JA Ft Polk Buyout Other Than Full and Open Competition under RFO Part 6.pdf
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- Attached to
- Ft Polk Printers Buyout
- Solicitation number
- JA26-0749
- Issued by
-
Defense Health Agency
About this file
This is a Justification and Approval (J&A) document for a sole source contract to purchase 118 Hewlett Packard multi-purpose printers from MinBurn Technology Group for Fort Polk in support of the Defense Health Agency (DHA).
The procurement involves a one-time equipment buyout of the current fleet of HP printers currently leased under contract HT001521F0070, which expires July 8, 2026. The fleet comprises 87 HP Color LaserJet Enterprise Flow MFP M681z units, 5 HP LaserJet Enterprise Flow MFP M635z units, 21 HP LaserJet Enterprise Flow MFP M528c units, and 5 HP Color LaserJet Enterprise Flow MFP M578c units, with all models being TAA compliant. The buyout is justified under RFO 6.103-1(c)(2)(i) based on substantial duplication of cost that cannot be recovered through competition. The J&A presents three options for maintaining printer support: Option 1 (re-compete as lease and support at approximately $1.7 million), Option 2 (purchase new printers at approximately $654,766.95 plus support costs), and Option 3 (buyout current fleet from MinBurn and compete the support separately). The recommended Option 3 represents only a fraction of the costs for the alternative approaches. Following the sole source buyout from MinBurn, a separate competitive procurement for base-plus-four annual printer support will be conducted as a Service-Disabled Veteran Owned Small Business (SDVOSB) set aside on DHA's NASA SEWP Printing Imaging Catalog, with six qualified SDVOSB contractors identified as capable of providing HP printer support. The Contracting Officer approved the procurement on an exception to fair opportunity basis, with FY26 procurement funding allocated for the one-time equipment purchase.
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Text version
CUI
Control Number: 26-0749
Controlled by: Defense Health Agency (DHA)
Controlled by: USAMRAA
CUI Category(ies): Source Selection
Limited Dissemination Control: (Insert FEDCON or FED
Only)
POC: Peichang Wang
Source Selection Information - See FAR 2.101 and 3.104-4
1 OCT 2024
Justification and Approval (J&A) for Other than Full and Open Competition
Revolutionary Federal Acquisition Regulation (FAR) Overhaul (RFO) Parts 6 and 12
Implemented by Class Deviation 2026-O0017, Revision 1
1. Identification of the Agency and Contracting Activity: Defense Health Agency (DHA), DHA
Contracting Activity (DHACA), Professional Services (PS) – Contracting Division (CD).
2. Nature and/or Description of Action being Approved: Approval is requested for a Sole Source
Firm-Fixed Price (FFP) contract, in accordance with RFO 6.103-1(c)(2)(i): “substantial duplication of cost to the Government that is not expected to be recovered through competition,” to buy-out 118 Hewlett
Packard (HP) multi-purpose printers currently leased from MinBurn Technology Group under
HT001521F0070 in support of Fort Polk. The Government intends to negotiate a FFP contract with
MinBurn Technology Group, the current awardee for HT001521F0070.
3. Description of Supplies/Services and Estimated Value: The purpose of this action is to buy-out the current fleet of HP multi-purpose printers leased from MinBrun under HT001521F0070 in support of Fort
Polk. If unable to complete the buyout for this equipment, Fort Polk is at risk of the contractor removing all of the printing capability from within the facility at the end of HT001521F0070, which will critically affect DHA patients’ ability to receive key documents such as discharge instructions, as well as cripple the administrative lanes such as Patient Administration and hinder their ability to complete their hospital functions. FY26 Procurement funding will be applied in the amount of $ for this one-time purchase:
One-time Equipment Buyout from Contract HT001521F0070: 1 job $ $
(87) TAA Compliant - HP Color LaserJet Enterprise Flow MFP M681z
CONUS
(5) TAA Compliant - HP LaserJet Enterprise Flow MFP M635z CONUS
(21) TAA Compliant - HP LaserJet Enterprise Flow MFP M528c
(5) TAA Compliant - HP Color LaserJet Enterprise Flow MFP M578c
4. Statutory Authority Permitting Other Than Full and Open Competition: RFO 6.103-1(c)(2)(i):
“substantial duplication of cost to the Government that is not expected to be recovered through competition.”
