JA VISN 10 Medicom Contract-Final_Redacted.pdf

Medicom ImageX Software Subscriptions and Support VA-25-00090689

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:

Based on market research, as described in section 8 of this justification, it was determined that no competition is available for this procurement. No other products are capable of meeting all the Government’s requirements. Medicom’s ImageX with Assistant Edition software deploys a proprietary peer-to-peer network which enables the seamless and secure sharing of radiology information, including reports and images through encrypted conduits between providers on the fully federated health information network. Medicom is the only vendor to facilitate bi-directional exchange of medical images and diagnostic reports among all VISNs. Medicom will ensure the VA can continue to save diagnostic images to the current systems and pathways, and both authenticate and validate bi-directional, electronic exchange of DICOM images, radiology reports, and radiology images. Medicom will allow Imaging Services to search the commercial imaging providers located within the VISNs, locate prior medical images and reports, and retrieve them to VA where they can be inducted to VA systems.

Medicom’s ImageX is already in place across 15 Veterans Administration Health Care Systems and VA Medical Centers across 11 states for clinical image data exchange, including three sites within VISN 10. If VA were to switch vendors from Medicom, VA facilities would have to remove existing services from complete sites and re-engage the legal teams of all sites to interface with a new vendor’s system. Medicom facilitates the creation of Business Associate Agreements (BAAs) between VA Medical Centers and each individual private sector facility or healthcare system. This is a highly resource-intensive process. The BAAs specify procedures for the secure handling of Personally Identifiable Information (PII), outline security requirements, and set expectations for reporting any violations related to HIPAA, the Privacy Act, or other concerns that may arise concerning the transmission of images or other patient medical data. If VA transitions away from Medicom, those BAAs would be voided and effectively restart the process of brokering agreements between facilities. There are currently 278 connections across the current installations of Medicom in VISN 10. This number includes prominent institutions such as the Cleveland Clinic, Indiana University Health, MetroHealth System, University of Cincinnati, Michigan Medicine, and many others. All of which underwent information-security, legal, contracting, and implementation processes to establish these connections. The estimate to rebuild these BAAs would take more than four years with an estimated cost over $5 million. These are additional costs that would not be recovered through competition. These estimates are based on previous acquisition history.

Additionally, Medicom ImageX is the only software approved through VA OIT Technical Reference Model (VA TRM). Compliance with VA TRM is achieved by using only technologies and standards that are listed as approved for use. Moreover, the Mission Act has enabled Veterans to seek diagnostic imaging services outside of VA. If VA loses Medicom’s ImageX and support services, digital image sharing would be unavailable. VA would have to use compact disks (CDs) and digital video disks (DVDs) that are hand-carried or mailed to and from VA facilities at the completion of a diagnostic test, ultimately creating bottlenecks and delays in the continuity of Veteran care. Delays in archiving images can also cause misplaced CDs or DVDs, repeated examinations, and “unreadable” images that are incompatible with some software in VA.

All adverse factors add to unnecessary health risks of Veterans and additional costs to VA. Therefore, a peer-to-peer network that provides VA the ability to electronically exchange data within the community is required. Medicom Imagex is the only software able to meet these unique needs for VA.

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 Contracting Opportunities Page in accordance with FAR 5.201. Any proposals that are received shall be evaluated.

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. VHA and VISN 10 will continue to research and monitor whether there are emerging products that enter the marketplace that are interoperable and compatible with VA community facilities, platforms, services, and software.

8. Market Research:

The Government’s technical experts conducted market research from January 2025 through March 2025 on similar products to Medicom’s ImageX. Specifically, the Government’s technical experts conducted web-based research on other software that could meet VA’s requirements. For instance, Intelerad and Nuance Powershare were found to provide similar functionality for medical image sharing. However, these products do not provide all the necessary functionality required by the VA. The software offered by Intelerad and Nuance do not provide the capability for storage within VA systems as they utilize cloud-based platforms that are not able to seamlessly connect to VA diagnostic and record keeping systems. Furthermore, Intelerad’s software does not provide the ability to exchange other health pertinent information and reports outside of Radiology.

Medicom is the only fully federated health information exchange provider that connects disparate silos or health information to be easily and securely searched and shared. On August 21, 2025, Medicom confirmed they are the only source for Medicom ImageX software, support services, maintenance and training, and Medicom does not have any authorized distributor or resellers. Based on these market research efforts, the Government Technical expert has determined that only Medicom Technologies can meet the Government’s needs.

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 Medicom’s ImageX with Assistant Edition software and supporting services, maintenance, and training on an other than full and open competition basis pursuant to the authority cited in Section 4 above, subject to availability of funds, and provided that the property and services herein described have otherwise been authorized for acquisition.

Date Advocate for Competition Technology Acquisition Center Office of Procurement, Acquisition, and Logistics Department of Veterans Affairs

9/5/2025