JA_CCDSO Extension_Redacted.pdf

Community Care DevSecOps Support Control Number VA-24-00071970 Extension

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 sole source action is for a modification to the hybrid Firm-Fixed-Price (FFP) and Time-and-Materials (T&M) Task Order (TO) 36C10B21N10280019 issued under Transformation Twenty-One Total Technology Next Generation (T4NG) Contract VA118-16-D-1028 with Veterans EZ Info Inc. (VetsEZ), 1901 1st Avenue, Suite 192, San Diego, CA 92101. The purpose of this modification is to extend the period of performance of Option Period Five for two-months and incorporate two additional one-month option periods for the continuation of Community Care DevSecOps Support.

3. Description of the Supplies or Services: The scope of the Community Care DevSecOps (CC DSO) Support TO is to provide the Community Care Product Line (CCPL) enhancements and maintenance of critical Community Care (CC) products. The current TO provides operations support and security compliance for the CCPL, including Consult Toolbox (CTB), Enterprise Precision Scanning and Indexing Automation (EPSI), Standard Episodes of Care (SEOC), Referral Documentation (REFDOC), and Delivery Operations Claims Management Platform (DOCMP) product lines. Services consist of development, testing, integration, architecture, refactoring, release planning, security expertise, and operations and maintenance support throughout the product lifecycle.

Additionally, critical support is provided to the entire CCPL through cross-functional resources that focus on security compliance, architectural engineering, and technical analysis. VA requires continued services to ensure key system capabilities are delivered and sustained, providing clinicians and Veterans uninterrupted support for critical CC systems. The proposed action will provide for continuity of the critical support to be maintained until a new TO is awarded. No additional hardware or software will be procured as a result of this action.

TO 36C10B21N10280019 was competitively awarded to VetsEZ on February 24, 2021.

The Base period of performance was March 1, 2021 – February 28, 2022, with two 12-month Option Periods and one 60-day optional task for transition support for a total TO value of $ . A modification (P00002) was issued on February 28, 2022, to descope six months from Option Period Two in order to reallocate ceiling from the T&M Contract Line Item Numbers (CLINs) in Option Period Two to the T&M CLINs in Option Period One. The modification was necessary to accommodate a surge of support requirements for the CCPL, resulting in the overall period of performance being reduced to August 31, 2023, with the total TO value being decreased to $ . On August 29, 2023, a modification (P00006) was issued to reinstate the original period of performance for Option Period Two through February 29, 2024, and incorporate three additional one-month option periods for continued support through May 31, 2024, to accommodate necessary support and adequate transition to the follow-on TO, increasing the TO value to $ 8. Due to delays with soliciting for the follow-on TO, the proposed action is required to extend the current option period by two months through July 31, 2024 and incorporate two additional one-month option periods for continued support through September 30, 2024, if needed, to provide a seamless transition. The total estimated value of the proposed action is $ , increasing the TO value to $ .

4. Statutory Authority: The statutory authority permitting an exception to fair opportunity is Section 41 U.S.C. 4106(c)(2) as implemented by the Federal Acquisition Regulation (FAR) 16.505(b)(2)(i)(B), entitled “Only one awardee is capable of providing the supplies or services required at the level of quality required because the supplies or services ordered are unique or highly specialized.”

5. Rationale Supporting Use of Authority Cited Above: The proposed source for this action is VetsEZ, 1901 1st Avenue, Suite 192, San Diego, California, 92101. VetsEZ was awarded the CC DSO Support TO on February 24, 2021, on a competitive basis under Service-Disabled Veteran-Owned Small Business (SDVOSB) set-aside procedures on the T4NG contract vehicle. The work performed by VetsEZ under this TO provides development services, post deployment support and sustainment support services for critical CC systems that facilitate the care of Veterans. VetsEZ releases system updates, as frequently as weekly, to provide critical defect resolution and new capabilities due to rapidly changing business needs and priorities for critical system features, to ensure the systems can meet the demands of our nation’s Veterans. The required expertise provided by VetsEZ allows the CCPL to effectively meet the fluctuating delivery demands of legislative mandates including: Maintaining Internal Systems and Strengthening Integrated Outside Networks (MISSION) Act; American Rescue Plan (ARP) Act; Megabus Act; Digital Accountability and Transparency Act (DATA Act); Social Security Number Reduction (SSNR) Act; Cleland-Dole Act;

Comprehensive Prevention, Access to Care, and Treatment (COMPACT) Act; and Promise to Address Comprehensive Toxics (PACT) Act.

Initially, the plan for the follow-on TO was to leverage the T4NG2 contract vehicle, however, due to delays associated with final awards, that was not a viable approach leading to the acquisition strategy shift to General Services Administration (GSA) Multiple Award Schedules (MAS) under Special Item Number (SIN) 54151S, Information Technology (IT) Professional Service. This change in acquisition strategy has resulted in a 2-month delay to solicitation release which is now scheduled to be released in May 2024. Extending the duration of this TO will provide uninterrupted delivery of sustainment and enhancements of vital CC products and ensure adequate time for proper transition to a follow-on TO with award slated for August 2024. Continuous services through September 2024, if all options are exercised, ensures vital support remains intact with adequate risk mitigation for successful transition of critical CC systems.