5. Rationale Justifying Use of Authority Cited: HT001521F0070 was awarded on 27 April 2021 on the basis of competitive Service-Disabled Veteran Owned Small Business (SDVOSB) set aside for lease and support of multi-purpose printers in support of Fort Polk. HT001521F0070 is a base-plus-four order in the amount of $1,770,715.75. HT001521F0070 ends on 08 July 2026, but the fleet of multi-purpose printers is still needed by Fort Polk to maintain patient care and hospital administration capabilities. Due to the
Control Number:
OCT 2024
continuing need for these assets, a follow-on contract has to be awarded. There’re several ways to fulfill the requirement of a follow-on contract:
1. Re-compete this requirement as a lease and annual support on DHA’s NASA SEWP Printing
Imaging catalog;
2. Purchase new printers and annual support on a competitive basis on DHA’s NASA SEWP
Printing Imaging Catalog;
3. Two-part actions: 1) Buy-out the current HT001521F0070 fleet from MinBurn on a sole source basis, and 2) re-compete base-plus-four annual support for these printers on DHA’s NASA SEWP
Printing Imaging catalog as a SDVOSB set aside.
The potential cost of Option 1 is approximately $1.7 million. This estimate is based on the total price of
HT001521F0070, which is $1,770,715.75. HT001521F0070 was awarded in April 2021 as a base-plus-four effort on a competitive lowest-price-technically-acceptable (LPTA) basis. Even if we don’t taking into account of inflation, there’s no reason to expect price of the re-compete for the exact same scope and effort to be noticeably lower than the HT001521F0070.
The potential cost of Option 2 is approximately $ . This estimate is base on price of purchase based on current market price as of 04 June 2026:
Part # Description Qty Unit Price Price
HP J8A13A#201
HP J8A13A#201 is a specific configuration (part number) of the HP Color LaserJet Enterprise Flow MFP M681z. 87 $6,359.00 $553,233.00
HP 1PV66A#201
HP 1PV66A#201 refers to the HP LaserJet Enterprise
Flow MFP M528c, a high-performance, monochrome all-in-one laser printer. 21 $2,859.00 $60,039.00
HP 7PS99A#201
HP LaserJet Enterprise Flow MFP M635z (Part No:
7PS99A#201) is a high-performance, monochrome all-in-one laser printer built for enterprise environments and heavy-duty office workflows. 5 $5,999.00 $29,995.00
HP 7ZU87A#201
HP 7ZU87A#201 is the HP Color LaserJet Enterprise
Flow MFP M578c. 5 $2,299.99 $11,499.95
118 $654,766.95
As well of estimated price of base-plus-four support: $ /year X 5 years = $ .
The potential cost of Option 3 is $ . This estimate is based on MinBurn’s quoted price for the buy-out of the current fleet: $ , as well as the estimate price of a separate order for base-plus-four support:
In comparison, the cost of Option 3, buy-out the current fleet from MinBurn and establish a separate competed order for support, $ , is only % of Option 1 and only % of Option 2. Buy-out the current HT001521F0070 fleet from MinBurn and establish a separate order on the basis of competitive
SDVOSB set aside against DHA’s NASA SEWP Printing Imaging catalog represent the most cost effective course of action for the Government. Considering the cost of option 3 only represent fractions of the costs for Option 1 and Option 2, it’s demonstrated that the additional cost is not expected to be recovered through competition.
