JA - CIDMO-34 - Systems Safety and Instructions Systems Design Expansion_Redacted.pdf

DEPARTMENT OF VETERANS AFFAIRS

Office of Procurement, Acquisition and Logistics (OPAL)

Strategic Acquisition Center (SAC) 5202 Presidents Ct, Suite 103

Frederick, MD 21703

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 – Frederick (SAC-F), on behalf of the Department of Veterans Affairs (VA), Veterans Health Administration (VHA), Digital Health Office (DHO).

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

This activity proposes to negotiate a non-competitive, firm-fixed price, sole-source award, with Ben Allegretti Consulting, Inc. (Ben Allegretti), a Service-Disabled Veteran- Owned Small Business (SDVOSB), for the procurement of services for Systems Safety and Instructional Systems Design services.

3. A description of the supplies or services required to meet the agency’s needs (including the estimated value).

This contract is to provide numerous assessment methods integral to the human factors engineer’s skillset, which combine technical knowledge with a deep understanding of human behavior and capabilities, aiming to create systems that are functional and efficient, but also safe and easy for the intended users. This includes expansion of system safety, and expansion of the instructional systems design. These parallel efforts will inform leadership of the necessary training interventions, methods, and mode of educational instruction to facilitate operational capacity during implementation. Also, these efforts will help build a systems safety community to promote resiliency and highlight the criticality of a Safety-II approach during a large sale enterprise deployment in a distributed model that requires necessary adaptability to support and accommodate the unique traits of over 1300 sites of care while maintaining the level of quality and standard of care.

the period of performance is a 12-month base period, with no option periods.

Strategic Acquisition Center (SAC) 5202 Presidents Ct, Suite 103

Frederick, MD 21703

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)(5) as implemented by the Federal Acquisition Regulation (FAR) Subpart 6.302- 5 entitled, “Authorized or required by statute”. The applicable statute is Public Law 109- 461: “Veterans Benefits, Health Care, and Information Technology Act of 2006” specifically, the “Veterans First Contracting Program” outlined in 38 USC § 8127(c) and VAAR 806.302-570(c).

5. A demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited.

Ben Allegretti Consulting is System for Award Management (SAM) registered and a verified SDVOSB who, as a responsible source, has successfully performed requirements of similar scope and complexity for the VA via a Task Order 36C77622N2756, against Indefinite Delivery Indefinite Quantity (IDIQ) Contract 36C77619D0016, with VHA DHO.

As an SDVOSB sole source contract for VHA, Ben Allegretti Consulting has demonstrated success in past performance, with a background in Human Systems Integration (HSI) methodologies. They have a proficiency in defining and implementing digital infrastructure requirements for collaboration. As well as the technical proficiency in utilizing digital tools and platforms for project management, communication, and information sharing with the VA.

Ben Allegretti Consulting will provide the below tasks:

Task A: The goal of the Systems Safety Expansion is to buildout and organize an ecosystem for Human Systems Integration (HSI) to promote safety considerations in the health informatics workspace. This will include evolution of infrastructure requirements for practitioner interaction and sharing of project information as well as continued organizing and inventorying a resource hub for collected training materials and opportunities. Efforts will include continued outreach to potential community members within the VA, compilation of existing training materials and HSI tools related to safety, and continued creation of the requirements for a space for online collaboration for an engaged community of systems safety practitioners. Key outcomes will be documentation of improved methods for integrating HSI work with existing VA work and aggregation of HSI studies in the VA.

Strategic Acquisition Center (SAC) 5202 Presidents Ct, Suite 103

Frederick, MD 21703

Deliverables should include: an updated list of potential HSI/Systems Safety community members in VA, more in-depth digital infrastructure requirements for sharing files and other information and connecting with other community members, and a growing collection and analysis of trainings, procedures, techniques, job tasks, and other documentation related to HSI and systems safety.

Task B: The goal of the Instructional Systems Design Expansion is to continue to deliver increased training plans that can be implemented by project teams wanting to improve the knowledge, skills, and abilities (KSAs) of a specified role within a specified domain of work (for instance, the role of the Clinical Applications Coordinator in configuring a facility’s health information system in preparation for an EHR transition). The Contractor shall continue to conduct an analysis and buildup of training needs, analyze existing training resources, specify training requirements, design the instruction, create the training plan, and provide the plan for assessing training effectiveness. The Contractor shall continue to apply an instructional systems design approach and these activities will be carried out in accordance with instructional design best practices; this includes capturing detailed information about learners, the learners’ work that training is intended to improve, and current levels of learner knowledge, skills, and abilities. The Contractor shall specify the requirements for specific training materials based on instructional objectives, the appropriate sequencing of content, the strategies for delivering content, and the instruments for measuring training impact. Strategies for instruction may utilize synchronous and asynchronous instruction, remote and in-person instruction, and may utilize a ‘train-the-trainer’ approach.