The CCPL must mitigate complex delivery and transition risks, requiring continued support of the current VetsEZ team. Based on contracts for similar Health DevSecOps services, new vendors require a minimum of two months to fully transition and provide development and sustainment services at levels consistent with prior vendor services to meet demanding community care requirements. The post-COVID-19 National Crisis continues to create additional complexity during this time as qualified resources are in high demand with limited availability. The clinical and IT environment of the post- COVID-19 pandemic and OIT’s DevSecOps migration, both compounds and exacerbates the known risks of transition. The CCPL is made up of a myriad of unique products integrated with numerous upstream and downstream systems built to stringent clinical specifications. Although the technology employed is common to industry, what is uncommon is the technical competency to understand hundreds of complex workflows and data variations that are inherent to CC requirements that can only be learned through clinical collaboration. To obtain the spatial and relational knowledge to develop technologies that safely meets clinical specifications requires clinical staff to orientate technologists to CC clinical workflows. With clinical staff already overburdened to focus on critical Veteran care, knowledge transfer will be impeded significantly, and this additional complexity would further delay a new vendor in being able to understand the clinical aspects of the technical workflows and provide support at the level the current environment requires. Given these additional complexities it is estimated that a vendor, other than VetsEZ, would require up to two months to onboard resources and develop sound knowledge of complex workflows to capably fulfill CC requirements. The current vendor has a unique understanding and experience of the clinical aspects of the technical workflows that could take another vendor up to nine months to obtain comparable knowledge. Specific product line details are provided below to further depict the unique qualifications and specialized capabilities VetsEZ provides to meet the requirements of the CCPL.

Clinical Integration consists of products that support the management of clinical care in the community such as CTB, EPSI and SEOC. Due to the recent platform integrations that were completed in January 2024, with dependent increments extending through August 2024 required to fully mature and implement the products, changing vendors at this time would disrupt workflows, lead to decreased efficiency, and increased costs, as detailed below. Retaining the current VetsEZ team ensures seamless system integration and maintenance of system security to meet critical project demands.

Sustaining the platform integrations (e.g., PEGA, WellHive) require specialized expertise to minimize the disruption of current workflow, to prevent delays and reduced efficiency. The VetsEZ team retains this expertise and knowledge of Clinical Integration, including the historical context, business requirements, and end-user needs. Adapting to a new platform required to modernize the capabilities is complex and time-consuming, requiring integration with existing systems and processes, significant investment in terms of time, effort, and resources, all of which the current vendor provides. Their historical knowledge and experience in building and maturing the CTB, EPSI, and SEOC systems are invaluable assets for successful integration. The VetsEZ team possesses expertise in both the legacy tool and the enhanced CTB, having worked closely with the business during its development. Additionally, with the EPSI product re-aligned within the Clinical Integration sub-portfolio in May 2021, the unique experience gained is imperative to sustain the required platform integration. Further, the VetsEZ team has accumulated the historical knowledge and expertise that is required to support ongoing development and maintenance of these critical clinical systems to meet legislative mandates. Adapting to a new platform is complex and time-consuming, requiring integration with existing systems and processes, significant investment in terms of time, effort, and resources. VetsEZ is the only vendor capable of meeting the timely needs of the CCPL to ensure successful sustainment and enhancement of the platform integrations. A new vendor brought in at this stage of the product development lifecycle would require rework of the initial designs resulting in duplicative costs and delays of product enhancements impacting legislative mandate compliance. Rework required may consist of a minimum of two planning increments for CTB, EPSI and SEOC, in addition, DOCMP would require an estimate of two planning increments, spanning over a 4-month timeline, estimated at $ .

DOCMP is a suite of claims processing components that assists with quicker processing, adjudication of claims, and report creation. The goal is to take on-premise products and migrate them to a cloud environment. Initial products identified to be migrated are the Document and Process Enable Repositories (DAPER), Operations Decision Management (ODM), and Health Administration Center (HAC) Data Warehouse. DAPER is a high visibility product that deals with Veteran eligibility.

Disruption of services would result in significant delays affecting several dependent products, including CP&E decommissioning, resulting in delayed modernization directly impacting Veteran eligibility by changing a manual process that currently takes 60 days into an automated process which will achieve a 30-day benchmark. Concerns related to this product have been briefed at the Chief Information Officer and Congressional levels. DAPER is a document imaging/workflow/data interchange designed to operate within and across multiple lines of business under the CCPL. It is a legacy product with locally developed code therefore limited experienced resources are available. Storage, latency, and congestion challenges plague the on-premise environment. The current CCPL architecture has identified a DAPER solution leveraging the existing VetsEZ team and their initiated PEGA platform replacement underway, utilizing the experienced development and implementation team mid-way through the replacement of DAPER. Continuity of services is imperative to the success of the solution with Phase III implementation scheduled in August 2024. Specialized knowledge of the environment, only available through the VetsEZ team, will provide an expeditious migration to the PEGA platform dictated by VA leadership.

