JA - Construct Repl CLC - CPS - Lex - 02.22.26 - FE.pdf

VHAPG Part 806.3 OFOC Page 1 of 3 Revision: 04 Effective Date: 12/15/25 Acquisition ID#: 36C776-26-AP-0387

DEPARTMENT OF VETERANS AFFAIRS

Justification and Approval (J&A) For

Other Than Full and Open Competition (>SAT)

Acquisition Plan Action ID: 36C776-26-AP-0387

1. Contracting Activity:

The contracting activity for this requirement is the Department of Veterans Affairs, Veterans Health Administration (VHA) Program Contracting Activity Central (PCAC).

2. Nature and/or Description of the Action Being Approved:

This justification is in support of a new, single award, Firm-Fixed-Price (FFP) contract for an Architectural-Engineering (AE) firm to provide Construction Period Services (CPS) for project 596-334 Construct Replacement CLC – Complex Care Minor, Lexington VA Health Care System – Franklin R. Sousley (Leestown) Campus.

Throughout the solicitation period, the A-E shall provide solicitation support services (SSS) to include, but not limited to, attending the pre-bid site-visit meeting and project walk, answering any technical questions/requests for information (RFIs) received from contractors within five calendar days of the date the questions, and providing addenda as necessary if required to revise specs and drawings.

The A-E shall provide CPS throughout the construction period to include, but not limited to, providing responses to any requests for information, reviewing submittals, creating a complete set of air emissions permit and land disturbance permit application forms, completing site visit reports, reviewing modification requests, completing a punch list, and delivering record drawings. A total period of performance of 605 calendar days is anticipated: 455 calendar days for SSS and 150 calendar days for CPS.

3. Description of Supplies/Services Required to Meet the Agency’s Needs:

Contract number 36C77623C0076 was awarded to RDC/John Poe Architects, L.L.L.P., on July 20,2023, by Program Contracting Activity Central (PCAC) in the amount of $1,075,092.00 (inclusive of SSS and CPS). However, the Government did not exercise these options due to funding issues related to the construction project. The design contract subsequently closed out. The COR signed off confirming that the design was completed on December 4, 2024. The construction procurement package was submitted to PCAC in November of 2025, with the final construction documents from RDC/John Poe Architects, L.L.L.P. SSS and CPS were originally accounted for in the award to RDC.

The anticipated award date for this requirement is approximately March 2026. The government estimated cost of the SSS and CPS is $229,683.

4. Statutory Authority Permitting Other than Full and Open Competition:

For this action, 38 U.S.C. 8127(c), known as the Veterans First Contracting Program, provides the authority to directly contract with an SDVOSB or a VOSB. Check the specific VAAR clause used below:

(X) 819.7007 Sole source awards to a verified service-disabled veteran-owned small business

5. Demonstration that the Contractor’s Unique Qualifications and/or Nature of the Acquisition Requires the Use of the Authority Cited Above (applicability of authority):

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Acquisition ID#: 36C776-26-AP-0387

This requirement is for Architect-Engineering services associated with the design, construction, and alteration of real property, so commercial business practices were not considered, and the commercial marketplace was not surveyed.

The proposed source for this acquisition is RDC/John Poe Architects, L.L.L.P., a registered and verified small business, located at 524 Fernwood Drive, Altamonte Springs, Florida 32701. RDC is technically qualified for this project as they are the designer of record for this current EHRM requirement. A review of the Contractor Performance Assessment Reporting System (CPARS) has confirmed RDC’s successful past performance on VA design projects. The VA’s technical experts have determined that RDC/John Poe Architects, L.L.L.P. is most qualified to perform the required services as they possess all institutional knowledge regarding this project.

6. Description of Efforts Made to ensure that offers are solicited from as many potential sources as deemed possible (including whether a notice was or will be publicized as required by RFO Part 5 and, if not, which exception under RFO Rul 5 applies):

On February 17, 2026, an SBA Small Business Search query indicated there are 33 verified SDVOSBs under NAICS 541330 within the state of Kentucky, that could potentially submit on this project. On January 15, 2026, a Notice of Intent to Sole Source to an SDVOSB was posted to SAM.gov. An amended Notice of Intent to Sole Source was published on January 22, 2026, correcting statutory authority and the period of performance.

The VA received a total two (2) responses to the notice of intent to sole source by the closing date. Per a Small Business Administration search, zero results were found to verify a SDVOSB designation for Patriot Construction Management or Grey Snow Patriot Alliance based on the UEI numbers submitted on their submissions.

