JFOC - BID Ceiling Logical Follow-on_Redacted.pdf

BID Task Order - Ceiling Increase for Optional Tasks Control Number VA-25-00007891

JUSTIFICATION

FOR AN EXCEPTION TO FAIR OPPORTUNITY

1. Contracting Activity: Department of Veterans Affairs (VA) Office of Procurement, Acquisition and Logistics Technology Acquisition Center (TAC) 23 Christopher Way Eatontown, NJ 07724

2. Description of Action: The proposed sole source action is for a modification to the Benefits Integrated Delivery (BID) Task Order (TO) 36C10B21N10070021 that was issued under the Transformation Twenty-One Total Technology Next Generation (T4NG) Indefinite Delivery Indefinite Quantity (IDIQ) contract VA118-16-D-1007 to Booz Allen Hamilton (BAH), 141 W. Front Street, Red Bank, NJ 07701. The purpose of this modification is to increase the Not-to-Exceed (NTE) ceilings for BID TO optional tasks in order to complete modernization efforts that are currently underway and scheduled for completion by the end of the BID TO Option Period 4. There will be no changes to the scope of work or technical requirements being performed under the BID TO, nor will the overall period of performance of the TO be extended due to this modification.

3. Description of the Supplies or Services: The BID TO was awarded on May 18, 2021, for a 12-month base period with 4, 12-month option periods and 5 optional tasks for Information Technology (IT) Development Security and Operations (DevSecOps) services for VA Benefits and Memorials Portfolio Products. The BID TO was established to enable the VA’s Strategic Goal to transform business operations by modernizing systems and focusing IT resources more efficiently to provide world-class customer service to Veterans and VA Employees. BID is in the middle of a five-year journey to modernize and simplify the IT systems footprint supporting the Veterans Benefits Administration (VBA) and National Cemetery Administration through the expansion and reuse of the Veterans Benefits Management System (VBMS) and Benefits Integrated Platform (BIP) technology solutions. The BID TO is the primary vehicle providing the operational, development, and modernization IT support for VA’s benefits processing and delivery systems. The base and each option period include the baseline requirements for project management, a BIP Systems Team, a BIP Agile Development Team, and travel. Much of the work performed under the TO is procured via the optional tasks; Optional Task 1 – Systems Teams, Optional Task 2 – Agile Development Teams, Optional Task 3 – Helpdesk Support, and Optional Task 4 – Shared Services Teams.

The President signed the Sergeant First Class Heath Robinson Honoring our Promise to Address Comprehensive Toxics Act (PACT Act) into law on August 10, 2022. As required by the PACT Act legislation, in March 2023, VA delivered to Congress a five-year plan and strategy to modernize its benefits IT systems. The BID TO, which was already supporting the modernization of VA’s benefits systems, needed to accelerate

BID Task Order - Ceiling Increase for Optional Tasks, Control Number VA-25-00007891 the work being performed in order to achieve the growth and enhancements required to support the modernization strategy outlined in the PACT Act 701(b)-modernization plan.

BID TO teams were immediately mobilized to ensure VA benefits IT systems could effectively manage the anticipated increased volume of Veteran benefits claim submissions as well as the more than 6,000 new VA claims processing staff. VA’s large-scale Veteran outreach program boosted not only PACT Act claims but also overall Veteran engagement and benefits enrollment, resulting in a record 39.3% increase in claims filed in fiscal year (FY) 2023. The PACT Act legislation has also allowed VA to accelerate the pace at which benefits IT systems can be brought up to industry standards and deliver more benefits for Veterans and their survivors. For example, VA successfully processed nearly 2 million total claims in FY 2023 and 2.5 million claims in FY 2024. These record levels of claims processing were made possible due to the rapid improvements made to benefits IT systems through optional tasks exercised under the BID TO, which included increased workforce personnel demands, technology enhancements, and modernization that enabled effective and efficient benefits claims processing. The BID TO continues to enable system expansion, new and improved training environments, and IT support tools that provide faster search capabilities across evidence files, improve workload management and the use of Veteran data. These modernization efforts, many of which are still underway, are improving the VA employee experience and VA’s ability to serve Veterans.

