JA_Laurel Bridge_Redacted.pdf

Control Number VA-21-00079710

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, New Jersey 07724

2. Description of Action: The proposed action is for a firm-fixed price (FFP) delivery order issued under a National Aeronautics and Space Administration (NASA) Solutions for Enterprise-Wide Procurement (SEWP) V Government-Wide Acquisition Contract (GWAC) for brand name Laurel Bridge Professional Digital Imaging and Communications in Medicine (DICOM) Compass Router software and maintenance support, along with associated installation, configuration and deployment services.

3. Description of the Supplies or Services: The Department of Veterans Affairs (VA), Office of Electronic Health Record Modernization (OEHRM) has a requirement for brand name Laurel Bridge Compass Router software to be deployed at 54 VA facilities throughout Veterans Integrated Service Networks (VISN)s 12, 15, 17, 19, 21, 22, 23 and the Fixed Facility Government Approved Laboratory test center to interface and communicate with Cerner. On June 5, 2017, VA announced its decision to replace their current Electronic Health Record (EHR) system, Veterans Health Information System

Technology Architecture (VistA), with Cerner, referred to as VA’s new EHR. The goal of this initiative is to leverage VA’s existing medical and laboratory devices to achieve interoperability with the new EHR. This proposed action supports these VISNs and the test center in their efforts to replace the legacy EHR, VistA, with the new electronic health record, Cerner. Due to clinical impact restraints, the existing Laurel Bridge Compass Router solution cannot be upgraded or configured to integrate with Cerner.

Specifically, clinical analysis efforts revealed that a single Compass Router at each site running dual Vista Imaging and Cerner workflows feeds during the Cerner transition was too high a risk to patient care. Therefore, a mirror copy of the currently deployed Laurel Bridge Compass Router solution is required in order to facilitate the transition from the currently deployed VistA EHR to the new Cerner EHR. This effort shall provide software for all virtually-deployed routers adding HL-7 and DICOM routing with custom filters to allow routing of Modality Work List and images between current imaging modalities, VistA EHR, Radiology Picture Archiving and Communication System (PACS) and new Cerner CareWare MultiMedia (CAMM) VNA. Implementation services, installation of interface software and patient identifier conversion for the multiple downstream radiology systems shall also be provided to include custom translation of the patient’s medical record number (MRN), social security number and other patient-identification-related fields as needed between these various systems so that both the new systems (Cerner CAMM) and the existing systems (Vista, Radiology PACS) can continue to communicate with each other during the transition period. Laurel Bridge will install, test, and validate the new software. The period of performance for this effort is 36 months from award consisting of a staggered delivery, installation and configuration schedule per facility.

Laurel Bridge Software and Services Control Number VA-21-00079710

4. Statutory Authority: Pursuant to Federal Acquisition Regulation (FAR) 16.505(a)(4), the following brand name requirement is being justified and approved as an exception to fair opportunity under the statutory authority of Section 41 U.S.C. 4106(c)(2) as implemented by 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: Based on market research described in section eight of this justification, it was determined that limited competition is available among resellers for the required brand name Laurel Bridge software and services. Only Laurel Bridge software and associated installation and configuration services are capable of meeting VA’s requirements for this effort. Currently, Laurel Bridge Compass Routers are utilized across VHA for DICOM/HL7 routing via VistA Imaging. In order achieve this routing functionality within VistA, extensive design and configuration efforts have taken place over the past 10 years to generate the necessary interfaces with multiple dependent applications that make up the VistA Imaging infrastructure as well as creating the necessary workflow designs and rulesets thereby enabling the images contained on the compass routers to be routed between current imaging modalities including VistA EMR and Radiology PACS. Additionally, current

VistA Imaging workflows/business processes, including Disaster Recovery procedures, are hardwired for use of Laurel Bridge throughout the country. As stated in Section 3, the existing Laurel Bridge Compass Router solution cannot be upgraded or configured to integrate with Cerner due to clinical impact restraints and patient safety, and therefore, as part of the ongoing Cerner implementation, VA requires a mirror copy of the existing Laurel Bridge Compass router solution throughout all VHA facilities. As a result, Cerner and OEHRM developed an approved interface specific to the Laurel Bridge Compass Router as VA’s existing compass router solution for VistA Imaging.

