JA_PTEMS_Extension 08.01.24 Redacted.pdf

PTEMS Total Task Order Value Increase Control Number VA-24-00009744

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, NJ 07724

2. Description of Action: The proposed sole source action is for a modification to the Firm-Fixed-Price (FFP) Task Order (TO) 36C10B21N10150056 titled “Product and Technology Ecosystem Management Services (PTEMS)” issued under Transformation Twenty-One Total Technology Next Generation (T4NG) Contract VA118-16 -D-1015 with Liberty IT Solutions, LLC., which has since been acquired by Booz Allen Hamilton Inc., (referred to herein as BAH) 8283 Greensboro Drive, McLean, VA 22102. On January 8, 2021, the TO was awarded with a 12-month Base Period beginning on January 8, 2021, with four (4) 12-month Option Periods and eight (8) Optional Tasks.

On January 8, 2024, the third option period was exercised and currently expires on January 7, 2025. Subsequently, a Justification for an Exception to Fair Opportunity (J&A) was executed on April 25, 2024 to increase the total TO value for the current PTEMS T4NG TO to serve as a bridge of support until a new competitive TO was awarded. VA is still in the process of competitively awarding a new TO; however, the awarded PTEMS J&A did not cover the efforts that will face a gap in service beyond July 2024 and the PTEMS TO will reach its total TO value by mid-August 2024. The purpose of this justification is to request another increase of the total TO value for the current PTEMS T4NG TO so that active program efforts that must continue through the end of the Option Period (January 7, 2025) will not experience a gap in service. No increase to the period of performance is required. This total task order value increase will serve as a bridge of support until a new competitive TO is awarded/transitioned to a new potential vendor. It will take 60 days to onboard the new awardee and then up to 90 days to transition all projects that had already begun on the existing contract.

3. Description of the Supplies or Services: The scope of the PTEMS TO is to enable the delivery of enterprise technology-agnostic capabilities across a broad range of Digital Transformation Center (DTC) Ecosystem solutions for business transformation and digital modernization while mitigating technology debt from developing and maintaining enterprise or monolithic systems. This includes Software-as-a-Service (SaaS), Platform-as-a-Service (PaaS), and emerging technology implementation, lifecycle management and delivery, systems/software engineering, web services development, software release and change management services, data migration and integration including application programming interface (API) development, configuration and development, and operations and maintenance support.

Due to unanticipated events that occurred from the previous extension to award and from the technical nature and criticality of this task order, mission-critical system requirements need to be addressed via another extension. The overall support for VA is critical to ensure continued sustainment services, cybersecurity support, and mission-critical healthcare modernization support services, currently supporting approximately

74 on-going efforts which were critical to start and must get to a completed state for transition to be successful. VA anticipated these 74 efforts to be executed on the competitive TO but because that award has been delayed, VA must continue them via this action due to their criticality. All efforts will transition at various times prior to January 7, 2025 Each effort will be completed based on their technical need and ability to get to a completed state prior to transition. PTEMS is critical to VA’s digital modernization by leveraging a technology-agnostic acquisition strategy that scales across the enterprise and helps VA customers accelerate business outcomes by leveraging the benefits of the cloud ‘as a service’ marketplace and optimizing technology investments through scalability and reusability. DTC requires that the current services outlined in Section 5 below via Optional Task Three (CLIN 7001) and Optional Task Four (CLIN 8001), under TO 36C10B21N10150056, continue without interruption to prevent a negative impact to sustainment of mission-critical applications, VA’s cybersecurity posture, and delivery of healthcare and benefits services to the nation’s Veterans. The total estimated value of the proposed action is XXXXXXXXX. This total TO value increase will allow these critical services to continue from August 2024, through January 7, 2025. Any new awardee will require up to 60 days to onboard and then start to work on new or continue projects. Once a project is started or extended, from that point it will take an additional 90 days to complete transition, to allow projects to get to a completed state for the successful transition. Once the new awardee has completed the onboarding process all new projects, that will begin and/or continue, will go through the new awardee.

4. Statutory Authority: The statutory authority permitting an exception to fair opportunity is Section 41 U.S.C. 4106(c)(2), as implemented by the Federal Acquisition Regulation (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: The proposed source for this action is BAH, 8283 Greensboro Drive, McLean, VA 22102. BAH is the Contractor on the PTEMS TO, which is currently in Option Period Three, expiring January 7, 2025. VA is in the process of competitively awarding a new TO which would encompass all the services detailed in this justification.

Due to unanticipated events leading up to the new competitive contract award (previously targeted award June 4, 2024; now targeting July 31, 2024), there are active efforts facing a gap in service between August 2024-January 2025 that were not included in the previous J&A. These efforts must be continued via this second J&A action and various requirements must be continued to a logical point of completion, prior to the transition to a new awardee. Now that the new competitive contract has been awarded on July 31, 2024, this J&A action enables critical ongoing work to continue through the end of the current TO's PoP end date, which allows for the required 60 days to onboard a new potential vendor, as well as 90 days to transition all projects, intake new requirements generate LOEs, and for the government to obtain CIO approvals of new LOEs and process them for award on the new competitive contract.