There are proven performance benefits of having the same A-E firm engage in the CPS as well as the original design, no other options were explored. It was determined by the site, and concurred by the CO, that the high value of the site-specific design experience makes other options far less beneficial to the efficient administration of CPS.

This Justification and Approval (J&A) document will be posted within 14 days after award in accordance with FAR Subpart 6.301. The award synopsis will be posted to GPE in accordance with FAR Subpart 5.301.

7. Determination by the CO that the Anticipated Cost to the Government will be Fair and Reasonable:

The market price for the AE’s rates for SSS and CPS will be compared with their rates from the original design portion of this project, from the IGCE, and from rates that have been used in previous design projects at the Lexington- Leestown site. The contracting officer will make fair and reasonable determination prior to award.

PCAC has experience with sole sourcing SSS and CPS in support of construction projects. Below is an overview of a similar requirement at this location:

Project # 596-334 Construct Replacement CLC – Complex Care Minor Design, Lexington VA Health Care System – Sousley in Lexington, Kentucky: The original design contract for this project was awarded by Program Contracting Activity Contract number 36C77623C0076 was awarded to RDC/John Poe Architects, L.L.L.P., on July 20, 2023, by Program Contracting Activity Central (PCAC) in the amount of $1,075,092.00 (inclusive of SSS and CPS). Since RDC/John Poe Architects, L.L.L.P. was a verified SDVOSB and the original design firm, it was determined to sole source this project to them in accordance with VAAR 819.7007. The estimate provided by RDC/John Poe Architects, L.L.L.P. was in the amount of $227,057.00 for a total performance period of 605 calendar days, to include attendance at the pre-construction meeting, monthly site visits, responses to Requests for Information (RFIs) and submittals, review of change orders, inspections and testing, work acceptance and providing As-Built drawings. This sole source contract was awarded to the original design firm.

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Acquisition ID#: 36C776-26-AP-0387

Historically, given the past pricing the AE submitted as part of the original design proposal is available for comparison, the CO expects the COR's estimate to be fair and reasonable.

8. Description of the Market Research Conducted and the Results, or a Statement of the Reasons Market Research Was Not Conducted:

The SBA SBS query indicates there are 33 certified SDVOSBs and VOSBs under NAICS 541330 within the state of Kentucky that could potentially be eligible to compete for this project. In addition, a list of 19 firms on the PCAC AE MATOC were verified as certified SDVOSBs. Lastly, a Special Notice of Sole Source Intent was published in January 2026 which resulted in two firms submitting responses. Per a Small Business Administration search, zero results were found to verify a SDVOSB designation for Patriot Construction Management or Grey Snow Patriot Alliance. No other vendor, either SDVOSB or small business concern, is willing to take over the liabilities from the original AE of record.

The CO has determined that RDC/John Poe Architects, L.L.L.P., who completed the original design package, is the most experienced firm and most likely to successfully perform the CPS without added costs or unacceptable delays.

9. Any Other Facts Supporting the Use of Other than Full and Open Competition:

It is recommended that a sole source award be made to RDC/John Poe Architects, L.L.L.P., a Service-Disabled Veteran- Owned Small Business (SDVOSB) concern that has completed the design portion of this requirement. A sole source award to RDC/John Poe Architects, L.L.L.P., is in the government’s best interest to successfully complete the SSS and CPS for this requirement as they possess all institutional knowledge regarding this project.

10. Listing of Sources that Expressed, in Writing, an Interest in the Acquisition:

Currently, there are no qualified firms that have expressed interest in this project. Per a Small Business Administration search, zero results were found to verify a SDVOSB designation for Patriot Construction Management or Grey Snow Patriot Alliance.

11. 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:

The Lexington VA Health Care System – Franklin R. Sousley (Leestown) Campus and VHA PCAC will compete future projects on the open market using the procedures established in FAR Subpart 36.102 for A-E procurements.

12. Requirements Certification: I certify that the requirement outlined in this justification is a Bona Fide Need of the

Department of Veterans Affairs and that the supporting data under my cognizance, which are included in the justification, are accurate and complete to the best of my knowledge and belief.

Tyler Messner Date COR/Engineer Lexington VA Health Care System – Franklin R. Sousley (Leestown) Campus

13. Approvals in accordance with the VHAPM Part 806.3 OFOC SOP:

a. Contracting Officer or Designee’s Certification (required): I certify that the foregoing justification is accurate and complete to the best of my knowledge and belief.

Bridget May Date Contracting Officer (PCAC) http://vaww.pclo.infoshare.va.gov/PMWeb/VHAPM_Part_806.3.aspx VHALEXMessnT Typewritten Text 2/23/2026