JEFO_copy_Redacted_1.pdf

United States Department of the Interior

INTERIOR BUSINESS CENTER

Washington, DC 20240

SOLE SOURCE JUSTIFICATION

SIMPLIFIED PROCEDURES FOR CERTAIN COMMERCIAL ITEMS

AUTHORITY: FAR 13.501(a), 41 U.S.C. 1901

1. Identification of the agency and the contracting activity, and specific identification of the document as a “Sole Source Justification.”

This document is a sole source justification for the Department of the Interior, Interior Business Center, Acquisition Services Directorate, Division 2, on behalf of Health and Human Services (HHS), The Office of Inspector General (OIG), Office of Evaluation and Inspections (OEI).

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

This is a follow-on requirement to Purchase Order (PO) 75040121P00009. PO 75040121P00009 was awarded as a sole source purchase order to Dr. Lee Adler. Dr. Adler is highly specialized in providing clinical and policy consultation and technical assistance and will be awarded the continuation of this important work. The incumbent award ends on August 15, 2023 and a new award will need to be in place prior to the expiration.

Services will be performed by Dr. Adler who is listed as a small business.

Dr. Lee Adler 145 North Spring Trail Altamonte Springs, Florida 32714

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

The scope of this work is to provide clinical and policy consultation and technical assistance in conducting four main studies regarding hospital quality of care. The studies are: (1) a toolkit outlining methods for identifying adverse events, (2) a study of mental health screening during prenatal and postnatal care, (3) a study of quality of care provided during labor and delivery, and

(4) an investigation into use of electronic health records (EHR) for OEI data collection. All studies will require extensive experience in highly specialized areas of patient and clinical care in hospitals. This work will also include consultation on new work plan items related to quality of care and patient safety as they arise. Current topics under consideration include polypharmacy and cardiac rapid response in rural settings.

The estimated value and period of performance is:

Adler’s knowledge, skill, interest, availability, and success in working with physician reviewers has been an extraordinary benefit to the successful completion of these studies. Dr. Adler’s participation in this acquisition will allow for efficiency and cost effectiveness with medical record reviews by successfully developing efficient protocols and facilitating the analysis of complex clinical data. Additionally, to hire and train a new external consultant would take numerous internal resources from OIG/OEI and substantially longer to get the expert up to speed on the OIG/OEI processes and study topics. Dr. Adler’s dedication to the OIG/OEI, extensive experience, and industry success makes him the sole source for this requirement.

6. A description of efforts made to ensure that offers are solicited from as many potential sources as practicable, including whether a notice was or will be publicized as required by FAR Subpart 5.2 and, if not, which exception under FAR 5.202 applies.

A notice of intent to sole source was publicized in accordance with FAR 5.203. The notice of intent was posted on March 20, 2023, to SAM.gov and was left open for comments and responses for eight (8) days. The response period was shortened from 15 days as the services are commercial in nature. The notice closed at 10:00am on March 28, 2023. The notice indicated, “Interested parties may identify their interest and capabilities regarding this requirement by submitting a capabilities statement by [March 28, 2023]”. No responses were received in response to this notice. It has been determined based on the lack of responses that Dr. Adler’s extensive experience are unique to the SOW and therefore this procurement shall be issued as a sole source.

7. A determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable.

The contracting officer (CO) will determine that the anticipated price will be fair and reasonable by comparing the proposed price to historical data and previous contracted prices. Additionally, the CO will compare the proposed price to published pricing on established vehicles, such as GSA Multiple Award Schedules for similar labor categories.

8. A description of the market research conducted (see Part 10) and the results or a statement of the reason market research was not conducted.

The CO searched the current PO in the Federal Procurement Data System (FPDS) and was able to review the acquisition history. The incumbent contract was a Firm Fixed Price PO that was issued as a sole source to Dr. Lee Adler. Dr. Adler is a sole proprietorship and has an active record in SAM.gov with no exclusions. Dr. Adler does not have any records in CPARS, as his awards have been below the simplified acquisition threshold.

The CO researched the labor rate used for the development of the IGCE and found a comparable labor rate published on GSA MAS schedule. GSA has a published rate for a “Physician Consultant I/II” which is used under Advize Health, LLC. Schedule 47QRAA22D00A2. The Physician Consultant most closely resembles the “clinical consultant” used in the IGCE as the physician consultant requires a medical degree, reviewing cases, and is a Ph.D. The minimum