JA SEP PM Services - Redacted.pdf

DEPARTMENT OF VETERANS AFFAIRS

Office of Procurement, Acquisition and Logistics (OPAL)

Strategic Acquisition Center (SAC) 5202 Presidents Ct, Suite 103

Frederick, MD 21703

LIMITED-SOURCES JUSTIFICATION

1. Identification of the agency and the contracting activity, and specific identification of the document as “Limited-Sources Justification."

This justification is executed by the Strategic Acquisition Center – Frederick (SAC-F), on behalf of the Department of Veterans Affairs (VA), Veterans Health Administration (VHA) Healthcare Environmental and Facilities Programs (HEFP) Special Engineering Projects (SEP).

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

VA intends to negotiate a sole-source task order with Booz Allen Hamilton (BAH) for SEP Program Management (PM) Services currently being provided under Blanket Purchase Order (BPA): 36C10X23A0022, Call Order: 36C10X25F0037. The current order has a Period of Performance (PoP) ending July 01, 2026. An extension to the current BPA Order is not permitted due to surpassing the BPA limit threshold.

The initial plan for the BPA was developed in 2022 with traditional contractual support of services under the Healthcare Environment and Facilities Program (HEFP) umbrella. However, in 2024, two major VHA major initiatives which were determined to be within scope began to award unplanned call orders under the BPA. These two major initiatives are the Electronic Health Record Management (EHRM) and the Office of Supply Chain Management implementation of a new standardized computerized management maintenance system

(CMMS).

Once these two other major initiatives were brought under the umbrella of the HEFP BPA, the required projects very quickly exceeded the original acquisition plan ceiling amount of $58,685,141.45 (by the end of Option Period 1). According to the station the two major VHA initiatives account for 75% of the BPA cost with the remainder being in accordance with the acquisition plan.

Therefore, contracting determined that the BPA quickly reached its limit threshold prior to establishing a new requirement, which resulted in a delayed acquisition transition.

This justification supports approval to award a short-term task order to Booz Allen Hamilton (BAH) under General Services Administration (GSA) contract 47QREA21D0001. The proposed period of performance is July 2, 2026 – September 30, 2026. This task order will provide Program Management Services supporting Healthcare Environment Facilities Programs (HEFP) and Electronic Health Record Modernization (EHRM) Facility Infrastructure Deployment Management.

The short-term bridge is necessary to prevent a gap in services. A follow-on requirement covering these services is in progress with anticipated award of July 24, 2026, well after the current period of performance expires on July 1, 2026. This bridge task order will ensure continuity of services during that interim period.

Limited-Sources Justification- Special Engineering Projects Program Management Services

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

The purpose of this sole-source task order (estimated at ) is to provide 3 months of services identical to those for the HEFP Program Management Services BPA Order that will end July 1, 2026. These services support SEP’s programmatic implementation and oversight of VHA’s strategic non-recurring maintenance infrastructure initiative for Electronic Health Record Modernization (EHRM) and other targeted infrastructure initiatives by:

establishing and performing targeted infrastructure project oversight and performance monitoring, monitoring and assessing cradle-to-grave infrastructure improvement projects to ensure alignment with prescribed schedules, providing consultation and education to VHA engineering field staff on program requirements including in-person or virtual training, and facilitating collaborative meetings—virtually and on-site—with project stakeholders to resolve capital project issues.

4. The authority and supporting rationale (see GSAM 538.7104-3 Sole source justifications - (iii)) and, if applicable, a demonstration of the proposed contractor’s unique qualifications to provide the required supply or service.

Authority: This sole-source task order will be placed against GSA contract 47QREA21D0001.

The authority to limit sources under GSAM 538.7104-3(b)(iii) applies because: “The order should be issued on a sole source basis in the interest of economy and efficiency because it is a logical follow-on to an FSS order already issued on a competitive basis.”

Supporting rationale: A lapse in contractor coverage would cause unacceptable delays and disruption to EHRM NRM (Non-Recurring Maintenance) program execution and congressional reporting commitments. It would also introduce material schedule risk, loss of project continuity, data/reporting degradation, and increased costs during an accelerated EHR deployment restart.

Proposed contractor’s unique qualifications: BAH is the incumbent BPA holder actively performing the specialized program management support for 1,099+ EHRM NRM projects (~$5.8B) across VA medical facilities. Their embedded Deployment Managers (DMs) maintain the most detailed, site level project perspective and readiness milestone tracking required by Electronic Health Record Modernization Integration Office (EHRM-IO) to plan the national GoLive wave schedule. The role demands a hybrid skill set (design & construction + telecom + capital program PM) that has proven challenging to staff with full-time employees and is more cost effective on a contract, time limited basis. The proposed contractor has standing processes, tools, and deliverables aligned to HEFP SEP (e.g., project inventory management, risk dashboards, VISN level oversight artifacts), enabling uninterrupted continuity for critical reporting and governance.

