JA Extension CMOP - final signed_Redacted.pdf

VA-25-00099773

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 a

Task Order (TO) 36C10B22N10240020, titled “Consolidated Mail Outpatient Pharmacy (CMOP) Integration Support and Software Support Services,” issued under the Transformation Twenty-One Total Technology Next Generation (T4NG) Contract VA118-16-D-1014 with Clear Vantage Point Solutions, LLC (hereinafter referred to as CVPS), 7630 Little River Turnpike, Annandale, VA 22003. The purpose of this modification is to extend the period of performance of Option Period Two by 3 months to allow the Government the ability to provide continued critical hardware integration, software development, and support services. This extension will serve as a bridge of support until a new competitive TO is awarded and transitioned.

3. Description of the Supplies or Services: VA CMOP requires the continuation of systems integration support and software development, modification, documentation, and support services for the network of automated pharmaceutical-dispensing operations at all CMOP locations. On September 1, 2022, the TO was awarded with a 12-month Base Period beginning on September 3, 2022, with 2 12-month Option Periods on a hybrid Firm-Fixed-Price and Time-and-Materials basis.

The last Option Period (Option Period Two) was exercised on August 15, 2024, and currently expires on September 2, 2025. The functional scope of this work includes all external interfaces to the CMOP system (including interfaces for VistA, Cerner, outsource vendors, and others planned and in production), the complete national data infrastructure which processes and routes data to the local CMOPs, the standardized transfer database and process at each CMOP, and the software, databases, and production software systems at most of the CMOPs. The scope of this effort involves bi-directional communication pathways and all related archive and business intelligence systems. The overall period of performance shall be extended from 36 months to 39 months, commencing on September 3, 2025, and extended through December 2, 2025. The total estimated value of the proposed action is

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 CVPS, located at 7630 Little River Turnpike Suite 205, Annandale, VA 22003. CVPS was awarded the existing CMOP Integration Support and Software

Consolidated Mail Outpatient Pharmacy (CMOP) Support Services Control Number VA-25-00099773 Task Order Extension

Support Services TO on September 1, 2022, as a Service-Disabled Veteran-Owned Small Business (SDVOSB) set-aside under the T4NG Indefinite Delivery, Indefinite Quantity contract. This award was issued with fair opportunity provided among all T4NG SDVOSB prime contract holders. CVPS is currently providing comprehensive systems integration support and software services for a network of automated pharmaceutical-dispensing operations under this TO. This includes maintenance of software at CMOP facilities, enhancement and integration support to improve performance and safety, and standardization of processes and documentation across multiple CMOPs. The Contractor is also maintaining bi-directional communication pathways and support related archive and business intelligence systems. Additionally, the Contractor is responsible for developing interfaces for new production equipment, leading standardization efforts, and delivering a complete development and test environment necessary for the successful completion of the project. CVPS has been working closely with VA over the past 3 years. VA is currently in the process of issuing a competitive follow-on TO for CMOP Systems Enhancement, Maintenance, and Integration Support services.

The last Option Period (Option Period Two) was exercised on August 15, 2024, and currently expires on September 2, 2025. VA is in the process of competitively awarding a new TO. The requirements development began in quarter 1 (Q1) of fiscal year (FY) 2025, with additional requirements refinement through Q4 of FY 2025. The Request for Information (RFI) was released on July 16, 2025, with an award currently projected by early November, allowing for a 30-day transition period (if applicable). The timeline to solicit the follow-on competitive TO has taken longer than originally anticipated due to the introduction of new review processes established to ensure compliance with the Executive Order (EO), Implementing the President’s "Department of Government Efficiency" Cost Efficiency Initiative, dated February 26, 2025. The new requirements, as a result of the EO, extended the timeline despite advance preparation efforts.

VA CMOP provides mail order prescriptions to Veterans using facilities with highly automated distribution systems at seven strategic locations throughout the country.

The CMOP program currently fills 135 million of VA’s outpatient prescriptions serving approximately 5 million patients annually, and accounts for 84% of all outpatient prescriptions filled. VA Medical Centers do not have the resources necessary to fill a large volume of prescriptions. Any disruption to production significantly impacts the prescription turnaround time to our Nation’s Veterans. Without these services, CMOP would not have the resources necessary to keep the automated pharmacy at full production capability. The services provided by this effort are critical for the daily functioning of CMOP’s automation systems, and the procurement of a follow-on contract for this effort was delayed from March 10, 2025, to June 2, 2025, due to the introduction and frequent changes made to the new Situation, Background, Assessment, and Recommendation (SBAR) approval process. The SBAR process was added to comply with the EO, Implementing the President’s "Department of Government Efficiency" Cost Efficiency Initiative, dated February 26, 2025. This EO aims to ensure transparent Government spending and accountability. This new process has caused delays in the flow of presolicitation documents from CMOP to the Contracting Office during that time. Consequently, an extension on the current

TO is required to provide sufficient time for award and transition of a follow-on competitive TO.