As described above, due to the technical complexities of the CCPL systems, extensive dependencies of incremental releases, and criticality of seamless support for systems that facilitate the care of Veterans, the successful transition to another vendor would require a minimum of two months which is essential for completion of PI iterations which would require between two and three PIs and release of enhancements. While transition to a new vendor will be necessary as this TO expires, VA has to maintain and sustain the current CCPL systems in order to fulfill its commitment to the care of Veterans while the follow-on TO is awarded. Extensive efforts are involved with acclimating to the CCPL environment. A new team would require up to three planning increments to onboard qualified resources, learn the systems’ architecture, and get acquainted with the stakeholders in order to perform at a similar level of expertise. The proposed extension will ensure critical support is provided during this time while the follow-on TO is executed. Any delay to receive care, particularly in acute cases, is a risk to a Veteran’s wellbeing and longevity. Only VetsEZ can meet the current requirements of VA. Procuring alternative support efforts at this time would result in substantial duplication of time and cost to the Government that is not expected to be recovered in competition.

6. Efforts to Obtain Competition: Market research was conducted, details of which are in the market research section of this document. This effort did not yield any additional sources that can meet the Government’s requirements. There is no competition anticipated for this acquisition. In accordance with FAR 5.301 and 16.505(b)(2)(ii)(D), the award notice for this action will be synopsized on the Contracting Opportunities website, SAM.gov and the justification will be made publicly available within 14 days of award.

7. Actions to Increase Competition: No barriers to future competition are anticipated.

The follow-on TO is anticipated to be awarded in fourth quarter of Fiscal Year 2024 under competitive procedures.

8. Market Research: This requirement is leveraging market research conducted in January 2024 as part of the competitive procurement, which includes support for the same services. A Request for Information (RFI 36C10B24Q0105) for the new CC DSO TO was released on SAM.gov on December 15, 2023, with Amendment 01 posted on December 19, 2023 to respond to industry questions, and Amendment 02 posted on December 20, 2023 to extend the due date of responses from December 22, 2023 to January 5, 2024 when the RFI closed. The RFI, with technical questions included, and requested that interested parties provide indication of their respective capabilities to perform the services. On January 5, 2024, the RFI closed with 19 responses. The Government technical experts completed a thorough technical analysis of the RFI responses and determined the following 13 vendors capable of meeting the Government’s requirement for the follow-on TO: American Communications Solutions LLC (ACS), Aurelius Tech and Talent Solutions, Booz Allen Hamilton Inc. (BAH), Crosscheck Technologies LLC, High Plains Computing Inc. (HPC Solutions), Magnus Opus LLC, Mind Commuting, Inc., Optimal Link LLC, Peregrine Digital Services, LLC, RC4Vets LLC, Science Applications International Corporation (SAIC), TekFive, and VetsEZ. The 13 capable vendors include 2 large businesses and 11 Service-Disabled Veteran-Owned Small Businesses (SDVOSBs), however, none of them would be able to start on day one providing the CC DSO services. While there are 13 vendors deemed capable of meeting the requirements due to its similar general capabilities, the vendors would be unable to provide the seamless support required for CCPL. A competitive TO is being pursued with award of the new TO slated for August 2024. Transition to a new vendor is anticipated at that time however adequate support during transition is imperative to ensure critical CCPL systems are sustained.

Additionally, specifically for this action, the Government technical experts conducted market research in April 2024 by reviewing the T4NG Prime contract holders’ websites.

As a result of that market research, it was determined that at least 6 T4NG Prime contract holders appear capable of performing the effort; ACS, B3 Group now part of Octo, Insignia, King Street Technologies, Sierra7 and VetsEZ; however, only VetsEZ is capable of providing seamless CC DSO support until award of the competitive TO.

VetsEZ has been instrumental in establishing Essential Scaled Agile Framework and DSO processes within the CCPL, they possess the technical expertise of complex workflows and data variations unique to CC requirements and the specialized expertise to the development services in order to continue to provide critical access to healthcare for our nation’s Veterans. As a result, based on the market research described, VA has determined that only VetsEZ can meet all of VA’s requirements.

9. Other Facts: None

10. Technical and 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.

Date: _ __

Deputy Product Line Manager Signature: _

11. 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 a comparison with the Independent Government Cost Estimate, price analysis, and a technical evaluation of the proposed level of effort.

Date: __

Procuring Contracting Officer Signature: __

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

Date:

Procuring Contracting Officer Signature:

Approval

In my role as procuring activity Advocate for Competition, based on the foregoing justification, I hereby approve the acquisition of a FFP and T&M modification to be issued under the T4NG Contract VA118-16-D-1028 TO 36C10B21N10280019 for CC DSO, 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.

Date: Signature:

Advocate for Competition Technology Acquisition Center

Office of Procurement, Acquisition, and Logistics