(630) 994-4247

The ADAA CE platform is specific to dental assistant certification and meets/exceeds the AFDS's CE requirements. Their services include: (1) secure password protection access; (2) site availability 365 days a year 24/7, making it available to personnel at all hours; (3) ability to track PACE approved continuing education hours, track courses completed, cumulative continuing education hours, (4) user access to print course completion certificates for all registrants; and (5) generation of reports for military bases by the Command team. ADAA will allow the AFDS to choose from over 77 courses from the ADAA library and CE courses from their ADAA dental assistant publication --and the list continues to grow annually. The ADAA website can generate CE data based on the military base and the individual. In addition, the ADAA member dashboard maintains the courses ordered, completion history, functionality to upload externally completed education; and offers personnel the opportunity to review and update profile information. The ADAA course certificates remain on the individual's CE member dashboard for an indefinite period. ADAA is certified as an approved PACE provider, a requirement of the AFDS.

IX. Any other facts supporting the use of Other Than Full and Open Competition.

ADAA is the only known source that offers the AFDS's acceptable CE courses on an on-line basis. The ADAA is the only source capable of providing a one-stop experience for all AFDS dental ancillary personnel on a 24/7 basis. The technical expertise is required to support the critical dental personnel providing AFDS with uninterrupted service.

X. List of sources, if any, that expressed interest in the acquisition.

American Dental Assistants Association 35 E. Wacker Dr. Ste 1730 Chicago IL 60601-2211

CAGE: 1W7L7

XI. A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before making subsequent acquisitions for the supplies or services required.

On-going market research will be conducted for this requirement to seek out either companies who have expanded their course curriculum, added tracking systems, become PACE certified, or any new entrants to the market place that could meet AFDS requirements. Additionally, AFDS will continue to assess its mission needs to determine if a change in scope is warranted that meets both mission success and opens the market to additional contractors. As AFDS identifies new requirements, every effort will be made to ensure future actions will be competed under full and open competition.

XII. Certification by the Contracting Officer.

As evidenced by my signature above, I have determined this document to be both accurate and complete to the best of my

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XIII. Certification by the technical/requirements personnel.

As evidenced by our signatures above, we certify that any supporting data contained herein, which is our responsibility, is both accurate and complete.