JnA_Redacted.pdf

DEPARTMENT OF VETERANS AFFAIRS

Justification and Approval (J&A) For

Other Than Full and Open Competition

Acquisition Plan Action ID: 36C252-26-AP-0053

1. Contracting Activity: Department of Veterans Affairs, Network Contracting Office (NCO) 12, Great Lakes Acquisition Center, on behalf of the Captain James A. Lovell Federal Health Care Center (FHCC), 3001 Green Bay Road, North Chicago, IL 60064. This is a justification for Other than Full & Open Competition.

Purchase Request: 556-26-1-2102-0006

2. Nature and/or Description of the Action Being Approved: Sole source award of a Hematology/Oncology Physician Services contract for the aforementioned Federal Health Care Center to Posterity Group LLC, 7361 Calhoun Place, Suite 200, Derwood, MD 20855. The resultant contract will be a firm-fixed price contract.

3. Description of Supplies/Services Required to Meet the Agency’s Needs: The FHCC has a requirement for a licensed and dually certified Hematology/Oncology Physician to provide services for the Hematology/Oncology Outpatient Clinic on Monday through Friday, 8:00 a.m. to 4:30 p.m.

The physician will provide telephone consultations during the evening, weekend and holiday off-tour hours. The physician will also oversee the Infusion Clinic, work in the Bone Marrow Biopsy Room, attend the Lung and Non-lung Tumor Board meetings, check critical lab values, and see Active Duty and Recruit referrals from the Naval Station Great Lakes. The physician is required by November 10, 2025.

The FHCC requires the physician to have a DEA certification, Board Certified/Board Eligible with three years of experience within the past five years.

The anticipated period of performance will be from November 10, 2025 through November 9, 2026.

The estimated value of this procurement is $1,207,200.

4. Statutory Authority Permitting Other than Full and Open Competition: 41 USC §3304(a)(5), 38 U.S.

Code § 8127(c), as implemented by RFO FAR 6.103-5 (Authorized or Required by Statute). COs may use the non-competitive (sole source) procedures authorized in VAAR 819.7008 (DEVIATION) or VAAR 819.7009 (DEVIATION) up to $5,000,000.

(x) 819.7008 Sole source awards to a certified service-disabled veteran-owned small business;

or ( ) 819.7009 Sole source awards to a certified veteran-owned small business

5. Demonstration that the Contractor’s Unique Qualifications and/or Nature of the Acquisition Requires the Use of the Authority Cited Above: Posterity Group has a fully qualified physician (dually certified) who is available to begin working upon notification of credentialing clearance and favorably adjudicated fingerprints. Posterity Group also submitted two additional Hematology/Oncology Physicians who are located near the FHCC who will provide coverage due to unscheduled/urgent absences of the selected physician.

Posterity Group is a certified SDVOSB. The Contracting Officer searched the SDVOSB/VOSB Sole Source Dashboard that revealed that there were no awards to this contractor. This contract will be awarded in accordance with VAAR 819.7008 as authorized by 38 U.S.C. 8127. This SDVOSB concern has been determined to be a responsible source with respect to performance, and the Contracting Officer has ensured that this concern meets the eligibility requirements in VAAR 819.7003.

6. Description of Efforts Made to ensure that offers are solicited from as many potential sources as deemed practicable, including whether a notice was or will be publicized as required by FAR Subpart 5.2: Notice 36C25226Q0053 was posted to SAM.gov on October 17, 2025, stating the Contracting Officer’s intent to sole source the one-year contract to Posterity Group. A response was received from DreamCatchers Consulting, a certified Small Disadvantaged Business, but it cannot provide a physician by the FHCC’s need date of November 10, 2025.

7. Determination by the CO that the Anticipated Cost to the Government will be Fair and

Reasonable: The CO anticipates that the cost to the Government will be fair and reasonable based on comparison to the IGCE and past purchases made by the VA.

8. Description of the Market Research Conducted and the Results, or a Statement of the Reasons

Market Research Was Not Conducted: Market research was conducted for the services of a Hematology/Oncology Physician for the FHCC. Website searches were conducted utilizing the Dynamic Small Business Search (DSBS) and Integrated Critical Staffing Program (ICSP) databases, GSA eLibrary, Bing website searches (ZipRecruiter, www.healthecareers.com and www.Physiciansidegigs.com) and contacting known SDVOSB vendors (Ghost RX, Posterity Group, Titan-Axon).