In anticipation of the increased volume of claims the PACT Act would bring, VA accelerated the timeline for planned systems modernization under the BID TO. Notable progress is being made to transform critical systems and infrastructure from dated and disjointed to modern and connected. VA has made progress against 70 modernization efforts, resulting in the modernization and enhancement of over 40 systems in a highly compressed timeframe. This substantial investment laid the foundation for the next stages of modernization which are underway and carry into FY 2026. In addition, although progress has been made to modernize VA benefits IT systems, several foundational architectural modernization initiatives are multiyear efforts that are in progress and require additional time to complete under the BID TO. These modernization efforts to improve the foundational architecture will provide critical security improvements, new capabilities, automation, and claims processing efficiencies which will enable accelerated benefits delivery and the effective and secure use of data to serve Veterans. While the PACT Act legislation has accelerated the work being done under the BID TO, it has not altered the nature of the work itself, which in the interests of the economy and efficiency must be carried through to completion by the incumbent contractor. Transitioning these modernization efforts to a new contract while the critical foundational architecture work is in progress would delay delivery and completion of the work and put the PACT Act modernization plan at significant risk.

Specifically, the PACT Act legislation has resulted in VA exercising the BID optional tasks at a faster rate than what was originally estimated when the NTE optional task ceilings were established for the TO. The BID NTE ceilings were established for the optional tasks based on an estimated number of Systems and Agile Development Teams and required labor categories and hours for the Help Desk Support and Shared Services Team optional tasks. The original estimates and quantities for the optional tasks were included in the solicitation to establish an overall NTE ceiling for each than 20 new presumptive conditions and additional presumptive locations has also increased. To accommodate this growth and demand, VA needs to continue its IT modernization efforts to improve the records, retrieval, and intake of claims to reduce the burden on Veterans. This includes streamlining dependencies on internal and external organization systems from which VA obtains evidence data. These organizations include the Department of Defense (DoD), private medical providers, Veterans Health Administration (VHA) medical records and other record repositories.

The modernization efforts currently underway on the BID TO will continue to accommodate this growth and significantly simplify the process for Veterans applying for PACT Act-related benefits.

Per the PACT Act, VA needed to begin processing PACT Act-related benefit claims by January 1, 2023. As such, VA IT systems actively supporting more than 6.5 million Veterans through nine benefits programs needed to quickly respond and assemble the abilities to receive, process, and deliver more earned benefits to more Veterans and survivors than ever before. To support PACT Act-related benefits claims, the work being done under VA’s BID TO was, and continues to be, accelerated. As a result, over the last year, significant progress has been made on initiatives that improve the way VA delivers benefits and services, leading to increased customer service satisfaction, higher utilization, and better outcomes for the Veteran. The impact of this progress is perhaps best represented by the more than 400,000 new healthcare enrollments submitted between March 2023 and March 2024, representing more than a 30% increase from the previous year, which is directly tied to service connectivity to specific conditions defined in the PACT Act legislation. This is the largest number of enrollees in a single year over the past five years at VA and a nearly 50% increase over pandemic-level enrollment in 2020. Enrollment at this scale would not have been possible without the accelerated use of the optional tasks exercised for the benefits IT systems modernization efforts being performed under the BID TO.

Furthermore, the PACT Act’s eligibility expansion resulted in nearly 2.5 million total claims processed in FY 2024, a record 47% increase from FY 2022-24. Notably, in July 2024, VA achieved the highest output month ever with 229,538 claims completed in a single month—the sixth time to achieve over 200,000 completions since first accomplished in January 2024. With the achievement of this milestone, VA’s top 10 best claims production months in agency history have all happened in the last 12 months. VA is currently processing an average of 9,694 claims per day, resulting in the backlog (claims over 125 days) being able to remain a low percentage of the overall claims inventory, approximately 27.5%, even though the number of claims is almost 50% higher. In comparison, the last time the claims inventory was nearly as high as it is now, was in 2013, and the backlog represented 70.2% of the total claims at that time.

