JA FAR Part 6_Urgent and Compelling_CPM_SAM posting.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 (SAC), on behalf of the Department of Veterans Affairs (VA), Office of Health Informatics (OHI), Clinical Informatics and Data Management Office (CIDMO), Field Informatics Stewardship (FIS).

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

This activity proposes to negotiate a non-competitive award firm fixed price sole source award to IT Concepts, Inc. (ITC), a Service-Disabled Veteran-Owned Small Business (SDVOSB), to provide support services for the transition of VA’s legacy electronic health records from VistA to Cerner Millenium (Cerner) at Initial Operating Capability (IOC) sites. Support will include testing the Cerner system at IOCs to ensure data accuracy and alignment to VA clinical processes.

This support is critical to the success of VA’s electronic health record system modernization efforts.

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

The FIS program office (currently leading the efforts under OHI and CIDMO) and will partner with ITC to support the pre and post deployment efforts at future IOC’s.

Support actives include the development of clinical process modeling blueprints and related workflows, development of an organizational change management strategy, and development and delivery of training to clinical staff.

The estimated value for this acquisition for $6,317,767.90 for a 12-month period of performance.

Strategic Acquisition Center (SAC)

(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)(2) as implemented by the Federal Acquisition Regulation (FAR) Subpart 6.302-2 entitled, “Unusual and Compelling Urgency.”

In accordance Federal Acquisition Regulation (FAR) Part 6.302-2, Unusual and Compelling Urgency. Delay in award of a contract would result in serious injury, financial or other, to the Government.

a) The justification prepared pursuant to FAR 6.303-2 and will be posted to SAM.gov in accordance with FAR 6.305(b);

b) The company has been determined to be a responsible source with respect to performance;

c) 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; and

d) The contracting officer has determined that the use of this authority is in the best interest of the government based upon the following:

a. ITC has an excellent performance history performing this work and is best suited to support this award due to their in-depth knowledge and understanding of the Enterprise Clinical Process Modeling Blueprint and Related Workflow requirements.

b. Further delay in obtaining these critical support services impacts multiple facets for future transition site pre and post go-live activities necessary for the transition to Cerner (i.e., work stoppage of the entire IOC deployment process, will negatively impact the quality-of-care Veterans receive today through CPRS/VistA, and introduce further disruptions to the Cerner Millenium transition.

c. The lapse in service is due to Government error. The program office requested award of a follow-on task order. Upon review of the request by the prior contracting office it was determined to not within scope and notified the customer as such. The Government program office did not clearly understand what the next steps should be to avoid a lapse in service. By the time they understood what needed to occur the prior award had expired there is currently a lapse in these critical services.

d. Any further delay in award would result in serious injury to the Government, risk of successful go-live implementations and/or

Strategic Acquisition Center (SAC) significant delays in go-live implementations, and ultimately an impact to Veteran healthcare services. The schedule for go-live implementations is dependent upon the services being procured. Any additional delay in award impacts deployment schedules which may potentially impact both cost and risk to the Government.

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

This effort provides critical services in support of Cerner-site go-lives to ensure clinical workflows between Computerized Patient Record System / Veterans Health Information Systems and Technology Architecture (CPRS/VistA) and Cerner function properly and support safe care for Veterans.

ITC possess extensive knowledge and expertise in both CPRS/VistA and Cerner and has successfully performed this work for FIS in the past. Their expertise and experience with this specific work will allow them to immediately begin providing services without further delay. It is imperative that the Government utilize a contractor with expertise in this subject matter to ensure successful performance in meeting the current pre and post go-live implementations at future transition sites.

(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.

The contracting officer has determined that a sole source award to ITC is in the best interest of the Government and that the anticipated prices will be fair and reasonable.

Determination of fair and reasonable will be made utilizing a comparison of proposed prices with prices found reasonable on previous purchases.

An exception to posting the pre-solicitation synopsis exists under FAR 5.202(a)(2), therefore, a pre-solicitation synopsis will not be posted.

(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, an Independent Government Cost Estimate, past proposal submissions (if available), and other information as made available.

Strategic Acquisition Center (SAC)

(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.

Vendor Information Pages (VIP) database utilizing the North American Industry Classification System (NAICS) code 541519 and the terms Cerner, VistA, Computerized Patient Record System and CPRS. These terms were utilized in the search both separately and in various combinations.

The term Cerner resulted in four (4) firms, none mentioned capabilities with the current electronic health records system in use by VA. Further, a review of each respective firm’s website garnered no additional information regarding specific experience with VisA or CPRS.

It should be noted that ITC does not include a list of capabilities in their VIP and their website contains no mention of Cerner, VistA or CPRS experience. However, VA has recent and extensive experience with ITC’s successful support of this critical service.

No other identified firm has the extensive knowledge, experience, and understanding of this work as demonstrated by ITC.

ITC is registered in VIP and an SDVOSB and SAM as a small business under the relevant NAICS code.

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

Due to the unusual and compelling nature of this award, VA requires the appropriate partner to support the efforts outlined above. A strategic partnership with an entity who is familiar with these activities is necessary to ensure that VA does not incur further delays for sites transitioning to Cerner which could result in an impact of medical services to our Nation’s Veterans.

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

IT Concepts, Inc.

1600 Spring Hill RD STE 305 Vienna, Virginia 22182-2229, United States

Strategic Acquisition Center (SAC)

(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.

In accordance FAR Part 6.302-2, Unusual and Compelling Urgency performance cannot exceed one (1) year without a determination of exceptional circumstances provided by the head of the agency. The period of performance for this award is one (1) year.

Should performance be required past one (1) year, this requirement will no longer qualify for award under FAR Part 6.302-2, as such, competition on future requirements will be conducted to the maximum extent practicable.