Key outcomes will be an increased, implementable training strategy with associated outcome measures that includes the most appropriate type of training, amount of training, optimum media, and mode of training, as well as further recommendations on any existing or emerging technologies, tools or methods that can be leveraged to maximize training effectiveness and reduce training time and associated costs.

Deliverables should include: a continued analysis of learner needs for achieving training objectives, a more in-depth environmental scan of existing training resources, a carry-on plan for delivering training to learners, and a continued plan for assessing the effectiveness of delivered training.

VAAR 819.7007 states explicitly, “A determination that only one SDVOSB can meet the requirement is not required,” and that using this authority, the following must be verified:

Strategic Acquisition Center (SAC) 5202 Presidents Ct, Suite 103

Frederick, MD 21703

(2) The justification prepared pursuant to FAR 6.302-5(c)(2)(ii) is posted in accordance with FAR subpart 5.301(d);

This J&A will be posted on Sam.gov.

(3) The SDVOSB concern has been determined to be a responsible source with respect to performance; and

Ben Allegretti Consulting is a registered and verified SDVOSB. Ben Allegretti Consulting has demonstrated experience with system safety expansion and instructional systems design expansion for the VA and can provide the required services to complete this effort. Due to their familiarity with the program and demonstrated capability this SDVOSB vendor can provide the services, and therefore a sole source will be issued using the authority FAR 6.302-5 -- Authorized or required by statute.

(4) In the estimation of the contracting officer, contract award can be made at a fair and reasonable price that offers best value to the Government.

Task Order 36C77622N2756 against Indefinite Delivery Indefinite Quantity (IDIQ) 36C77619D0016 for services similar to this requirement was made to Ben Allegretti Consulting using competitive procedures with pricing that was found acceptable at time of award. Ben Allegretti’s proposed pricing will be verified using the Independent Government Cost Estimate (IGCE), the pricing from the previous contract, and technical expertise. A fair and reasonable price determination will be made prior to award.

6. A description of 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 by Subpart 5.2 and, if not, which exception under 5.202 applies.

In accordance with 819.7007(b), the determination to make a sole source award to an SDVOSB is a business decision wholly within the discretion of the contracting officer;

therefore, the requirement to ensure that offers are solicited from as many potential sources as practicable is not applicable to this procurement. In addition, 819.7007(c) further authorizes the contracting officer to make the award without first determining that only one SDVOSB source can meet the requirement. A notice of the proposed action will be synopsized via the Government Point of Entry (GPE) in accordance with FAR Section 5.201, and the agency will make publicly available the justification required by 6.305(a) within 14 days after contract award.

Strategic Acquisition Center (SAC) 5202 Presidents Ct, Suite 103

Frederick, MD 21703

7. A determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable.

No award shall be made until the Contracting Officer determines the cost to the Government to be fair and reasonable. This determination will be based on a comparison of current contract pricing, past proposal submissions (if available), other information made available, and an IGCE.

8. A description of the market research conducted (see Part 10) and the results or a statement of the reason market research was not conducted.

Market research was conducted, and Ben Allegretti Consulting has been determined to be a responsible source with respect to performance. They are registered and certified in Veteran Small Business Certification (VetCert) as a SDVOSB with the NAICS code for this requirement (NAICS 541611), which in accordance with Public Law 109-461 Section 502(c) meets the requirements of this statute to sole source to a SDVOSB. In addition, a review of their Representations and Certifications was conducted in the System for Award Management (SAM) and Ben Allegretti represented that they are an

SDVOSB.

In addition, the Integrity Information in SAM.gov was reviewed and FAPIIS shows no reports for Ben Allegretti Consulting that would indicate defective pricing, instances of contractor fault or recipient not-qualified, terminations for cause, default or material failure to comply, or non-responsibility of the contractor.

9. Any other facts supporting the use of other than full and open competition.

The Procuring Contracting Officer has determined that this proposed action meets all the requirements of 38 U.S.C. 8127(c).

Ben Allegretti Consulting is a responsible SDVOSB for performance of the services described herein, and the proposed contract can be awarded at a fair and reasonable price.

10. A listing of the sources, if any, that expressed, in writing, an interest in the acquisition.

N/A

Strategic Acquisition Center (SAC) 5202 Presidents Ct, Suite 103

Frederick, MD 21703

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

Future requirements will be issued on a competitive basis against the soon to be awarded Integrated Healthcare Transformation (IHT) 2.0 IDIQ contract vehicle.