JA CliniComp CIS Sustainment and Support 36C10B26R0050_Redacted.pdf

VA-26-00042621

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

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 firm-fixed price contract to CliniComp International, Inc. (CliniComp), located at 9655 Towne Center Dr, San Diego, CA 92121-1964, for continued maintenance and sustainment of the existing CliniComp Clinical Information System (CIS) Sustainment and Support which includes all necessary software updates, testing and support.

3. Description of Supplies or Services: The Veterans Health Administration (VHA), Equipment Life Cycle Management (ELCM) has a requirement to support the existing System-as-a-Service (SYaaS) CliniComp system currently deployed and operational within 44 VA Medical Centers (VAMC) across nine Veteran Integrated Service Networks (VISN). The VAMCs currently own a significant amount of CliniComp CIS hardware, UPS and switches purchased under other efforts. This CIS system provides automated collection and charting of physiologic monitors, ventilators and other medical devices, monitors, real time reporting, building and configuration of specific environment, auto-triggers, database queries, real-time access to information in acute and critical care areas, emergency departments, intensive care, medical/surgical units, post anesthesia care, procedural care, progressive care and/or telemetry areas of care. The CliniComp CIS provides remote and single sign-on access, inbound and outbound Health Level Seven (HL7) interfaces to Veterans Health Information Systems and Technology Architecture (VistA), inbound data from medical devices, record upload to VistA Imaging, and data extracts. The system operates within the VA clinical environment and interfaces with VA health information systems, including VistA/ Computerized Patient Record System (CPRS), using established health information exchange standards such as HL7. The CliniComp CIS provides a real-time bi-directional interface with VistA and allows the creation and storage of a completed Portable Document Format (PDF) file that is accessible in VistA Imaging via the CPRS and may be integrated with VHA’s Tele-Critical Care (Tele-CC) national infrastructure.

This acquisition is for the continued sustainment and support of the existing CliniComp CIS SYaaS operational capability and does not procure a new clinical information system or expand the current CliniComp footprint within VA. The requirement includes continued upgrades, maintenance and technical support services necessary to sustain the CliniComp CIS associated hardware, software and licenses as well as to include continued support for VA owned hardware purchased separately in which the associated warranty is ending. ELCM requires continued maintenance, sustainment, and technical support services necessary to support the continued operation of the existing CIS capability. Continued support of the existing CIS minimizes operational disruption, preserves existing interfaces and validated clinical workflows, avoids

CliniComp CIS Sustainment and Support VA-26-00042621 unnecessary implementation and retraining costs, and maintains continuity of patient care until VA’s planned Oracle Cerner transition is completed.

The Period of Performance (POP) shall be a 12-month base period, two 12-month option periods and 13 Optional Tasks. The overall period of performance shall not exceed 36 months.

4. Statutory Authority: The statutory authority permitting other than full and open

Acquisition Regulation Overhaul (RFO) VA Deviation Part 6.103-1(d), “Only one responsible source and no other supplies or services will satisfy agency requirements”.

5. Rationale Supporting Use of Authority Cited Above: Only CliniComp is able to provide the necessary software maintenance, sustainment, and technical support services for the currently deployed and operational CIS system. The Government’s requirement is for continued manufacturer-authorized maintenance and sustainment of the existing CliniComp CIS environment. The current CliniComp CIS system is uniquely configured to fit the specific needs of the various VISN facilities in which it is currently fielded. The software has been developed by and is maintained solely by CliniComp and is considered to be proprietary to CliniComp. CliniComp does not authorize any third party to perform software maintenance or services on its software. CliniComp retains exclusive rights to the software, source code, and system architecture, no other third party or reseller is able to provide the necessary software maintenance, sustainment, and technical support in order to support the existing CliniComp CIS system.

Additionally, this Commercial-off-the-Shelf software is highly configured/customized to interface with VISTA, medical devices, Tele-CC, and analytic systems and configurations to the software are necessary to meet VA’s interoperability and standardized terminology requirements.

Other commercially available CIS products have VistA interface capabilities; however, each interface must be configured to support the specific clinical workflows, data requirements, device connections, and operational needs of the individual facility.

Before that interface can be configured, the replacement CIS must first be designed, configured, and validated for the facility so the Government can determine what data must be exchanged with VistA. Accordingly, replacing the currently deployed CliniComp environment would require substantial site-specific system design, configuration, interface development, testing, validation, and implementation at each affected facility.