To further elaborate on the 90-day transition period, the requirements development for the competitive TO began in the fourth quarter of fiscal year (FY) 2023, with additional requirements refinement throughout the first quarter of FY 2024. The solicitation was released on April 9, 2024, with award on July 31, 2024. Once the competitive task order is awarded, there is also a requirement for 90 days of overlap to support a seamless transition of the services to a new vendor. Without a proper transition, there would be a break in service. For these reasons, VA requires a modification to increase the total TO value so that these critical services can continue beyond July 31, 2024, which is the date through which the previous PTEMS TO JA covered continuation efforts. A 90-day transition period is critical to ensure a seamless handoff to a new potential vendor as there are currently 74 active projects on the current PTEMS TO. In order to properly transition activities to the new competitive TO, it is critical to address technical and functional requirements spanning functional, compliance, non-functional, and visualization aspects to include End-User Requirements and Research, Mock-Ups, Wireframes, Prototypes, Screen Flows and Navigation, Taxonomy and Information Architecture, Business Rules and Reporting, Configuration and Change Management, Acceptance Criteria and Testing Scenarios, and Measurable Success Metrics to comply with critical VA requirements that include Section 508, FedRAMP Authorization, Authority to Operate (ATO), Privacy Impact Assessments, and Interoperability standards.

This 90-day transition is required for all of the following critical knowledge transfer activities, for on-boarding to occur, and for the current efforts to be sustained:

o Some projects have mandates for decommissioning legacy systems and firm requirements for the new system to go-live. A new vendor would not only have to learn the new system but also be able to train thousands of users on how to use the system prior to go-live (training and change management) plus perform data migration of critical data.

o The PTEMS BAH team is currently working to integrate systems with other agency’s authoritative data sources. The PTEMS BAH team has active service requests in a queue with other agencies for critical integrations that would need to be re-submitted and the requirements process restarted if another vendor were to take over.

o A new vendor would need to become familiar with the VA Lighthouse API capabilities in order to ensure current service level agreements continue to be met, avoiding degradation to APIs and Veterans not being able to access their information.

o A new vendor must learn all existing DTC processes and procedures for building and releasing applications within the ecosystem.

o A new vendor must become familiar with the Veterans Crisis Line (VCL) Medora system and VA Health Connect (VAHC) system to perform the on-call 24x7 support for both programs.

o A new vendor must obtain access to all of the applicable environments in order to learn all of the respective systems and become experts to support issues that arise in production.

o A new vendor must be able to functionally administer and monitor multiple platforms and tools (Medora, Lighthouse, Salesforce, VA.gov, Centralized Data Repository, DTC Integration Platform, etc.).

o A new vendor must take ownership of numerous projects that are in the middle of enhancements development that have not yet been released and then perform the subsequent testing and release process to push those features into production.

o A new vendor must obtain the knowledge on existing project backlogs and gain technical understanding of each user story and associated priorities.

BAH is currently performing all the sustainment services, cybersecurity support, and mission-critical healthcare modernization support services, as described in Section 3.

Without this continuation of services, VA faces a gap in service for the critical sustainment, cybersecurity, and modernization support provided under the current TO, which would negatively impact VA’s mission-critical sustainment support, cybersecurity posture, and digital modernization efforts while the new TO is being competed and awarded. This total TO value increase will ensure continuity of sustainment support for mission-critical applications (such as Medora, used by the Veteran Crisis Line), VA’s cybersecurity compliance support, digital modernization of healthcare related applications, as well as continued compliance with Federal mandates and mandatory Federal reporting and a seamless transition to a new vendor. Any interruption of these tasks executed by the BAH team supporting VA would immediately result in direct impacts to millions of Veterans and associated VA mission-critical programs such as the Veterans Crisis Line, the Veteran Homelessness Program, VA 24x7x365 healthcare services, Tele-Emergency Care, VA.gov, Provider Connect, Lung Cancer Screening, the API Lighthouse Program which serves over 118,000 Veterans, Community Care Scheduling, Veteran Billing System, National Call Centers (NCCs), Clinical Patient Assessment Calculators, Veteran-Home Intake Contact Center, Eligibility and Enrollment, Veteran Whole Health Mobile App, the Center for Care and Payment Innovation, the Women Veteran Call Center (WVCC), Identity Governance and Administration, Chief Information Security Officer (CISO) Security Support, and many other systems/programs, which would cause degradation of systems, services, and applications VA-wide and would severely and negatively affect VA’s ability to provide suicide crisis support, homelessness benefits, critical healthcare to our Veterans, benefits eligibility services, benefits processing, payments to Veterans, and essential security protection/response support. Only current/active program efforts that are facing a gap in service will be continued under this justification; no new projects/program efforts will be executed under this justification. Any new projects/program efforts will be executed on the new competitive TO (or an alternate acquisition vehicle).