VA’s modernization efforts under the BID TO are providing the necessary improvements to the benefits IT systems that are resulting in claims being processed more quickly and accurately. While the incremental nature of Agile DevSecOps performance has resulted in near-term system improvements for which benefits have already been realized by Veterans, their families, caregivers, and beneficiaries as well as the VA workforce, many of these modernization initiatives are multi-year efforts. The positive impact of these efforts will continue to ramp up over time as modernization milestones are completed during BID TO Option Period 4. BID TO teams have not only delivered new features and capabilities to benefit IT systems, but they are on track to deliver further critical complex modernization initiatives that are currently underway that will enable claims processors to work as effectively and efficiently as possible, with faster search capabilities across evidence files, better workload management, and consolidation of information. The BID TO provides the necessary continuity of DevSecOps support services needed to complete modernization efforts underway for critical financial and payment distribution systems, the Board of Veterans' Appeals systems, VBMS, Benefits Enterprise Platform (BEP), and BIP. These modernization and automation efforts are establishing a technological framework that will ensure secure and reliable access for over 27,000 benefits claims processors in their daily operations. As a result, claims processing will take days instead of months. Specifically, VA’s IT system modernization roadmap for FY 2025 spans Option Period 3 and Option Period 4 of the BID TO, and includes critical milestones that are essential to avoiding an increase in the claims backlog while also ensuring compliance with federal laws and mandates including the PACT Act, Executive Order 14028, "Improving the Nation's Cybersecurity” through the implementation of Zero Trust Architecture, and the Consolidated Appropriations Act, 2022, P.L. 117-103, Division J, Title II (Sec. 237), which, following the Social Security Number (SSN) Fraud Prevention Act of 2017, mandates VA discontinue using SSNs to identify individuals in all VA information systems no later than March 23, 2026.

Transitioning these modernization efforts to a new contract will result in significant re-work and an estimated 6-12 month delay in completing and delivering on the critical modernization investments that are in progress. Specifically, transitioning to a new DevSecOps contract will be a complex endeavor spanning approximately 6-12 months to assume the responsibilities for maintaining VA mission-critical benefits IT systems and the complex modernization initiatives that are currently being performed under the BID TO. This estimate is based on the magnitude and complexity of the work at hand which is supported by over 2,000 contract staff fielding 230 Agile development teams, 15 systems teams, and 12 shared services teams. Adequate transition time of at least six months will be required to recruit, hire, and onboard skilled staff; obtain security clearances; procure, provision, and configure computers with specialized software;

orient and train staff on Benefits and Memorials (BAM) applications, infrastructure, practices, procedures, and policies; and shadow existing staff to obtain the practical experience needed to support VA’s systems. Furthermore, new contract vendors cannot be expected to continue or complete technical solutions designed by a former contract vendor as they will have a different approach to program management, engineering services, and technology modernization. A new vendor would therefore require additional time, potentially up to an additional six months, to reassess and redesign strategies and solutions for each initiative; thereby resulting in new commitments and milestones for the delivery of modernization work that are currently scheduled for completion during FY 2025-26 under the BID TO.

Continuity of the modernization efforts currently being performed under the BID TO is essential to optimize and automate claims processing steps, allowing employees to focus on the most value-added tasks to ensure accurate and timely decisions. Only the current contract vendor has the necessary onboarded staff immersed in the modernization efforts who can continue and complete the work underway without delay.

Transitioning the work to a new contract, to include the onboarding and training of over 2000 contractor staff, while these key initiatives are in flight will result in incomplete deliveries, rework, loss of investments, and delays in processing Veteran benefits.

Descriptions of several key PACT Act VA IT benefits systems modernization initiatives that are in progress, their impacts on VA, and impact on providing Veterans benefits are below and include VBMS, VBA Corporate Database (CRP), Enterprise Management of Payments, Workload, and Reporting (eMPWR-VA), BEP, and BIP.

VBMS Modernization.

VBMS serves as the primary system of record for processing Veteran compensation claims. VBMS has modules supporting every step of claims processing and integrations with all the other VA benefits IT systems and external organizations. VA’s ability to deliver on PACT Act legislation and meet the commitments in the 701(b) modernization plan centers on the successful completion of VBMS modernization as VBMS is the product for processing Veteran Compensation and Pension (C&P) benefits claims. VA is anticipating an additional 10.3 million rated claims over a ten-year period, on top of the 4% average annual growth. VBMS modernization efforts that are currently underway on the BID TO include:

National Work Queue (NWQ) Modernization. NWQ manages the routing and distribution of claims to Regional Offices (RO), Teams, and Users. Currently, NWQ processes roughly 1.8 million claims via nightly jobs that average 2 hours to complete. As the claim volume increases, job processing times increase, jeopardizing the ability to begin each workday with a fully distributed claims backlog.

