JA - FAR 16.5 EHRM Bridge_FINAL_Redacted.pdf

EHRM Rapid Decision Making (Bridge)

JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY

1. Identification of the agency and the contracting activity, and specific identification of the document as a "Justification for an Exception to Fair Opportunity."

This justification for an exception to fair opportunity is executed by the Strategic Acquisition Center (SAC), on behalf of the 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 award (sole source) Firm Fixed- Price task order under the Integrated Healthcare Transformation (IHT) 1.0 multiple awardee Indefinite Delivery Indefinite Quantity contract. The requirement will be awarded against contract 36C10X20D0002 to Aptive HTG, LLC, (SAM UEI - L2LMMGFF12A3) a Service-Disabled Veteran-Owned Small business (SDVOSB) for an emergency ten (10) month bridge with the potential to utilize FAR 52.217-8 for up to six

(6) additional months for continued services for Clinical Informatics Services to the numerous customers and sponsors engaged with the DHO. VHA supports and provides medical care for VA’s eligible beneficiaries through the VA health program which includes VA Medical Centers (VAMC), contracted health care networks. DHO’s Office of Clinical Informatics (OCI) advances the enterprise standard of care and experience through improved data, tools, and informatics processes. DHO is charged with responsibility for helping ensure the success of the modernized VA EHR, Oracle Health Millennium, through the implementation, alignment, and sustainment of value streams, functional requirements, business process reengineering (BPR), clinical content standardization, workflow standardization, and change management. In support of the modernized VA EHR, the Electronic Health Record Modernization (EHRM) Rapid Decision-Making requirement requires the Contractor to solve informatics issues escalated from sites that are or have recently transitioned to the Federal Electronic Health record. The contractor does this in collaboration with clinical SMEs from across

VHA.

The current task order 36C10X20D0002, 36C10X23N0040 period of performance is 02/28/2023 – 08/25/2025, which includes exercising all option periods and FAR clause 52.217-8. The total task order value inclusive of options is $63,510,917.49.

3. A description of the supplies or services required to meet the agency’s needs

(including the estimated value).

This requirement is for Aptive HTG, LLC to provide continued support to the Clinical Informatics and Data Management Office’s (OCI) and the Client Portfolio Management Office (CPMO), which is OCI’s executive program office for VHA EHRM. EHR Modernization is one of the largest undertakings in VA’s history. Deploying a new, distinct EHR medical system for use by the majority of VA’s 400,000+ employees require unprecedented but necessary standardization across VA’s 140+ medical centers, the largest healthcare system in the U.S. The size and complexity expose VA’s modernization of EHR to a high degree of risk and emergent effects. For example, patients risk loss of medication and delayed appointments if EHR changes fail to communicate correctly with other VA systems and other healthcare entities. VA’s medical centers fall under the purview of VHA. The Digital Health Office’s Client Portfolio Management Office integrates activities related to VHA’s EHRM efforts, including EHRM Council management and functional triage and resolution of EHR modernization risks and issues. The Client Portfolio Management Office delivers products and services related to VHA's EHRM efforts including management of the Tier 1 Subject Matter Experts (SMEs) and functional issues. CPMO supports a high reliability, learning digital health organization. CPMO’s mission is to improve the Veterans’ experience and provide healthcare staff with information and solutions for better decision workflows.

VA needs this requirement for the Contractor to support value stream management to solving clinical informatics issues escalated in relation to the Federal EHR (aka EHR modernization). Contractor will engage VA stakeholders and end-users, incorporating their needs and observations into work product standardized at the enterprise level for national deployment. Contractor will also support validating improvements to VA end-users from VA end-user-centric improvements to processes related to modernized EHR.

Tasks/services urgently needed include EHRM Issue Management, EHRM Council Management, and Informatics Adoption Pathways. Informatics Adoption Pathways are an essential element of change management transitioning between EHR systems in a highly complex and dynamic healthcare delivery environment. Gaps in support for evolved operational needs will disrupt the current accelerated timeline for resumption of EHR deployments currently underway.

The period of performance will be for one ten (10) month bridge from 08/25/2025 – 06/24/2026 with a six (6) month option period from 06/25/26 – 12/24/26. The total estimated value of this action, inclusive of options, is $39,989,205.12.