This interface was required and utilized for the deployment of the mirror Laurel Bridge Compass Router software for VISNs 11, 10 and 20 which were the first VISNs to begin deploying the new EHR. To implement any other brand Compass Router solution would require VA and, in turn, Cerner to redesign the already approved and implemented Cerner Interface Configuration/Control Document (ICD). This custom interface includes Compass Router dependent interfaces and business workflows specific to Laurel Bridge that would have to be redesigned and implemented to support another brand name Compass Router solution which would take at a minimum of six months to complete at an estimated cost of $1.5M. This estimate is based on the average historical cost and timeframe for Cerner to develop an approved interface for new hardware/software. Additionally, a transition to any other brand Compass Router solution to integrate with Cerner would require the redesign of existing interfaces with approximately 30 dependent applications, such as Powerscribe, Carestream PACS, and Philips Intellispace, and the associated workflows and rulesets that are already in place as part of the fully integrated Laurel Bridge Compass router solution currently being utilized across VHA. Any such replacement or new implementation effort is estimated to cost $9M and take at least three years to complete. This estimate is based on the average historical cost and timeframe to develop interfaces with applications supporting Vista Imaging. As such, the procurement of an alternate brand compass router software solution rather than deploying a mirror copy of the existing Laurel Bridge solution would result in substantial duplication of costs and delivery delays. In addition, it would add unnecessary complexity and duplicative activities for VA’s medical facilities and imaging staff who would be required to implement new workflow designs and rulesets thereby disrupting the existing clinical workflow and compromising patient care.

Further, no other source is capable of providing the required maintenance support, installation, configuration and deployment services as access to Laurel Bridge’s proprietary source code is required in order to ensure the services provided to the software are properly configured. Failure to acquire Laurel Bridge Compass Routers would leave VHA without the ability to transition from the VistA VNA to Cerner VNA uninterrupted or with minimal interruption for OEHRM operations which directly affects patient care and safety.

6. Efforts to Obtain Competition: Market research was conducted, details of which are in section 8 of this justification. This effort did not yield any additional sources that can meet the Government's requirements. However, the undersigned VA technical representative determined that limited competition is available among resellers for brand name Laurel Bridge Compass Router software, maintenance support, installation, configuration and deployment services. In accordance with FAR 16.505(a)(4)(iii)(A)(1), this justification will be provided with the solicitation to all appropriate NASA SEWP V

GWAC holders. Furthermore, in accordance with FAR 5.301, 16.505(b)(2)(ii)(D), and 16.505(a)(4)(iii), the award notice for this action will be synopsized on the Contracting Opportunities website and this justification will be made publicly available within 14 days of award.

7. Actions to Increase Competition: The Government will continue to conduct market research to ascertain if there are changes in the marketplace that would enable future actions to be competed.

8. Market Research: The Government’s technical experts conducted market research in April and May of 2021 by reviewing alternate products to Laurel Bridge Compass Router, which consisted of Radiology Information System broker and DICOM Systems

Router for Image routing. While similar software solutions from alternative manufacturers exist, they are unable to emulate existing workflow designs and rulesets and would require extensive resign efforts in order to develop the necessary interfaces with both Cerner and the multitude of dependent applications currently supporting VA’s imaging infrastructure. Therefore, only a mirror copy of the existing Laurel Bridge compass router solution can meet VA’s requirements for this effort and avoid both the duplicative time and cost, as well as any disruption to critical clinical workflows as outlined in Section 5 of this document. Further, the market research confirmed that due to the proprietary nature of the Laurel Bridge compass router solution, no other source can provide the required maintenance support, installation, configuration and deployment services. Based on all of these market research efforts, the Government’s technical experts have determined that only Laurel Bridge brand name software and services can meet all of VA’s needs.

Further market research was conducted in August 2021 by utilizing the NASA SEWP Provider Lookup which revealed three NASA SEWP GWAC holders, all of which are

Service Disabled Veteran Owned Small Businesses (SDVOSBs), that are resellers of brand name Laurel Bridge products and services. However, the requirements for this effort include brand name Laurel Bridge installation, configuration and deployment services that must be performed by Laurel Bridge personnel due to proprietary constraints as detailed in Section 5. As such, no SDVOSB or small business concern would be able to comply with the limitations on subcontracting requirements if the solicitation were to be issued as an SDVOSB or small business set-aside. As such, and considering the required brand name Laurel Bridge products and services are available from multiple SDVOSB resellers on NASA SEWP V such that adequate competition exists on this vehicle, the solicitation will be issued for competition among all NASA SEWP V contract holders in Groups B, C and D under North American Industry

Classification System (NAICS) code 541519, and will not be set aside.

9. Other Facts: None.