JA FY26 Psychological Assessment Tools - Signed_Redacted.pdf

Control Number: FY26-0801

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

This acquisition is conducted under the statutory authority of 10 U.S.C. 3204(a)(1), and Regulatory Authority (see RFO 6.103-1 Only one responsible source and no other supplies or services will satisfy agency requirements). RFO 6.103-1 – Consideration will be limited to a specific source and products peculiar to one manufacturer (NCS Pearson, Inc.) that are essential to the Government’s requirements. Market research and clinical Subject Matter Experts (SMEs) reviews indicate that other companies’ similar products do not meet, or cannot be modified to meet, the agency’s strict clinical needs and functional requirements.

5. Rationale Justifying Use of Authority Cited:

Pursuant to the authority cited in Section 4, a sole-source award to NCS Pearson, Inc. is the only viable method to satisfy the Government’s minimum requirements. Pearson publishes and maintains a substantial portion of the psychological and neuropsychological assessments currently used across DHA MTFs, including proprietary instruments identified by MTFs as required for clinical operations. These assessments are available only through Pearson and cannot be obtained by other publishers. While other vendors may offer instruments that measure similar constructs, the Pearson assessments identified by MTFs in the Request for Information (RFI) were selected for their specific scoring methodologies, normative data, interpretive frameworks, and supporting validation evidence. As a result, vendor proposed alternatives cannot be considered direct replacements when evaluating assessment coverage.

From a clinical perspective, assessments that appear similar on the surface are not necessarily interchangeable. Differences in scale construction, scoring, reference populations, and interpretation guidelines can affect how results are understood and applied in diagnosis, treatment planning, disability evaluations, readiness determinations, and longitudinal patient monitoring. Attempting to replace a requested Pearson assessment with an alternative instrument would change the underlying measure and may limit comparability with historical data and established clinical practices, thus limiting clinical and diagnostic effectiveness. Therefore, continued access to Pearson’s proprietary assessment portfolio is necessary to maintain the assessment capabilities currently identified and utilized across DHA, as there are no clinically acceptable substitutes for these by-name Pearson instruments in the current environment.

6. Efforts to Obtain Competition:

In accordance with RFO Part 10, market research was conducted, which included issuing an RFI that was posted on May 7, 2026, and closed on May 27, 2026, as well as consulting with DHA clinical SMEs. It was determined that only NCS Pearson, Inc. can provide the 26 specific, proprietary psychological assessments required by the agency. At this time, no further effort will be made to obtain competition for these specific items, as NCS Pearson, Inc. is the sole developer, publisher, and intellectual property owner able to provide the exact products and services required.

7. Actions to Increase Competition/Remove or Overcome any Barriers to Competition:

Market research confirms that the overall PAT requirement cannot be fulfilled by a single source. The required psychological assessments are proprietary to each respective publisher with no resellers or external distributors. The agency's acquisition strategy is to prioritize the largest and most critical portion of the requirement first, which is the subject of this justification. Future needs for other publishers' proprietary assessments may be addressed via separate procurement decisions as and when determined necessary by the agency. For this specific requirement, no other immediate actions can be taken to remove barriers because the limiting factor is the strict intellectual property ownership of the required tools by NCS Pearson, Inc, of which they are the sole proprietor. In an attempt to increase competition for potential requirements of these specific items in the future, the DHA will continue to monitor the commercial psychological assessment market, including tracking the emergence of possible platform aggregators, and changes in intellectual property licensing agreements or distribution.

8. Market Research:

Extensive market research was conducted for the FY26 PAT requirement in accordance with RFO Part 10. The research, which included an RFI and consultations with clinical SMEs, confirmed that the commercial market for psychological testing is highly fragmented due to strict intellectual property ownership. The key findings supporting this justification are as follows:

Market Comprised of Multiple Sole-Source Providers: The market research confirmed that "gold standard" clinical assessment tools are the exclusive, copyrighted intellectual property of different publishers. Key vendors like NCS Pearson, PAR, Inc., and WPS operate as sole-source providers for their unique portfolios and do not resell their competitors' core products.