4. Identification of the exception to fair opportunity (see 16.505(b)(2)) and the supporting rationale, including a demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the exception cited. If the contracting officer uses the logical follow-on exception, the rationale shall describe why the relationship between the initial order and the follow-on is logical (e.g., in terms of scope, period of performance, or value).

The statutory authority permitting an exception to fair opportunity is Section 41 U.S.C.

4106(c)(3) as implemented by the Federal Acquisition Regulation (FAR) 16.505(b)(2)(i)(C), entitled “The order must be issued on a sole-source basis in the interest of economy and efficiency because it is a logical follow-on to an order already issued under the contract, provided that all awardees were given a fair opportunity to be considered for the original order.”

Aptive HTG, LLC. has been determined to be a responsible source as one of the IDIQ holders under the IHT 1.0 IDIQ, as the incumbent currently delivering national solutions for VHA, and as a registered and certified SDVOSB. Contractor has maintained reductions to clinician support burdens by over 35%, preserving resources for workflow optimization. Contractor has maintained reductions in patient safety risks by 10-15%, as measured by related incident reports. Contractor resolves EHR issues (over 60% at high severity) leading to reductions in medication errors, diagnostic delays, and clinical decision support failures, thus protecting Veteran care. Contractor has maintained improvements to informatics readiness by 100%, reducing deployment timelines by 6-12 months. Contractor has maintained acceleration of the EHRMIO Change Leadership Team Informatics Lead role, reducing deployment timelines from 6-9 months to 3 months. Contractor has maintained processing time reduction of 81% (facilities) and 59% (VISNs), preventing millions in additional costs from inefficiencies, manual workloads, and prolonged downtime.

Without this contract we will see an increase in clinician burden including workarounds for lack of process standardization, and patient risk (due to medication errors and diagnostic delays due to missed handoffs and underdeveloped interfaces in processes or terminology. These gaps in turn will result in increased frequency of adverse events and increased cost to treat increased morbidity. In addition, current EHRM timelines are based in part on sustained resource capacity for the work defined in this contract so a gap in services will impact go live timelines.

VA is in the process of reprocuring a longer-term procurement for these services. As illustrated above, a gap in services for this work will have a direct and profound impact on EHRM success, quality and timeliness of patient care at federal EHR sites, a top SecVA priority. In addition to the 45 days required to award a new TO on IHT 1.0, the average time for onboarding is 30 days, after recruitment is completed, which takes an average of 30 days; and then orienting the Contractor staff to the specific requirements of OCI’s work environment without a significant lapse in performance which takes another 30 days. Absence of contract staff to perform the tasks in this contract will result in delays in the deployment schedule in the electronic health record (EHR) and significant patient safety risks at sites using the Federal EHR. Due to the extensive expertise that this vendor has developed in resolving significant federal EHR issues and the extremely limited flexibility in timelines, a logical follow on to the current vendor is the most appropriate approach, while the VA continues to pursue the long-term contracting strategy.

5. A determination by the contracting officer that the anticipated cost to the

Government will be fair and reasonable.

IHT 1.0 has already determined the rates for service offered at hourly rates to be fair and reasonable. Under this effort, Aptive HTG, LLC will submit a proposal outlining their proposed effort and pricing with the established IHT 1.0 multiple award IDIQ. This determination will be based on a comparison of current contract pricing, an Independent Government Cost Estimate, and other information as made available. No award shall be

9. Evidence that any supporting data that is the responsibility of technical or requirements personnel (e.g., verifying the Government’s minimum needs or requirements or other rationale for an exception to fair opportunity) and which form a basis for the justification have been certified as complete and accurate by the technical or requirements personnel.

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.

Program Manager Office of Health Informatics (OHI)

Approval

Based on the foregoing justification, I hereby approve this acquisition on an “other than full and open competition” basis pursuant to the basis pursuant to the statutory authority cited in paragraph four above, subject to availability of funds, and provided that the property and services herein described have otherwise been authorized for acquisition.

As this action does not exceed $75M, the certification below required by FAR 16.505(b)(2)(ii)(C)(3) serves as approval.

Strategic Acquisition Center and National Acquisition Center