JA_TRAIN FY20 (FAR PART 6) Redacted.pdf

Control Number VA-20-00043339

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

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 sole source action is for a firm fixed price (FFP) task order for the Public Health Foundation (PHF) TrainingFinder Real-Time Affiliate Integrated Network (TRAIN) Software as a Service (SaaS) Learning Management System (LMS) solution, and associated maintenance and support with PHF, 1300 L Street, NW, Suite 800, Washington, DC 20005.

3. Description of the Supplies or Services: The Department of Veterans Affairs (VA) Veterans Health Administration (VHA) Employee Education System (EES) Office requires the PHF SaaS/cloud-based TRAIN LMS solution. The mission of VHA’s EES office is to provide cutting-edge learning technologies and teams ready to deliver those technologies. In meeting this goal, EES strives to provide support and guidance to locations worldwide in an effort to effectively utilize web-based medical training as one important component of their overall training plan. EES is leveraging talent and technology to pursue its mission to develop and use advanced learning technologies and methodologies to improve medical education and training for healthcare teams and patients, for the purpose of improving healthcare outcomes.

Through the Mission Act, EES is currently mandated to offer continuing educational material to non-Department medical professionals (community providers). The program is to include education on identifying and treating common mental and physical conditions of Veterans and family members of Veterans, the health care system of VA, and other matters as the Secretary considers appropriate. Additionally, courses must be accredited and provided at no cost to community providers. As courses are developed in VA, they may be accredited in 17 different possible accreditations depending on the course topic and are posted to LMS so that community providers have access to them.

The current VHA TRAIN MISSION Act LMS instance is customized to fulfill VHA’s needs as outlined in the MISSION Act legislation.

The Contractor shall provide project management, a subscription to the PHF TRAIN LMS solution, maintenance, and customer service/administrative support for the SaaS based LMS. Maintenance support includes updates, patches, new versions, and remediation of errors/defects within five business days after error/defect becomes known to the Contractor. Administrative support includes site management (process and list of new VHA-Mission Act courses that are submitted), responses to user support requests for VHA TRAIN Mission Act course issues (related to a user’s issues with accessing and completing a course, accessing “my learning” for a course record, and printing certificates) and sign-in issues (related to a user’s issues with his/her user name, national provider identification number and reconciliation, and password issues).

Administrative support will also include contract assistance with group configuration

Learning Management System Control Number VA-20-00043339 for VA Mission Act changes, posting and updating announcements, documents, discussion boards, or other information posted in the knowledge management areas of VHA TRAIN-Mission Act, and the performance of periodic quality assurance reviews of listing on the VHA TRAIN Mission Act system. Additionally, the SaaS LMS solution shall be Federal Risk and Authorization Management Program (FedRAMP) compliant. The period of performance shall be 12 months from the date of award, with two 12-month option periods.

4. Statutory Authority: The statutory authority permitting other than full and open competition is 41 U.S.C. 3304(a)(1) as implemented by the Federal Acquisition Regulation (FAR) 6.302-1 entitled, “Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.

5. Rationale Supporting Use of Authority Cited Above: Based on Market research as described in Section 8 of this justification, PHF’s TRAIN SaaS is the only LMS solution that can fulfill the Government’s requirements. Specifically, the TRAIN LMS solution is the only LMS that is compatible with VHA’s existing TRAIN platform which delivers non- Mission Act training courses. The current VHA TRAIN MISSION Act LMS platform is configured to fulfill VHA’s needs as outlined in the MISSION Act legislation. Starting over with an implementation of a new LMS would require the same customizations to be performed which would result in a duplication of cost that would not be recovered through competition. It is estimated that the additional and duplicate cost to replace the existing LMS platform and reconfigure the business process is approximately $2M.

Additionally, replacement and or migration and configuration will result in delays of approximately six months. This estimate is based on previous procurement history.

Additionally, extensive marketing and communications with the VA community healthcare partners utilizing the current TRAIN system have already been deployed.

Switching now would make all those efforts moot and would produce substantial confusion within the 600,000-plus-strong provider community. These non-VA providers are currently using Mission Act TRAIN to fulfill requirements mandated by the Mission Act and would lose their current progress in courses as well as their course history.

Changes to the system would adversely impact reporting and access for the thousands of community care providers that are already utilizing the TRAIN system. Additional cost delays will be incurred in addition to the duplicative customization/configuration effort if existing progress data for TRAIN system users is migrated to a new system and VA staff is retrained on the new system. In addition, any other LMS solution will be unable to immediately carry out the Mission Act-mandated collection and reporting of National Provider Identification (NPI) numbers and the communication of completion and NPI data to VA’s existing LMS. This is so, because only PHF can provide support for the SaaS LMS due to proprietary constraints. Only PHF has the access required to support the SaaS LMS. PHF’s TRAIN LMS solution is the only solution that is compatible with the existing TRAIN LMS platform and business processes. An inability to procure the required PHF TRAIN LMS solution would directly and adversely impact Veteran care through these providers, as delays in obtaining needed training would impact their ability to provide care or adequate knowledge for Veteran-specific issues.

6. Efforts to Obtain Competition: Market research was conducted, details of which are in the market research section of this document. This effort did not yield any additional sources that can meet the Government’s requirements. There is no competition anticipated for this acquisition. Additionally, the proposed action will be synopsized on the Federal Business Opportunities Page in accordance with FAR 5.201 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: A Request for Information (RFI) (36C10B20Q0374) was issued on June 11, 2020 and amended on June 25, 2020 to National Aeronautics and Space Administration (NASA) Solutions for Enterprise-Wide Procurement (SEWP) V Government-Wide Acquisition Contract (GWAC) and the Federal Business Opportunities website, to ascertain if there were any other sources that could meet the Government’s requirements. In the RFI, the Government requested capability statements from vendors to identify alternative commercially available LMS solutions and the estimated cost of the alternative solutions.

The RFI closed on June 29, 2020; seven vendors (Kevadiya, Inc., VetsEZ Info, Inc., Agile Six Applications, Gyrus Systems, KPMG, Scallop Software Inc, and TADA Entertainment Group) responded to the RFI with an alternative tool. However, the Government technical representatives determined that, due to proprietary constraints, none of the respondents could provide support on the currently fielded TRAIN software or the proposed SaaS solution. As such, none of the vendors were determined capable. On August 19, 2020 the Government communicated its capability findings via email to the vendors whom responded to the RFI. The Government specifically stated that it has been determined that the proposed LMS is not compatible/interoperable with the current LMS without replacement or significant services including configuration and migration of data which will result in duplicative costs and delays that will adversely impact Veteran care. The Government has not received any further feedback, nor any objection from the respondents.

Furthermore, on June 20, 2020, PHF confirmed that TRAIN subscriptions are not available through its authorized resellers. As a result of the all of the market research results, PHF was determined to be the only authorized source that can provide the VA requirements. A detailed market research report is in the contract file.

9. Other Facts: None.

Approval

In my role as procuring activity Advocate for Competition, based on the foregoing justification, I hereby approve the acquisition of the PHF TRAIN SaaS LMS solution and associated maintenance and support, on an other than full and open competition basis pursuant to the statutory authority cited in Section 4 above, subject to availability of funds, and provided that the services herein described have otherwise been authorized for acquisition.