Due to the demand for the PTEMS 1.0 TO, much of which was driven by VA’s emergent COVID-19 response requirements that could not be foreseen, the PTEMS 1.0 total TO value was utilized nearly two (2) years earlier than originally expected. Additionally, due to the continued emerging demand of new business customers, including recent PACT Act related requirements that were previously unknown, as well as the size and complexity of the PTEMS 2.0 requirements, the acquisition package needed thorough development to ensure all applicable requirements were captured in their totality. As such, the recompete TO will not be awarded prior to the projected date when the

PTEMS total TO value will be reached, which would result in a gap of critically required services. Loss of BAH support during this gap will result in significant direct impacts to patient care, system degradation of mission-critical applications, such as Medora (impacting VA’s ability to assist suicidal Veterans) and failing to comply with Federal and VA cybersecurity mandates.

Based on market research which can be found in Section 8 of this document, it was determined that BAH remains the only responsible source capable of satisfying PTEMS requirements within the required timeframe, until a follow-on TO is awarded and an orderly transition can occur. No other source can provide the aforementioned support or continuity of services required as a result of the delays in the award and execution of the new TO. This total TO value increase will provide for the timely continuance of this critically needed support to ensure there is no gap in service, where this continuance is crucial to ensuring continued daily operations and sustainment of mission-critical VA applications, cybersecurity posture, and digital modernization.

Additionally, there are critical custom components and applications which require elevated privileges that rely upon the technical expertise and VA specific knowledge of PTEMS BAH contractors to maintain functionality and provide maintenance. Any impact to the level of support for these applications would result in system degradation for mission-critical applications, like Medora (impacting VA’s ability to assist suicidal Veterans), and applications that directly impact Veteran patient care, such as VAHC CRM and Tele-EC. It would also result in VA failing to comply with Federal and VA cybersecurity mandates. Over the years, PTEMS developed very specific methods and applications to maintain operations and meet the VA mission. A new vendor, without intimate VA knowledge, would not be able to correctly operate or maintain the applications (e.g.: Medora, VAHC CRM, Tele-EC, Provider Connect, Lighthouse) or apply the appropriate processes/procedures until after a lengthy timeframe, which would have cascading negative effects across VA, resulting in potential adversarial cyber infiltration, loss of VA data, and significant impacts to patient care. Interruption to any of the above mentioned critical operational activities and essential service tasks executed under the existing TO with BAH would immediately impact operations of 74 active programs. Any source, other than BAH, would require a ramp-up period of 60 days to onboard and 90 days to transition appropriate staff, develop a PTEMS intake/level of effort process, conduct site visits to fully understand end user processes, understand the backend interdependencies with VA authoritative data sources, obtain necessary permissions and access to VA systems, recruit and train staff with the appropriate skill sets, and properly transition all required tasks and workloads. This 60-day onboarding time period is based on lessons learned and past experience on this effort in addition to similar OIT support contracts. Failure of DTC to provide all current functions until such a time as a follow-on TO and an orderly and complete transition can occur between VA, BAH, and the new TO awardee, would cause undue negative impacts to VA such as interruptions to patient care, Federal mandates being missed or not adhered to, and cyber threats going unmitigated, all of which would be unacceptable to VA. Therefore, VA needs to increase the total TO value to ensure critical services are continued until a competitive award is finalized. The total TO value increase accounts for the time needed to have a new TO awarded as well as 60 days to onboard personnel and 90 days needed for the transition period. The estimated total TO value increase amount was determined by utilizing a program-specific total cost of ownership model level of effort based on previous and existing requirements.

6. Efforts to Obtain Competition: Market research was conducted, the details of which are in Section 8 of this document. This effort did not yield any additional potential sources that could provide the seamless support while the competitive procurement is being solicited and awarded. Due to the critical need for continuity of support, there is no competition for this acquisition. In accordance with FAR 5.301 and 16.505(b)(2)(ii)(D), the award notice for this action will be synopsized on the Contracting Opportunities website, SAM.gov, and the justification will be made publicly available within 14 days of award.

7. Actions to Increase Competition: No barriers to future competition are anticipated. VA awarded a new competitive task order on July 31, 2024, and future acquisitions will be awarded on a competitive basis.

8. Market Research: Throughout FY24 Q2-Q4, DTC Subject matter experts regularly reviewed industry trade publications and conducted internet research to ascertain what vendors might be capable of providing the required PTEMS support. DTC subject matter experts conducted market research of the following companies: BAH, Cognosante MVH, LLC, Accenture Federal Services, Huron Consulting Services, LLC, TISTA, Acumen Solutions, Inc., and Deloitte Consulting, LLP. From these research efforts, the Government’s technical experts determined that only the current technical support team from BAH can meet VA’s immediate requirements for continued sustainment, cybersecurity support, and digital modernization support. While DTC subject matter experts concede that other vendors may have the general capabilities to perform the current PTEMS requirements, none other than BAH could meet the immediate requirements in a seamless manner as detailed above in Section 5 of this justification.

9. Other Facts: None.