No Single Vendor Solution: As a result of this market structure, no single vendor can meet the entirety of the Government's requirement for all 88 essential assessments. The RFI responses confirmed that no publisher or platform aggregator (e.g., Telehelp, Spring Health, IGNTD) can provide the complete list of required instruments.

Rejection of Functional Equivalents: While some vendors proposed "functionally similar" alternatives for tests they do not publish, DHA's clinical SMEs definitively rejected these claims. The market research concluded that these alternatives could not be considered direct replacements due to significant variations in scoring methodologies, normative data, and clinical application, as detailed further in Section 5.

Prioritization Based on Usage Volume: Historic utilization data indicates that the portfolio of 26 proprietary assessments published by NCS Pearson, Inc. accounts for the vast majority (estimated 60-70%) of the total volume of tests ordered and administered across the DHA enterprise.

Given this proprietary market structure, the only viable acquisition strategy is to prioritize addressing the most critical segments of the requirement directly with the publishers holding the

Psychological Assessment Resources (PAR) and Western Psychological Services (WPS): Both are publishers of required psychological assessments and hold the proprietary rights to their own distinct portfolios (e.g., PAR owns the PAI; WPS owns the ADOS-2). Their RFI responses confirm they can supply their own tests but do not have the intellectual property rights or distribution authority to provide the 26 specific, mission-critical assessments owned exclusively by Pearson. Therefore, they are not a viable source for this particular requirement. These vendors are being considered to fill separate requirements for their own proprietary assessments.

IGNTD, Inc., Spring Health, and TeleHelp 24/7: These vendors operate as platform integrators or service providers, not primary publishers of the required high-acuity assessment tools. Their RFI responses confirm that they own none of the 88 proprietary assessments on the Government's list. They can only host or provide access to third-party tests if the Government separately procures the licenses directly from the publisher (i.e., Pearson). As they cannot sell or provide the required Pearson content, they cannot be considered a source for this acquisition.

In summary, while multiple vendors expressed interest in the overarching PAT requirement, only NCS Pearson, Inc. can fulfill this specific, brand-name-essential requirement.

11. Technical Certification:

I certify the supporting data under my cognizance, which are included in the justification, are accurate and complete to the best of my knowledge and belief.

12. Requirements Certification:

I certify the supporting data under my cognizance, which are included in the justification, are accurate and complete to the best of my knowledge and belief.

13. Legal Review:

I have reviewed this justification and have found it to be legally sufficient.

14. Contracting Officer Determination of Fair and Reasonable Pricing and Certification of Accuracy and Completion.

Fair and Reasonable Cost Determination: I hereby determine the anticipated cost to the Government for this contract action will be fair and reasonable.

Basis for Determination: In accordance with RFO 12.204(a), a price analysis was conducted to determine the reasonableness of the proposed price. Obtaining Certified Cost or Pricing Data is exempt in accordance with RFO 15.403-2(b)(3).

Contracting Officer Certification: I certify this justification is accurate and complete to the best of my knowledge and belief.

Pamela J. Bryerton Contracting Officer

EMS-CD

BRYERTON.P

AMELA.JEAN.

1014923264

Digitally signed by

BRYERTON.PAMELA.JE

AN.1014923264

Date: 2026.08.10 10:11:29 -05'00'

Review and Approval

I have reviewed this justification and find it adequate to support other than full and open competition.

Approval Based on the foregoing justification, I hereby approve the procurement of proprietary Psychological Assessment Tools and access to their proprietary digital delivery platform for on an other than full and open competition basis pursuant to the authority of RFO 6.103-1 Only one responsible source and no other supplies or services will satisfy agency requirements, subject to availability of funds, and provided that the supplies and/or services herein described have otherwise been authorized for acquisition.