DSBS Search

A search with keyword “hematologist”, and “NAICS code 561320” resulted in 0 small businesses.

Searches with keyword “Oncologist” and “Hematologist” resulted in 0 small businesses.

A search of “UEI ZMDPAJH4RFQ5” for the Posterity Group LLC confirmed that it has an active SBA certification. The business type section shows that it is a Service-Disabled Veteran-Owned Small Business that is registered with SAM.gov.

Integrated Critical Staffing Program (ICSP)

The hourly rate for a Hematologist is $433.82 and $404.72 for an Oncologist. The ICSP did not offer rates for a dually certified hematologist and oncologist physician

GSA eLibrary

A search of Category 621-009 (Hematologist/Oncologist) resulted in six vendors.

Aya Healthcare, Cancer CarePoint, Jackson & Coker LocumTenens and LocumTenens: Do not provide dually certified Hematologist/Oncologist physicians.

CompHealth (Large Business) and Insync Consulting (SDVOSB) were contacted, and they stated that if they are able to identify physicians that they would not be able to provide physicians at the FSS rates. No anticipated rates were provided.

Bing Website Searches

ZipRecruiter – The search revealed three Illinois companies that were seeking physician services. The average hourly rate was $266.14.

www.heathecareers.com - The compensation for a dual certified Hematologist/Oncologist physician ranges from $135,000 to $857,000 annually in Mt. Vernon, Illinois ($67.88 to $430.22 per hour).

www.Physiciansidegigs.com – According to this site, the average annual salary was $496,000 from mid-2023 to mid-2024. The salary has been trending upward since 2018-2019, and it is anticipated that the salaries will continue to increase. At the highest reported salary, the physician’s hourly rate is $626.

Contacting Known SDVOSB Vendors

Ghost RX: Responded that it was interested but did not confirm that it would be able to provide a physician and did not indicate what the rate would be for the services.

Posterity Group: Responded that it could provide a physician and provided the anticipated hourly rate of $600.

Titan-Axon: Responded that if it were able to provide a physician it would be at an hourly rate of . The vendor did not indicate that it would be able to provide a physician.

The market research efforts resulted in the Contracting Officer identifying Posterity Group, a Service-Disabled Veteran Owned Small Business as capable of providing the required services.

Posterity Group met the eligibility criteria outlined in VAAR 819.7003, it is certified in DSBS and the action is below the $5M threshold.

9. Any Other Facts Supporting the Use of Other than Full and Open Competition: N/A

10. Listing of Sources that Expressed, in Writing, an Interest in the Acquisition: DreamCatchers Consulting LLC responded to the Intent to Sole Source Notice. However, it cannot provide a physician by the FHCC’s need date of November 10, 2025. Titan-Axon and Ghost RX did not respond with available physicians.

11. A Statement of the Actions, if any, the Agency May Take to Remove or Overcome any Barriers to

Competition before Making subsequent acquisitions for the supplies or services required: An Acquisition Planning Team will reconvene if the FHCC requires continued services at the conclusion of the one year contract, and then depending on market research, a competitive solicitation will first be considered among SDVOSB/VOSBs that can provide the services at a fair and reasonable price.

12. Requirements Certification: I certify that the requirement outlined in this justification is a Bona

Fide Need of the Department of Veterans Affairs and that the supporting data under my cognizance, which are included in the justification, are accurate and complete to the best of my knowledge and belief.

Mary Ellis Clinical Director

FHCC

13. Approvals in accordance with the VHAPM Part 806.3 OFOC SOP:

a. Contracting Officer’s Certification: I certify that the foregoing justification is accurate and complete to the best of my knowledge and belief.

Patrice R. Bond Contracting Officer

NCO 12

b. One Level Above the Contracting Officer: I certify the justification meets requirements for other than full and open competition.

David Picchi Division Chief

c. Director of Contracting: I certify the justification meets requirements for other than full and open competition.

Paul M. Lauro Director of Contracting

d. VHA RPO HCA Review and Approval: I have reviewed the foregoing justification and find it to be complete and accurate to the best of my knowledge and belief and approve for other than full and open competition.

Daryl A. Berg Executive Director, RPO Central Head of Contracting Activity