NWQ routing is highly complex, being managed through roughly 1,000 claim distribution and routing rules. The modernized NWQ architecture enables flexibility to schedule and enables the recall and distribution of open benefit claims at the national level in a near real-time, event-driven manner, limiting the wait-states that are inherent in the current NWQ nightly job architecture. The modernized NWQ structure enables the creation and scheduling of routing rules and ruleset collections, which empowers the NWQ Business Administration team to control the frequency for which routing decisions are applied. Modernized NWQ is successfully undergoing final Beta testing, and the full release is planned for FY 2025. Feature-driven enhancements to further improve workload distribution and increase efficiency in claims processing are scheduled for completion during Option Period 4.

Transitioning this work to a new contract prior to completion would require a reassessment and potential redesign of the strategies and solutions to execute the highly complex NWQ routing. Due to the complexities of the work at hand, a contract transition would delay delivery into at least FY 2027. Delays in the delivery of Work Queue modernization will result in ineffective and inefficient routing, decreased accuracy, and prolonged processing of Veteran benefits compensation claims.

Claim quality and claim timeliness concerns have been escalated to the House

Committee on Veteran Affairs due to current claim routing limitations. In response, a Prior Transaction Routing modernization effort has been prioritized to begin in FY

2025. The Prior Transaction Routing enhancement builds off Modernized NWQ and allows claims to be routed to the RO and the employee who completed the previous transaction on a claim. The NWQ Admin Team will be able to indicate when a claim should and should not be sent to the RO or employee who completed the prior transaction, based on employee type, user roles, transaction type, and lifecycle. This enhancement is scheduled for completion during Option Period 4. Transitioning this work to a new contract will result in delays in realizing the highly anticipated workload management routing capabilities that will be provided by this enhancement. A contract transition would delay delivery into FY 2028 due to the rework involved with the highly complex routing rules. Delays in delivery of Prior Transaction Routing will result in continued delays and accuracy in Veteran compensation claims.

Modernizing the Claims Evidence file includes changes to the user interface as well as migrating systems from the legacy eFolder interface to the new Claims Evidence interface. The Claims Evidence User Interface provides improved document search capabilities to users in the single repository for all Veteran claims documentation. It enables automation through computable and searchable data generated by Optical Character Recognition. The search functionality also reduces manual document review timelines, improving speed and accuracy in claims processing. The remaining effort being performed under the BID TO focuses on migrating approximately 20 additional systems from the legacy eFolder interface to the Claims Evidence interface and decommissioning the legacy eFolder Service, which is scheduled for completion during Option Period 4. Transitioning this work to a new contract will delay the decommissioning of legacy systems and the establishment of a modern Claims Evidence file until FY 2028 or beyond. PACT Act legislation requires VA to accommodate the increased number of records and evidence needed to verify the Veteran’s service connectivity to the more than 20 new presumptive conditions and additional presumptive exposure locations. This modernization initiative is fundamental to the VA’s plan to improve Veteran records retrieval and intake to reduce the burden on the Veteran to prove eligibility. Delaying the completion of this initiative will decrease VA claims processor’s user capabilities, automation, and accuracy to process claims and prolong inefficient and disparate Veteran benefits evidence repositories.

The Enterprise Correspondence Manager initiative supports decommissioning the legacy and siloed letter/document generator, PC Generated Letters, as well as modernizing Core, Ratings, and Awards letters. This initiative centralizes the management and generation of letters correspondence to Veterans into a single correspondence service for all BAM Lines of Business, allowing users to generate and manage all letters via business-managed templates reducing the need for additional Office of Information and Technology (OIT) development. This capability will provide a consistent and singular methodology for document creation, eliminate the need to copy and paste between applications and reduce the number of letter customizations required and is scheduled for completion during Option Period 4.

