JOFOC Ada CBOC - Redacted.pdf

Effective Date: 11/15/24

REVISION: 01

Acquisition ID#:

DEPARTMENT OF VETERANS AFFAIRS

SOLE SOURCE JUSTIFICATION UNDER SIMPLIFIED PROCEDURES FOR CERTAIN COMMERCIAL

ITEMS IN ACCORDANCE WITH FAR 13.5

Acquisition Plan Action ID:

JOFOC Tracker Number:

1. Contracting Activity:

Department of Veterans Affairs (VA), Veterans Integrated Service Network (VISN) 19, Department of

Veterans Affairs Oklahoma City Health Care System (OKC VAHCS) and Network Contracting Office

(NCO) 19;

2. Nature and/or Description of the Action Being Processed:

This procurement is for Community Based Outpatient Clinic (CBOC) Primary Care Services and Tele-

Mental Health Services in accordance with FAR 13.5 Simplified Procedures for Certain Commercial

Items and specifically FAR 13.501 Special Documentation Requirements, where acquisitions conducted under Simplified Acquisition Procedures are exempt from the requirements of FAR Part

6, but still require a justification using the format of FAR 6.303-2.

The OKC VAHCS requires Community Based Outpatient Clinic (CBOC) Primary Care Services and Tele-

Mental Health Services. The medical center estimates a panel size of 1750 Veterans per month. The contractor shall provide a professional medical staff and CBOC solely dedicated to Veterans. This is a short-term contract for continued Veteran care while a long-term contract is being procured. The contract will be awarded as a new contract. The type of contract planned is firm-fixed-price

Indefinite Delivery Indefinite Quantity (IDIQ) contract. Services are currently being provided under

IDIQ contract 36C25925D0002 for Period of Performance, October 1, 2024 – September 30, 2025.

This is a short-term contract for continued services until the long term contract is awarded. The long term requirement is in the pre-award phase with an anticipated award date of 12/1/2025.

3. Description of Supplies/Services Required to Meet the Agency’s Needs:

The OKC VAHCS requires CBOC services providing Patient Aligned Care Team (PACT) - Primary Care

Services in a private clinic environment to Veterans, primarily in Ada, Oklahoma. The Contractor is required to meet Veteran Health Administration (VHA) performance and quality criteria and standards including, but not limited to, customer satisfaction. The contract allows for tele-health services to be provided on site via tele-health with VA staff. The care provided by the Contractor should be patient centered, continuous, accessible, coordinated, and consistent with VA standards.

DESCRIPTION EST.QTY PM/PM EST.MONTHY TOTAL EST. TOTAL

CBOC Services

October 1, 2025 – March 31, 2026

Acquisition ID#:

This contract action will have a fixed-price six (6) month base period from October 1, 2025, through

March 31, 2026. It is estimated that 1750 Veteran enrollees may visit the clinic each month over the six (6) month base period of performance, at a cost of per member per month (PMPM). The short-term contract will include Federal Acquisition Regulation (FAR) clause 52.217-8 Option to

Extend Services. If executed, the period of performance could be extended to September 30, 2026.

The specified rates under this clause will be those rates in effect under the contract each time an option is exercised under this clause.

4. Statutory Authority Permitting Restricted Competition:

FAR 13.5 Simplified Procedures for Certain Commercial Items. The statutory authority for applying the Simplified Procedures for Commercial Items of FAR 13.5 is 41 U.S.C. § 1901 and is implemented by FAR 13.106-1(b)(2) for restricting competition on this procurement. Competition is restricted on this procurement for the reason below:

(X) Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency

Requirements

( ) Unusual and Compelling Urgency

( ) Industrial Mobilization, Engineering, Developmental or Research Capability or Expert

Services

( ) International Agreement

( ) Authorized or Required by Statute

( ) National Security

( ) Public Interest

5. Demonstration that the Contractor’s Unique Qualifications or Nature of the Acquisition Requires the Use of the Authority Cited Above (applicability of authority):

The services required by this procurement are essential to the continued patient care of the

Veterans primarily residing in Ada, Oklahoma. With a required start date of October 1, 2025, the incumbent contractor, Bruce W. Dennis, MD, PLLC is the only source in the position to provide all the requirements of the PWS.

Bruce W. Dennis, MD, PLLC has the appropriate staff, systems and facility equipped to provide the continuity of highly specialized services to the Veterans in the area thus avoiding unacceptable delays in fulfilling the agency’s requirements.

There are no other sources with CBOC capabilities located in the Ada, Oklahoma area that can provide the existing services in the required time frame. A new CBOC contractor will need fully credentialed staff and a suitable facility that meets PACT standard prior to providing care to the

Veterans. Credentialing new personnel is taking three to six (6) months; however, the facilities have been experiencing delays. Further, setting up a new CBOC would take up to six months after award to set up. Therefore, there is insufficient time to accomplish this prior to the need date of October 1, 2025.

Acquisition ID#:

6. Description of Efforts Made to ensure that offers are solicited from as many potential sources as deemed practicable:

A long-term competitive solicitation for a SDVOSB set-aside has been issued. This short-term interim contract will ensure continued services until the long-term acquisition is awarded. The short-term requirement was not solicited.

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

Reasonable:

The Contracting Officer will determine that the anticipated cost to be fair and reasonable based on current contract pricing, Independent Government Cost Estimate (IGCE) and United States Bureau of

Labor Statistics (BLS) – Consumer Price Index (CPI) Escalation rates. The Medical Sharing Office

SharePoint site indicates a CPI rate of 2.87%.

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 by the contracting officer between August 14, 2025 – August 27, 2025, on Small Business Search (SBS) to determine businesses capable of providing Community

Based Outpatient Care services in Ada, Oklahoma. In addition, to meet the VA Rule of Two, a review of the Small Business Search website was also conducted to determine if two (2) or more service-disabled veteran-owned small businesses (SDVOSBs) and veteran-owned small businesses (VOSBs) that are capable of providing Community Based Outpatient Clinics are listed in Ada, Oklahoma.

SBS reflects forty-two (42) small businesses listed under North American Industry Classification

System (NAICS) 621498 for Oklahoma. There are four (4) Service-Disabled Veteran Owned Small

Business listed. The listing shows one (1) small business in the city of Ada, Oklahoma, the incumbent contractor, Bruce W. Dennis, M.D., P.L.L.C.

Although four (4) SDVOSBs are reflected on the SBS listing, the Rule of Two cannot be met as there are not any Service-Disabled Veteran Owned Small Businesses with capability to stand up a CBOC in the timeframe for required services. A new contractor will require a suitable facility that meets PACT standard prior to providing care to the Veterans of which typically takes four (4) to six (6) months buildout.

Bruce W. Dennis, MD, PLLC is the only source capable of providing continuity of services within the limited period before contract expiration. Any change in contractor support at this time is not feasible as the process would require the new contractor to locate and build-out a new facility, recruit and hire staffing, undergo VA background checks, and complete credentialing, which is not realistic given the timeframe of current services expiring on October 1, 2025. A new contractor will need at least six (6) months to provide a fully operational CBOC in Ada, Oklahoma, once a location has been selected.

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

None