JA Final - USCG Clinic Accreditation Redacted_Redacted.pdf

(e) Type of funding: Operations and Support Funds

(f) Year of funding: Fiscal Year 2025 thru Fiscal Year 2035

(g) Solicitation number: 70Z02325R11100001

(h) Background information about the requirement:

The USCG has a requirement for accreditation services for USCG ambulatory health care clinics throughout the United States. Accreditation services must be provided through an accreditation source recognized by the Centers for Medicare and Medicaid Services and validate implementation of the medical and dental home standards.

USCG ambulatory health care clinics are TRICARE authorized primary care sites. The Defense Health Agency (DHA) operates TRICARE. DODI 6025.13 authorizes the DHA to issue guidance for all Military Treatment Facilities (MTFs) and all operational clinical services in the military health care system. In accordance with DODI 6025.13 all MTFs must maintain accreditation through an accreditation source recognized by the Centers for Medicare and Medicaid Services.

In accordance with The Coast Guard Patient Centered Wellness Home (PCWH) program, implementation of the PCWH model is required by HSWLSCINST 6012.1. The USCG requires accreditation validation that implementation of the medical home and dental home standards required under the PCWH program is carried out to the highest evidence-base standards at each clinic to ensure compliance with the USCG PCWH program and a ready workforce capable of carrying out USCG missions.

3. Description of Supplies/Services.

This requirement is to obtain external accreditation services for USCG ambulatory health care clinics through an accreditation source recognized by the Centers for Medicare and Medicaid Services with standards that evaluate compliance with the medical home and dental home standards of the USCG�s PCWH program.

4. Identification of Statutory Authority Permitting Other Than Full and Open Competition. The statutory authority permitting other than full and open competition is 10 U.S.C. § 3204(a)(1) implemented by the FAR Subpart 6.302-1 entitled �Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.� More specifically, this action will be in accordance with FAR 6.302-1(a)(2)(iii)(A)(B), � For DoD, NASA, and the Coast Guard, services may be deemed to be available only from the original source in the case of follow-on contracts for the continued provision of highly specialized services when it is likely that award to any other source would result in�(A) Substantial duplication of cost to the Government that is not expected to be recovered through competition; or (B) Unacceptable delays in fulfilling the agency�s requirements.

5. Identification of Exception to the Buy American Act. Not applicable, this is not a domestic foreign end product. These are services to be provided by a US vendor.

6. Demonstration that the Proposed Contractor�s Unique Qualifications or the Nature of the Acquisition Require Use of the Authority Cited.

(a) Rationale for using the authority cited in section 4 of the J&A;

There are 11 accreditation sources recognized by the Centers for Medicare and Medicaid Services, 6 of the sources do not accredit outpatient primary care clinics, 1 source does not accredit dental services, and 2 sources do not assess to medical home standards. Of the remaining accreditation sources AAAHC is the only accreditation source recognized by the Centers for Medicare and Medicaid Services capable of providing the highly specialized services without substantial duplication of cost to the Government that is not expected to be recovered through competition and eliminates unacceptable delays in fulfilling the USCG�s requirement to ensure continuation of care for USCG beneficiaries.

The USCG clinics have been aligning processes to the AAAHC standards since 2009. The USCG has spent years refining the quality improvement and assurance (QI/QA) program through the development of extensive policies and procedures that are the basis for all accreditation efforts and are used for training of all clinic and medical personnel within the USCG. AAAHC has its own accreditation method which is unique to that business entity as do all accreditation agencies. The USCG has promulgated the QI/QA program with policies, procedures, and training in response to the current contractor�s accreditation method. Using another entity would create substantial duplication of effort, cost, and impact readiness because this would require the USCG to have to rework its policies, procedures, and training to comply with a different accreditation method.

Training healthcare personnel at all clinics and reworking USCG policies, procedures, and training manuals to align with another accreditation source�s proprietary standards would result in unacceptable delays in providing health care services at clinics to USCG personnel, which is the core mission of the clinic.

The following table demonstrates the impact between issuing a follow-on contract with AAAHC versus switching to another accreditation source.

Impact Follow-on Accreditation Source New Accreditation Source

Healthcare Quality Currently meeting mission requirements

Aligning to new standards could impact quality

Staffing Staff has historical knowledge of standards

Requires training clinic staff to new standards

Policies & Procedures

Currently based on AAAHC standards

Requires reworking policies and procedures to align with new standards

Accreditation Currently accredited to AAAHC standards

Risk lapse of service if unable to achieve new standards

Mission Readiness Proven to ensure workforce mission ready

Risk to workforce readiness

Facilities Currently accredited to AAAHC standards

Could require facility renovations to meet standards that would result in unacceptable delay to clinic accreditation.

Time No impact on time as currently accredited to AAAHC standards

Clinic preparation to meet new standards would require additional staff time.

Cost Currently accredited to AAAHC standards

Cost to train staff, prepare clinic for accreditation assessment and renovate facilities is estimated at $7M or more per year

Unacceptable Delay

Currently accredited to AAAHC standards

Delay in clinic readiness for accreditation assessment from updating policies and procedures, and training and aligning staff to new standards.