Transitioning this work to a new contract will require rework of solutions and strategies to manage and generate VA letter correspondence prolonging delivery into FY 2027; thereby delaying VA’s decommissioning of legacy systems and the ability to provide consistent, effective, authoritative, and authentic letters to Veterans.

VBA CRP

The VBA CRP is a vital system for enabling Veterans to receive payments and storing data related to disability compensation, pension, Veteran readiness and employment benefits, including Veteran claims histories, ratings information, awards, and payment data. It also houses payment information for GI Bill education benefits. A total of 7 applications integrate directly with CRP and 41 applications integrate via BEP services.

The database, consisting of over 1,100 data tables and 600 reference tables, is crucial for VA to provide benefits and payments to Veterans. It serves as a comprehensive database for essential Veteran information, facilitating real-time interactions, and providing access to benefits information for both VBA employees and external users.

Modernizing and fully decommissioning a legacy system is a multi-year process due to the more than 1,000 integration points.

Under the BID TO, CRP is undergoing complex cloud migration and modernization initiatives to improve the operational reliability and resilience of VA IT benefits systems.

CRP is a critical core system for VBA Claims processing. CRP is currently in the process of testing the CRP cloud migration from the on-premise VA Austin Information Technology Center (AITC) to the CRP Virtual Private Cloud in the VA Enterprise Cloud (VAEC) within the Amazon Web Services (AWS) GovCloud. CRP Cloud Migration to improve the performance of the single centralized Oracle database containing the transaction history of Veteran benefits across VBA lines of business is essential for VBMS, Board of Veterans Appeals (BVA), and VA Health Connect (VAHC) Customer Relationship Management (CRM) functions. To date, efforts for cloud provisioning, infrastructure, security, and ATO have been completed, and migration efforts including data transfer and synchronization, integration and coordination, and operationalization of the new infrastructure are in progress. Modernization efforts that are currently underway on the BID TO include:

Rehosting CRP on AWS to enable acceleration of benefits systems modernization efforts and improve network performance, strengthen uptime guarantees, enable faster product development and deployment, increase security, and increase ability to scale to meet needed capacity. This modernization effort is currently in flight, with coordination across all integrated systems and coordinated milestones through final production cut-over. Any schedule interruption puts at risk modernization efforts for all connected systems, impacting VA’s ability to efficiently deliver Veteran benefits and payment.

Anonymizing production data sets to enable data parity in lower environments, which will empower automated and manual testing to identify issues earlier in the development life cycle by using data that mimics reality.

Implementing a Blue/Green software release strategy and supporting architecture to enable the rapid release and rollback of deployments to production and lower environments.

These modernization efforts are scheduled for completion during Option Period 4.

Completing these efforts is critical for improving operational reliability and resiliency and security through migration to the cloud and modernization of key infrastructure. The CRP migration to VAEC has major impact on the resiliency of many dependent systems, internal and external (e.g., VBMS, BEP, Master Veteran Index, Virtual Lifetime Electronic Record/Data Access Services, Disability Exam and Assessment Program, CRM). Tuxedo, one of the key components of the CRP and BEP ecosystem, is very sensitive to network latency, as are many of the dependent systems. Transitioning this work to a new contract will delay the completion of these efforts into FY 2027 and beyond which will severely negatively impact VA’s ability to provide Veterans, Beneficiaries, and Survivors with accurate and timely benefits compensation services and benefits payments. Operational reliability and resiliency equate to the VA benefits IT systems uptime and availability for which benefits and payments may be processed.

These modernization efforts are essential for accommodating the increased demand and growth needed for processing Veterans PACT Act-related benefits.

