JOFOC McCurtain 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 Tracking Number:

1. Contracting Activity: Department of Veterans Affairs, VISN 19, Rocky Mountain Acquisition Center, NCO 19, 6162 South Willow Drive, Suite 300, Greenwood Village, CO 80111 on behalf of Department of Veterans Affairs Eastern Oklahoma Health Care System (EOVAHCS). 1011 Honor Heights Drive, Muskogee, Oklahoma 74401.

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 Eastern Oklahoma VAHCS CBOC requires Primary Care Services and Tele-Mental Health Services.

The medical center estimates a panel size of 1000 Veterans per month. 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

36C25925D0004 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 pre-award phase.

3. Description of Supplies/Services Required to Meet the Agency’s Needs: The EOVAHCS requires CBOC services providing Patient Aligned Care Team (PACT) - Primary Care Services in a private clinic environment to Veterans, primarily McCurtain, Oklahoma. The Contractor is required to meet VHA performance and quality criteria and standards including, but not limited to, customer satisfaction, The contract allows for telehealth 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.

MONTHLY

TOTAL

EST. TOTAL

Acquisition ID#:

McCurtain County CBOC Services Base

Period

October 1, 2025– March 31, 2026

Total Estimated Contract Value

This contract action will have a fixed-price six (6) month base performance period from

October 1, 2025, through March 31, 2026. It is estimated that 1000 Veteran enrollees may visit the clinic each month over the base period, 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 McCurtain County, Oklahoma. With a required start date of October 1, 2025, the incumbent contractor, STG International Inc is the only source in the position to provide all the requirements of the PWS. STG International Inc has the appropriated 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 by the need date.

There are no other sources with CBOC capabilities located in McCurtain County, Oklahoma area that can provide the existing services in the required time frame. A new CBOC contractor will need a fully credentialed staff and suitable facility that meet 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 (6) months after

Acquisition ID#:

award to set up. Therefore, there is insufficient time to accomplish this prior to the need date of

October 1, 2025.

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

The long-term requirement is in the final stage of source selection by the Source Selection Authority

(SSA) member. This short-term interim contract will ensure continued services until the long-term acquisition is awarded.

The Contracting Office conducted market research on Small Business Search (SBS). The SBS search consisted of using North American Industry Classification System (NAICS) 621498 for the state of

Oklahoma; yielded forty-two (42) small businesses, one small business located in Oklahoma and four

Service-Disabled Veteran Owned Small Business (SDVOSB).

A sources sought was not issued as part of the market research for the short-term interim contract due to the length of time to outfit an operational CBOC, personnel familiar with procuring acquisition services, and identify a timeframe to duly stand up an operational CBOC at four (4) months to six (6) months.

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, 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: 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 McCurtain County, Oklahoma. In addition, to meet the VA Rule of

Two, a review of Small Business Search to determine was also conducted to determine if two (2) or more service-disabled veteran-owned businesses (SDVOSBs) and veteran-owned small businesses

(VOSBs) Community Based Outpatient Clinics are listed in McCurtain County, Oklahoma.

SBS reflects forty-two (42) small businesses listed under NAICS 621498 for Oklahoma. There are four

(4) Service-Disabled Veteran Owned Small Business listed. The listing shows no small business in the city of McCurtain County, Oklahoma.

Although four 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 meet PACT standard prior to providing care to the Veterans of which typically takes four (4) to six (6) months buildout.

Acquisition ID#:

STG International Inc., 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, which typically takes four (4) to six (6) months, 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 McCurtain County, Oklahoma, once a location has been selected.

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

None

10. Listing of Sources that Expressed, in Writing, an Interest in the Acquisition:

STG International Inc.

2900 S. Quincy St STE 888

Arlington, VA 2206

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:

A long-term competitive solicitation for a SDVOSB set-aside has been issued.

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.

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

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

9/19/25

Date

Contracting Officer

Network Contracting Office 19