Any source other than CVPS requires an estimated minimum of 180 days to provide the requested services. This includes 90 days to process and award a new acquisition package. An additional 90 days of onboarding transition is also required.

Specifically, this includes performing background checks, issuing Government Furnished Equipment, and onboarding staff to comply with the Personal Identification Verification security requirements including elevated privileges approvals. The 90-day new acquisition package estimate is based on historical efforts to process an acquisition package of this size. The 90-day onboarding estimate is based on previous efforts conducted for similar hardware integration, software development, and support services of this magnitude. Based on the market research effort, the Government’s technical experts have determined that only CVPS can meet all of VA’s needs for uninterrupted pharmaceutical automation systems support and software development services for the 3-month extension at this time.

During the period of this proposed extension, CMOP will need to fill approximately 33 million outpatient prescriptions, serving around 4 million patients, accounting for 84% of all outpatient prescriptions filled by VA. This is a critical workload of 500 prescriptions per minute for every minute that CMOP is in operation across two shifts. Each of those 500 prescriptions is processed through multiple systems that are maintained by this effort. This involves managing an ultra-high availability of approximately 300 different applications involving a wide variety of robotic automation systems. The technical complexity of these systems requires constant care and maintenance to troubleshoot issues as they arise and resolve them in real-time to prevent any interruption in the flow of prescriptions across the nation, as there is no possibility of recovery from such interruptions. Without this critical support, CMOP systems would quickly degrade to the point where prescription flow would be completely halted. In addition, there are multiple issues daily that need immediate response from these contractors at both national and local levels to maintain the operational integrity of the entire CMOP network.

6. Efforts to Obtain Competition: Market research was conducted, details of which are in Section 8 of this document. This effort did not yield any additional sources that can meet the Government’s requirements without negative impact on current operations. 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 Contract Opportunities website 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. A competitive TO is anticipated to be awarded in November 2025, and future acquisitions will be awarded on a competitive basis. To further ensure and promote competition in future acquisitions for this requirement, the Government’s technical experts will continue to conduct market research to identify any changes in the marketplace that would enable future actions to be fully competed.

8. Market Research: The Government’s technical experts conducted market research by reviewing and searching for vendors who are capable of providing the required hardware integration and software development and support. This market research is an ongoing process starting in late 2024 and continuously being conducted, as recently as July 2025. The VA Technology Acquisition Center issued two RFIs, RFI 36C10B25Q0450 for CMOP Maintenance and Support and RFI 36C10B25Q0451 for CMOP Software Enhancements, on the Contract Opportunities site via SAM.gov on July 16, 2025. The Government received responses from multiple companies across the two RFIs. Of these responses, several were deemed capable of performing the respective efforts. Considering the responses from both RFIs, there is a reasonable expectation that two or more SDVOSBs are capable of performing the effort. As such, there is a reasonable expectation that two or more SDVOSBs will compete on the follow-on solicitation.

In the interest of complying with the EO and in the spirit of efficiencies, it was determined to consolidate the requirements under a single effort. This decision aims to streamline processes and achieve better coordination and integration of services.

Consequently, the previous requirements described under RFI 36C10B25Q0450 have been consolidated with RFI 36C10B25Q0451 into a combined effort entitled, "CMOP Systems Enhancement, Maintenance, and Integration Support."

Although other vendors are capable of performing the CMOP hardware integration and software development and support services, the Government’s technical experts determined that only CVPS can meet the Government’s requirement seamlessly.

Only CVPS can provide continued uninterrupted systems integration support and software development, modification, documentation, and support services for the network of automated pharmaceutical-dispensing operations until the recompete is awarded. Other vendors have the general capabilities to perform the current requirements but would need time to transition and onboard, only CVPS could meet the immediate requirements without interruption. CVPS has the staff currently onboarded with the technical expertise and experience that can meet VA's needs in the required timeframe for seamless continuation of systems integration support and software development, modification, documentation, and support services for the network of automated pharmaceutical-dispensing operations at all CMOP locations, consisting of all technical and administrative activities described in Sections 3 and 5 above until the new TO is awarded. The competitive TO is currently projected to be awarded in the November 2025 timeframe. This extension will provide for the timely continuance of this critically needed support to ensure there is no gap in service.

9. Other Facts: None.

10. 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.

Date

Director, Systems Program Management Office Consolidated Mail Outpatient Pharmacy Veterans Health Affairs

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 historical prices paid. The TO was initially executed on September 1, 2022, and was awarded based on adequate price competition. The proposed prices for the 3-month extension shall be compared to the prices presently on contract and will be negotiated as necessary to reach an overall price that is fair and reasonable.

Contracting Officer

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

Date

Contracting Officer

8/21/2025

8/21/2025

8/21/2025

Approval

In my role as procuring activity Advocate for Competition, based on the foregoing justification, I hereby approve the modification of TO 36C10B22N10240020 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.

Advocate for Competition Technology Acquisition Center Office of Procurement, Acquisition, and Logistics Department of Veterans Affairs

8/22/2025