eMPWR-VA The eMPWR-VA product supports the Office of Financial Management (OFM) by providing finance and accounting payment capabilities and integration with the Department of Treasury Payment System. Under the BID TO, efforts are well underway to develop and implement internal and external interfaces and integrations of Application Programming Interfaces (APIs) between DGIB, eMPWR-VA, and other systems to process VBA Education Benefits payments to Veterans; reconcile any overpayments and debts with Debt Management Center (DMC); and update budgetary data in the General Ledger (GL) reporting to Department of Treasury. BID TO teams are currently expanding eMPWR-VA capabilities by integrating with new services from CRP, BEP Services, Master Person Index (MPI), VA Profile, DMC, VBMS, and Corporate Waco-Indianapolis-Newark-Roanoke-Seattle with scheduled completion during Option Period 4. Additional key integrations include Financial Management Business Transformation (FMBT) Integrated Financial and Acquisition Management System (iFAMS), Loan Guaranty (LGY), Specially Adaptive Housing / Special Housing Adaptation (SAH/SHA), Centralized Accounts Receivable, Insurance, Chapter 31 Readiness and Employment System (RES), and International Direct Deposit which are also currently underway with scheduled completion in Option Period 4. These efforts will replace legacy Benefits Delivery Network (BDN) functionality and improve the accuracy and timeliness of payments for Veterans.

Transitioning this work to a new contract will require rework of solutions and push important integration coordination into FY 2027 and beyond. These modernization efforts are essential for accommodating the increased demand and growth needed for processing Veterans PACT Act-related benefits and will provide Veterans, Beneficiaries and Survivors timely payments of their compensation. The continuity and completion of the work being performed under the BID TO is important to realize the value of the investments for this work to date and for VA to meet integration aggressive deadlines, not to delay OFM’s completion of strategic objectives and priorities and not to disrupt successful completion of external efforts that depend on eMPWR-VA integration. The potential for disruption and delay of important integration work in progress presents a significant risk to the delivery of key VA and VBA strategic objectives which results in degradation of accurate and timely services and payments for Veterans and their families. This risk would pertain to FMBT iFAMS Wave integrations, BDN Drawdown, Digital GI Bill, LGY Modernization, SAH/SHA Modernization, and numerous internal OFM objectives for modernization and performance of eMPWR-VA.

BEP

The BEP is a mission-critical product that provides VA Standard Data API for IT benefits systems including the BIP platform and VBMS. BEP is the modern replacement for the legacy Benefits Gateway Services (BGS). This modern solution reduces load on temperamental Tuxedo services and enables improved operational reliability and resiliency for increased claim volumes. BEP is hosted on-premise at the AITC and is currently undergoing a migration to the VAEC within AWS GovCloud. The migration to the cloud currently underway under the BID TO will provide improved security, performance, scalability, agility, operational stability, and improved Veteran benefits processing and data integration. Current BEP infrastructure poses an imminent risk to VA processing of PACT Act claims due to infrastructure and technical limitations that affect the ability to continue to grow benefit delivery at the increased rates introduced via the PACT Act. Pauses or delays in these modernization initiatives will result in claims backlog growth outpacing the ability of IT systems to handle them. BID TO teams are currently implementing the build-out of BEP cloud infrastructure in the Development domain with a focus on WebTest and preparing its users for cutover and testing. The nature of the modernization initiative is complex and intricate requiring careful and elaborate testing and validation with many up and downstream products. The complex nature of the work introduces a level of risk that obligates a vendor to finish what was started. One vendor cannot simply put down and transition the work to another vendor without pausing the effort to allow for a new technical assessment and potentially different approach to be implemented by the new vendor. Modernization efforts that are currently underway on the BID TO include:

Rehosting existing BEP components to AWS to enable future modernization efforts and improve system resiliency, scalability, and security.

Introducing modern performance monitoring tools and capabilities for proactive identification of application degradations and failures.

Implementing Blue/Green software release strategy and supporting architecture to enable the rapid release and rollback of deployments to production and lower environments.

These modernization efforts are scheduled for completion during BID Option Period 4.

Transitioning to a new contract will require rework of the solutions and push important integration coordination into FY 2027 or longer. This technology directly supports all VA IT benefits systems operations and VA’s ability to deliver timely benefits to Veterans and their survivors. More than 26,000 VA claims processors depend on this information.

Continuity and completion of these modernization initiatives is critical as the overall modernization plans for the 40 consuming applications are based on the coordinated milestone dates. Disruption to the current and planned tasks will also delay the retirement of the legacy BGS environment, which is currently at end of life. These modernization initiatives are fundamental to the VA’s modernization plan and essential for accommodating the increased demand and growth needed for processing Veterans’

PACT Act-related benefits. This work directly enables VA’s ability to effectively and securely streamline data with internal and external organization systems, such as the DoD and VHA medical records.