6. Efforts to Obtain Competition: This is part one of two-part actions to maintain support for Fort Polk.
Part one is a buy-out of current fleet of printers from MinBurn. Part two will be a competitive action to be competed among SDVOSB offerors on DHA’s NASA SEWP Printing Imaging catalog.
7. Actions to Increase Competition/Remove or Overcome any Barriers to Competition: Part two, support for printers-fleet, will be competed among SDVOSB offerors on DHA’s NASA SEWP Printing
Imaging catalog.
8. Market Research: In accordance with FAR Part 10, market research was conducted on 04 June
2026. After analyzing all options, a two-part approach, 1) purchase existing fleet of printers from
MinBurn and 2) compete the printer-support portion on DHA’s NASA SEWP Printing Imaging catalog, is the best value to the Government. This JA is for part one of two-part actions: purchase the existing HT001521F0070 fleet from the awardee, MinBurn. The estimate price for the two-part approach is only % of a full lease and support re-compete, and only % purchasing new printers and support approach.
Part two for printers support will be a procurement against the established Defense Health
Agency’s NASA SEWP Printing Imaging Catalog, there are six (6) SDVOSBs of proven past performance on this catalog that are capable of providing HP printers.
9. Other Facts:
a. Procurement History:
(1) Is this a new requirement? No.
(2) If 9.a.(1) is No, was the action just prior to this one competed? Yes. The previous action, HT001521F0070 was competed on SDVOSB set aside on DHA’s NASA SEWP Printing
Imaging catalog.
(3) If 9.a.(2) is Yes, what has changed where this action cannot be competed? Market research (see above) indicates a two-part approach is the best value to the Government. Part one, buy-out of current printer-fleet is sole source, but, part two, printers support, will be competitive SDVOSB set aside on DHA’s NASA SEWP Printing Imaging catalog.
b. Additional Information: N/A.
10. Interested Sources: Part One: MinBurn Technology Group. Part Two: All SDVOSB offerors on
DHA’s NASA SEWP Printing Imaging Catalog
11. Technical Certification:
I certify the supporting data under my cognizance, which are included in the justification, are accurate and complete to the best of my knowledge and belief.
Maynard Lamar Moseley
Chief Customer Support Branch
Information Management Division
BJACH, Fort Polk
12. Requirements Certification:
I certify the supporting data under my cognizance, which are included in the justification, are accurate and complete to the best of my knowledge and belief.
Maynard Lamar Moseley
Chief Customer Support Branch
Information Management Division
BJACH, Fort Polk
13. Legal Review:
I have reviewed this justification and have found it to be legally sufficient.
Grant T. Wahlquist
Associate General Counsel, Contract Law IT/HQ/PM Support
Office of General Counsel
Defense Health Agency
APPROVAL
14. Contracting Officer Determination of Fair and Reasonable Pricing and Certification of Accuracy and
Completion.
Fair and Reasonable Cost Determination:
I hereby determine the anticipated cost to the Government for this contract action will be fair and reasonable.
Basis for Determination: The Contracting Officer will make an independent determination that the anticipated cost to the Government is fair and reasonable through current market prices, price analysis techniques using the Contractor’s list prices, the Independent Government Cost Estimate, and historical pricing under previous orders against the DHA Printing Imaging Catalog on NASA SEWP for the same and similar products.
Contracting Officer Certification:
I certify this justification is accurate and complete to the best of my knowledge and belief.
Based on the foregoing justification, I hereby approve the procurement of (HP multi-purpose printers buy-out) on an exception to fair opportunity basis pursuant to the authority of 10 United States Code
(U.S.C.) 3204(a)(1) RFO 6.103-1(c)(2)(i): “substantial duplication of cost to the Government that is not expected to be recovered through competition,” subject to availability of funds, and provided that the supplies or services herein described have otherwise been authorized for acquisition.
Kevin D Hodge
Contracting Officer
Professional Services Contracting Division (PS-CD)
Defense Health Agency Contracting Activity (DHACA)
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