Each affected facility has established and validated CliniComp-specific configurations, clinical workflows, data mappings, medical-device connections, logical links, security and routing constructs, VistA/CPRS and VistA Imaging integration, analytics extracts, and other site-specific operational dependencies. Implementation of a new clinical system would require these elements to be redesigned, configured, tested, clinically validated, and implemented at each affected facility to prevent disruption of clinical operations. The estimated duplication in cost associated with procurement of a replacement solution includes software, hardware and licenses, as well as services which include project management, implementation, testing, training, and significant VistA interface reconfiguration. The VistA interface itself is site/instance-specific, reflecting the unique workflows, data fields, and operational processes that have been incrementally developed and refined over time within each facility’s Commercial Off- The-Shelf (CIS) system. Replacing the current vendor would necessitate a full re-development of the CIS software to replicate the existing operational state, followed by a complete rebuild of the VISTA interface to align with the re-developed system. This effort would entail significant new investments in hardware, software, training, and development resources. Based on historical implementation data, such a transition would require an estimated 18 to 24 months per facility to complete, during which time critical operational capabilities would be disrupted or degraded. This would result in major disruptions in clinical documentation and workflow affecting 44 facilities across nine VISNs which includes approximately 2,063 critical care beds. In addition, extracts to analytics would have to be redeveloped and tested. Procuring a replacement system to include new hardware, deployment, configuration, testing, training, and integration is baselined between $1M-$3M per facility resulting in a total duplication of cost of more than $80M. These estimates are based on historical acquisitions from prior, similar clinical information systems, implementation timelines, and VistA interface development efforts undertaken by VA. In addition, these duplicated costs would not be recovered through competition. Accordingly, continuation with the incumbent vendor represents the only practicable means of maintaining system integrity, operational continuity, and compliance with established facility-specific processes.

VA will bear a higher level of risk to its patients as the time it would take to get a new system in place would require a phased approach estimated to take more than 5 years (18 months to 24 months+ per facility). Because a swap of CIS would take years to accomplish, the existing system would still require sustainment and support until the new CIS is accepted and fully implemented.

Finally, VA is migrating to Oracle Cerner over the next five years with final site implementation scheduled to take place in 2031. While there is no set timeline for when facilities covered under this effort will migrate to Oracle Cerner it is anticipated that the Oracle Cerner solution/system will incorporate their own CIS system and the facilities under this contract will not be exercised via the Optional Task as they migrate to Oracle Cerner. Replacing CliniComp with another CIS would take longer to fully implement than the roll out of the incoming Oracle Cerner solution. This would result in unnecessary risk, added complexity.

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 which can meet the Government’s requirements. However, the undersigned VA technical representative determined there are no resellers for support of the brand name CliniComp CIS Sustainment and Support. In accordance with RFO VA Deviation Part 5.101(d) a pre-solicitation notice shall be posted to SAM.gov, combined with the solicitation. Further, in accordance with RFO VA Deviation 5.301(d), an award notice will be posted to SAM.gov within 60 days of award.

7. Actions to Increase Competition: The Government will continue to conduct market research to ascertain if there are changes in the marketplace that would enable future actions to be competed.

8. Market Research: The Government technical experts conducted market research efforts from November 2025 through February 2026, and focused on reviewing whether other vendors could provide similar system capabilities that would provide continued sustainment, maintenance, and technical support for the existing CliniComp CIS system. Market research was conducted to assess the availability of commercial sources capable of providing continued sustainment, maintenance, and technical support for the existing CliniComp CIS system currently deployed within VHA medical facilities. Market research included a review of prior contractual actions, vendor capability information, and other available commercial sources, specifically PICIS and Pacific Monarch. These vendors are unable to provide similar solutions without substantial duplication of time and costs as described above. The VA currently owns CliniComp specific hardware, UPS and switches all previously procured by the VISNs.

Which was then developed and customized to operate within the VA’s system. Due to proprietary data/code neither vendor, PICIS or Pacific Monarch, can provide the necessary maintenance or sustainment support for the currently deployed CliniComp CIS environment which includes both proprietary hardware and software support. This effort did not identify any additional sources capable of meeting the Government’s requirement without unacceptable disruption to clinical operations, system integrity, or patient safety. Accordingly, CliniComp was determined to be the only responsible source capable of fulfilling the Government’s sustainment requirements for the existing CliniComp CIS system.

Additional market research was conducted by the Contract Specialist May-July 2026, by utilizing the National Aeronautics and Space Administration (NASA) Solutions for Enterprise-Wide Procurement (SEWP) V Governmentwide Acquisition Contract (GWAC) Provider Look-up Tool to determine whether there are authorized resellers of CliniComp CIS that hold NASA SEWP V GWACs. The Contract Specialist searched for CliniComp CIS and found that the search revealed zero sources. The Contract Specialist contacted CliniComp excellence directly in June 2026, to inquire about authorized resellers. The Senior Vice President, Client Services responded on July 7, 2026, and stated, “CliniComp does not have any authorized resellers”.

9. Other Facts: None.

Technical/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.

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 comparison to the Independent Cost Estimate and price analysis based on historical pricing data.

Contracting Officer Certification

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

Office of General Counsel (OGC) Review

I have reviewed this document and find it legally sufficient, based on the representations set forth in the documents and, if any, attachments. The Head of the Contracting Activity’s approval is an independently supported decision not wholly reliant on the legal sufficiency determination.

HCA Approval

In my role as Head of the Contracting Activity, based on the foregoing justification, I hereby approve the acquisition of CliniComp CIS Sustainment and Support on an other than full and open competition 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.