BIP

The BIP is a modern cloud-native platform for enabling technology in support of benefits processing. The BIP provides IT design patterns and integration with other VA systems and enterprise platforms, like VA’s Lighthouse APIs, to interact with other domains internal and external to VA. These capabilities are key to supporting the improved use of the Veterans’ data in claims processing. BIP is foundational to enable the complex transition and migration of legacy VBMS to the platform and NWQ modernization. BIP is currently being enhanced under the BID TO to ensure VA benefits systems operational reliability and resiliency, security, and continuous integration / continuous delivery (CI/CD) capabilities including feature flagging solutions and automated testing that all benefits IT system tenants may utilize. Efforts currently being worked under the BID TO will also enhance the security posture of the BIP which is critical to safeguarding Veteran data, including Personally Identifiable Information (PII) and Protected Health Information (PHI). As the cyber threat risk increases, any delays in completing these initiatives increase risks to protect sensitive Veteran data. These efforts will improve VA benefits IT systems availability, enhance Veteran services and improve claims processors’ day-to-day workflows. Modernization efforts that are currently underway on the BID TO include:

Implementing Continuous Authority to Operate (cATO) capabilities that automate and improve platform security and compliance. cATOs provide enhanced security by assessing applications against currently known vulnerabilities, rather than what was known at the time an assessment was made months or years prior, reducing the risk of cyber threats.

Deploying a modern CI/CD capability that allows platform tenants to integrate and deliver software in a more simplified, automated, and transparent manner.

Implementing Artificial Intelligence / Machine Learning (AI/ML) augmented frameworks and tools that accelerate the delivery of user-facing chatbots, improve the quality of code, and improve operational reliability and resiliency.

These modernization efforts are scheduled for completion during BID Option Period 4.

Transitioning to a new contract will delay completion of the initiatives into FY 2027 which will result in increased risks to Veteran information data. Cyber threat risks continuously increase; therefore, VA must ensure the highest security posture for BIP in order to safeguard Veteran data, PII, and PHI housed in the benefits IT mission critical applications.

6. Efforts to Obtain Competition: Market research was conducted, the details of which are in the market research section of this document. This effort did not yield any additional sources that can provide the seamless support required to perform the modernization efforts currently underway and scheduled for completion during Option Period 4 of the BID TO. The compressed and aggressive timelines and interdependent nature of the work being performed under the BID TO are the result of carefully orchestrated planning performed in collaboration with VBA, BVA, and OIT stakeholders. Transitioning this work, or attempting to carve out separate requirements to complete the current initiatives underway, prior to achieving the technical milestones that are scheduled for completion during BID Option Period 4 would jeopardize numerous OIT commitments to VBA and BVA, including the modernization initiatives detailed above. Due to the significant complexity and magnitude of the work, the most economical and efficient way of completing this work (avoiding significant delays and duplicative work) is a logical follow-on modification to increase the NTE ceiling for the optional tasks which will enable the completion of these modernization efforts during Option Period 4 of the BID TO. Therefore, there is no competition anticipated for this acquisition. In accordance with FAR 5.301 and 16.505(b)(2)(ii)(D), the award notice for this action will be synopsized on the System for Award Management website and the justification will be made publicly available within 14 days of award.

7. Actions to Increase Competition: No barriers to future competition are anticipated. VA is currently working to finalize the requirements for at least one competitive follow-on contract, Benefits Enterprise Services (BES), which is anticipated to be solicited and awarded during FY 2025. The base period for this new competitive contract is anticipated to include a 6-month transition period to allow sufficient time for a new vendor to recruit, hire, and onboard approximately 2,000 skilled staff members; obtain security clearances; procure, provision, and configure their computers with specialized software; train staff on BAM’s applications, infrastructure, practices, procedures, and policies; and shadow existing staff to obtain the practical experience needed to support VA’s systems. Furthermore, as services are transitioning between contracts, there are expected to be changes regarding the program management, engineering services, and technology solutions and strategies for future BAM DevSecOps requirements. Vendors will need additional time, potentially up to an additional 6-months, to provide commitments and milestones for the delivery of new modernization solutions for each initiative. Therefore, VA anticipates that transition between contracts for the services being performed under the BID TO will begin during Option Period 4 as modernization efforts are completed and/or reach appropriate technical milestones or phases, in order to ensure the successful transition of BID services to a new contract no later than May 18, 2026, the completion date for BID Option Period 4.