Switching to a new accreditation source would drive a complete redirection on how healthcare quality is assessed within the USCG health care clinics. Changing the source would require changes to policies and procedures to ensure compliance with new standards, would require substantial retraining of the USCG health care clinic workforce, and put clinics at risk of failing accreditation.

(b) Details covering what events lead to the situation requiring use of other than full and open competition procedures including whether any portion of the work can be segregated to allow for competition;

Competition has existed in previous acquisitions based on possible vendor response.

AAAHC has consistently prevailed in competition.

Market research identified only two accreditation sources recognized by the Centers for Medicare and Medicaid Services that can provide the highly specialized services.

Only one of the two accreditation sources is capable of providing the highly specialized service without substantial duplication of cost that is not expected to be recuperated through competition.

Segregating any portion of this contract to allow for a variety of vendors to compete will undermine the entire purpose of obtaining external accreditation to ensure high quality healthcare, create a fragmented healthcare culture within the USCG and create inconsistency in programmatic execution.

(c) Summarize alternatives considered and why they will not work;

Transition to another accreditation source agency would undo years of expense and labor hours that have gone into ensuring a consistent appropriate to accreditation across the enterprise. In an effort to remain fiscally accountable, retaining standards already incorporated into the USCG healthcare culture allows for continued growth and development of the organic healthcare system without creating unnecessary strain to an already overtasked resource.

Consistency with accreditation is a critical element of healthcare quality as each accreditation organization evaluates clinical quality using different methods.

(d) Impact to the mission that would result if the J&A is not approved and, consequently, the product or service not provided.

If the J&A fails to be approved, the USCG will incur additional expense as a result.

This includes additional cost to retrain all USCG healthcare personnel on the new standards, travel costs for personnel to either provide or attend training on the new standards, additional costs related to workload as new policies and procedures will need to be implemented and potentially loss of service as a primary care site due to the loss of accreditation as transition to a new organization is not a quick process and can take many months to a year for preparation. Additionally, many organizations recommend a consultant team be hired to provide mock surveys in preparation for the implementation of new standards which will require an additional contract at greater expense to the USCG. Additionally, there would be a need to refocus not only procedures but policies governing how USCG medical evaluates itself. The estimated cost to the Government to effectively switch accreditation is an additional or more per year.

7. Description of Efforts Made to Ensure that Offers are Solicited from as Many Potential Sources as is Practicable.

An RFI was published on SAM.gov on October 17, 2024 requesting sources capable of providing the accreditation pursuant to USCG requirements. Pursuant to FAR 6.203-1(d), a synopsis in accordance with FAR 5.201 will be posted to SAM.gov 14 days before contract award. In accordance with FAR 5.207 (16)(ii), the synopsis will include a statement that all responsible sources may submit a capability statement, proposal, or quotation, which shall be considered by the agency. Pursuant to FAR 6.305(a), this J&A will be posted on SAM.gov within 14 days after contract award and will remain posted for 30 days.

8. Determination by the Contracting Officer that the Anticipated Cost to the Government will be Fair and Reasonable.

The contracting officer determined that the anticipated price(s) will be fair and reasonable based on prior acquisition history and review of the IGCE prepared by the requiring office.

9. Description of Market Research.

Various techniques were used to evaluate the market. A Request for Information was posted from October 17, 2024 through November 4, 2024, without any responses being received.

The internet was searched for a list of contractors that would be able to provide the required service within the parameters of HHS and USCG requirements. The market research showed that only AAAHC met the full HHS and USCG requirements to provide external accreditation services with the other organization requiring a modification of USCG requirements which have been in place since 2009. Price lists for AAAHC and the Joint Commission were available due to the current contract and past full and open competition to assess for the evaluation of price reasonableness determination.

10. Any Other Facts Supporting the Use of Other Than Full and Open Competition.

None.

11. A Listing of the Sources, if Any, that Expressed, in Writing, an Interest in the Acquisition.

An RFI was published on SAM.gov on October 17, 2024 requesting sources capable of providing the accreditation pursuant to USCG requirements. The draft PWS was included. No responses were received.

12. A Statement of the Actions, if Any, the Agency May Take to Remove or Overcome

Any Barriers to Competition Before Any Subsequent Acquisition for Supplies or Services Required.

Prior to any subsequent acquisition market research will be conducted to include a review of accreditation sources that accredit ambulatory health clinics and meet DHA requirements. Additionally, an RFI will be published on SAM.gov requesting sources capable of providing accreditation services pursuant to USCG requirements.

13. Contracting Officer�s Certification.

I certify that the data supporting the recommended use of other than full and open competition is accurate and complete to the best of my knowledge and belief.

Contracting Officer

14. Technical/Requirements Personnel Certification.

I certify that this requirement meets the Government�s minimum need and that the supporting data, which forms a basis for the justification, is accurate and complete.

Technical Representative/COR

FINAL APPROVAL

Procuring Activity Advocate for Competition (PAAC)