5. A determination by the ordering activity contracting officer that the order represents the best value consistent with GSAM 538.7104-3.

GSA has already determined the prices of supplies and fixed-price services, and rates for services offered at hourly rates, under schedule contracts to be fair and reasonable in accordance with FAR 8.404. Therefore, the contracting officer is not required to make a separate determination of fair and reasonable pricing, except for a price evaluation as required by GSAR 538.7102-2(d)(2) and 538.7104-2(a)(3). By placing an order against a schedule contract using the procedures in GSAM 538.7104-3, the contracting officer has concluded that the order represents the best value and results in the lowest overall cost alternative (considering price, special features, administrative costs, etc.) to meet the Government ’s needs. Although GSA has already negotiated fair and reasonable pricing, additional discounts will be sought before placing an order (see GSAM 538.7104-3).

6. A description of the market research conducted among schedule holders and the results or a statement of the reason market research was not conducted.

Market research was conducted and documented in the Market Research Report and Acquisition Strategy Memorandum. No SDVOSB, VOSB, small businesses, or other large businesses can provide the continuation of required services during this limited period of performance. Through the search, the CO determined that Booz Allen Hamilton, Inc. (BAH) was the only viable contractor that could offer these services over this specific three-month duration of time to avoid a break in service.

Additionally, HEFP SEP previously analyzed the potential addition of full-time employees vs.

contract staffing and twice pursued internal approvals to hire; neither proposal was approved.

The skills mix and scale (22 positions; nationwide, VISN aligned) make rapid staffing with qualified federal personnel unlikely in the needed timeframe. The program determined contract support is more cost effective and operationally flexible (scale up/down with project load) than FTEE, and that continuing with the incumbent preserves specialized knowledge and data/reporting continuity until the replacement contract is awarded.

7. Any other facts supporting the justification.

Congressional reporting: The support enables VA to meet quarterly reporting requirements under Section 503 of the Veterans Benefits and Transition Act of 2018 and Section 2 of the VA Electronic Health Record Transparency Act of 2021 (EHRM oversight). Disruption to DM activities would risk non-compliance, schedule delays, and cost growth.

Program scale and progress: HEFP SEP has obligated approximately $2.8B and completed approximately 459 projects to date, with 1,557 projects identified; continuity preserves momentum during the accelerated restart of Oracle Health deployment.

8. A statement of the actions, if any, the agency may take to remove or overcome any barriers that led to the restricted consideration before any subsequent acquisition for the supplies or services is made.

All future requirements will be evaluated on a case-by-case basis. The Government intends to conduct a full and open competitive acquisition to replace the current task order. This interim sole-source award to BAH is intended solely to provide continuity of critical services during the transition period and to allow sufficient time for the competitive acquisition and orderly phase-in/phase-out activities, thereby preventing any disruption in service.

9. Evidence that any supporting data that is the responsibility of technical or requirements personnel (e.g., verifying the Government ’s minimum needs or requirements or other rationale for limited sources) and which form a basis for the justification have been certified as complete and accurate by the technical or requirements personnel.

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

Signature: ________________________________ Date: ____________

Michael Vulpis Healthcare Engineer | COR 3 Healthcare Environment and Facilities Programs (HEFP/10NA5)

10.

is accurate

Pursuant to GSAM 538.7104-3, I certify that this justification is accurate and complete to the best of my knowledge and belief.

Dylan Nolz Contracting Officer Strategic Acquisition Center- Frederick (SAC-F)

Approval

In my role as Contracting Activity Competition Advocate, based on the foregoing justification, I hereby approve this acquisition on an “sole source basis” basis pursuant to the statutory authority cited in paragraph four above, subject to availability of funds, and provided that the services herein described have otherwise been authorized for acquisition. As this action does not exceed $15M, the certification below required by GSAM 506.304(d)(1) serves as approval.

Efrain J. Fernandez Director of Contracts Procuring Activity Advocate for Competition (SAC Frederick) Strategic Acquisition Center

MICHAEL VULPIS

Digitally signed by MICHAEL

VULPIS

Date: 2026.05.19 10:59:22 -04'00'

DYLAN NOLZ Digitally signed by DYLAN NOLZ Date: 2026.05.19 11:04:41 -04'00'

EFRAIN

FERNANDEZ

Digitally signed by EFRAIN

FERNANDEZ

Date: 2026.05.19 11:19:39 -04'00'