8. Market Research: VA’s technical experts conducted market research in October 2024 to ascertain if other vendors could efficiently and economically satisfy the requirements associated with the modernization efforts scheduled for completion during BID Option Period 4. BAM technical experts conducted research of vendors including Accenture Federal Services, GovCIO, LLC, TiSTA Science and Technology Corporation, and Science Applications International Corporation. These vendors offer IT expertise to modernize and support federal IT systems; however, each vendor has different approaches to program management, engineering services, and modernizing IT systems. Transitioning the modernization efforts currently underway prior to their scheduled completion dates would therefore result in pausing the development work while a new vendor reassesses the business and functional requirements for each system, potentially redesigns the current technical solutions being developed, and provides new delivery schedules and commitments for each initiative.

Additional market research was also conducted via a Request for Information (RFI) for the BES procurement which was posted on SAM.gov on November 1, 2024. The RFI included a request for interested vendors to provide feedback and recommendations regarding major technical milestones and schedule risks associated with successfully transitioning product support and development services from the BID Task Order to the BES contract, which will include the transition of approximately 15 Systems Teams and 230 Agile Development Teams supporting eMPWR, C&P, Memorials, BIA, and Appeals Product Lines. RFI responses were received on December 2, 2024, which included capability statements from multiple vendors, including the companies reviewed by the BAM SMEs above. The responses provided by industry demonstrated that other vendors have the capabilities to meet VA’s general requirements for DevSecOps support. However, none of the vendors would reasonably have the requisite code level review and skillset required to immediately address and begin work on the requirements currently in flight under the BID TO and achieve the current targeted completion dates scheduled for Option Period 4. Furthermore, the responses detailed transition risks associated with service disruption impacting continuity of service of operations and potentially affecting the development and deployment pipelines, risks of introducing security vulnerabilities or misconfigurations during the transition which would potentially compromise integrity and confidentiality of code infrastructure, and data migration challenges, including risks of data loss or corruption.

The RFI respondents also provided recommendations for mitigating transition risks, such as implementing parallel operations and phased migration, rigorous validation processes, phased rollouts and rollback mechanisms and continuous monitoring to minimize service impact. This feedback and the recommendations provided by the vendors support VA’s assessment that transitioning BAM DevSecOps services between contracts will take between 6-12 months. Additionally, the RFI responses are being taken into account as the future BAM DevSecOps requirements are updated for solicitation, including transition tasks, as it is clear from the vendors’ responses that the transition of these services is expected to be a long, complex effort. For VA’s immediate needs, BAH has the established technical expertise, approach, and onboarded staff to complete the inflight modernization efforts for the critical VA systems supported under the BID TO that are scheduled for completion during Option Period 4. Likewise, attempting to split the current work being performed onto separate contracts would result in unnecessary delays and duplication of work. Therefore, the most efficient and economical means of assuring the necessary continuity of operational services and completion of the modernization efforts being performed under the BID TO is to increase the optional task NTE ceilings to support the required work that will be performed and completed under Option Period 4 of the BID TO.

9. Other Facts: N/A

10. Technical and Requirements Certification: 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.

Date: ______________________________

Program Manager Signatur

11. Fair and Reasonable Cost Determination: I hereby determine that the anticipated price to the Government for this action will be fair and reasonable as the FFP unit prices for the optional teams and labor categories for Option Period 4 performance were incorporated into the TO at award. These prices are not subject to change due to the increase in the NTE ceiling and were previously determined fair and reasonable at time of TO award.

Procuring Contracting Officer

Signature

12. Procuring Contracting Officer Certification: I certify that this justification is accurate and complete to the best of my knowledge and belief.

Procuring Contracting Officer Signature:

Office of General Counsel (OGC) Review

I have reviewed this document and find it legally sufficient based on the representations set forth in the document and, if any, attachments. The Senior Procurement Executive’s approval is an independently supported decision not wholly reliant on the legal sufficiency determination.

Date

Office of General Counsel

12/17/2024