JOFOC Redacted_Redacted.pdf

resulted in unique operational knowledge of the HEHR architecture, system configurations, data pipelines, integration workflows, and processing methodologies that are not readily transferable without substantial duplication of cost, schedule delay, and operational risk.

The requirement is non-severable because it consists of continuous, interdependent processes performed within the HEHR production environment, including data ingestion, validation, integration, and reporting. In addition to several intermediary deliverables, the final deliverables include (1) Final hospital data set - 2025 HID harmonizing and integrating all eligible hospital encounter-level data collected for the data collection year; and (2) Final Dataset of collected 2025 Annual Hospital Interview (AHI) data. These functions must be executed sequentially and without interruption to maintain data integrity and system performance. Segmentation of the work or transition between contractors would disrupt ongoing operations, resulting in incomplete datasets and degradation of mission-critical outputs. Furthermore, the final deliverables are only able to be completed and of benefit to the Government when the entire project is complete.

While the BPA allows for competition, the requirement must be performed within an active, integrated HEHR environment with interdependent workflows and continuous operations.

BAH’s embedded system knowledge, established technical framework, and operational integration enable immediate execution without disruption. Transitioning to another contractor would require reestablishing environments, revalidating integrations, and re-coordinating stakeholders, resulting in significant delays and increased costs. Accordingly, only the BAH can meet the requirement within the required timeframe without unacceptable mission impact.

4. Authority Cited and Rationale: Authority of the FSS Program, Title III of the Federal Property and Administrative Services Act of 1949 (41 U.S.C. 251, et seq.); Title 40 U.S.C. 501, Services for Executive Agencies, as implemented at FAR 8.401 and GSAM/R 538.7104-3(b)(1).

GSAM/R 538.7104-3(b)(1)(ii)- Only one source is capable of providing the products, services, or solution required at the level of quality required because the products, services, or solutions are unique or highly specialized.

Booz Allen Hamilton (BAH) is the only source capable of performing the requirement at the required level of quality because the work must be executed within the active HEHR production environment supporting NHCS operations. BAH developed the existing HEHR infrastructure under contracts #75D30122F15087 (cloud migration and enhancement), #75D30119F06803 (Electronic Data Collection and Processing for the National Hospital Care Survey), and #75D30122F15721 (Collection of Electronic Health Record Data from Federally Qualified Health Centers Sampled in the National Ambulatory Medical Care Survey). BAH has the operational knowledge of the system architecture, data pipelines, and stakeholder interfaces necessary to sustain uninterrupted performance.

Although the Government obtained the underlying 2025 claims and EHR source data during the acquisition delay period through existing operational mechanisms, the Government lacks the technical capability and system-specific operational expertise necessary to process, harmonize, validate, and integrate the data into a finalized 2025 Harmonized and Integrated Database (HID) within the HEHR environment.

Performance requires operational knowledge of the HEHR architecture, existing system configurations, data processing pipelines, and integration methodologies established by BAH under prior NHCS and HEHR contracts. Transitioning the requirement to another contractor would require substantial duplication of effort to recreate environments, revalidate integrations, establish operational familiarity with the HEHR environment, and redevelop processing workflows, resulting in significant delays, increased costs, and unacceptable mission risk.

The finalized HID is necessary to support production of national inpatient and emergency department estimates and fulfill ongoing NHCS mission requirements. Accordingly, only BAH can perform the requirement within the required timeframe and operational environment without unacceptable disruption to Government operations.

GSAM/R 538.7104-3(b)(1)(i)- The need is of such unusual urgency that following the procedures would result in unacceptable delays in fulfilling that need.

GSAM/R 538.7104-3(b)(1)(ii)- Only one source is capable of providing the products, services, or solution required at the level of quality required because the products, services, or solutions are unique or highly specialized.

GSAM/R 538.7104-3(b)(1)(iii)- The order should be issued on a sole source basis in the interest of economy and efficiency because it is a logical follow-on to an FSS order already issued on a competitive basis.

GSAM/R 538.7104-3(b)(1)(iv)- It is necessary to place the order with a particular FSS contractor to satisfy a minimum guarantee established in the FSS BPA.

. GSAM/R 538.7104-3(b)(1)(v)- A law expressly authorizes or requires that the purchase be made from a specified source.

5. Market Research:

Market research determined that while multiple BPA vendors demonstrated partial capability, only BAH can perform within the existing HEHR operational environment without disruption.

The requirement must be executed within a live, integrated production system with established configurations, workflows, and stakeholder coordination. Transitioning to another contractor would require establishing development environments, revalidating system integrations, and re-coordinating with stakeholders, resulting in operational disruption and increased performance risk. Accordingly, only BAH can meet the requirement within the required timeframe without unacceptable mission impact.

Market research determined that the requirement cannot be segmented for performance by multiple vendors due to its non-severable nature. The work must be executed as a continuous, integrated effort within the HEHR environment, and dividing the requirement or introducing a transition would disrupt ongoing operations and degrade data quality. As a result, alternative approaches, including partial competition, would not meet the Government’s needs.

6. Procurement history:

a. Contractor: Booz Allen Hamilton Contract or Order Number: 75D30119F06803 (Electronic Data Collection and Processing for the NHCS) Award Date and Period of Performance: 09/23/2019-09/22/2024 Value (including all options):

b. Contractor: Booz Allen Hamilton Contract or Order Number: 75D30122F15087 (HEHR Cloud Migration) Award Date and Period of Performance: 09/01/20222-08/14/2023 Value (including all options):

c. Contractor: Booz Allen Hamilton

Contract or Order Number: 75D30122F15721 (Collection of Electronic Health Record Data from Federally Qualified Health Centers Sampled in the NAMCS) Award Date and Period of Performance: 09/30/2022-07/31/2025 Value (including all options):

7. Actions to Foster Competition for Future, Similar Requirements:

NCHS will examine the barriers that led to restricted consideration for this task order by taking strategic measures, the agency can enhance the transition process and facilitate smoother integration in the future. Early planning and coordination is essential. The agency will begin early discussions with both the outgoing and incoming contractors. This will allow for a seamless transition and ensure that the new Contractor understands the intricacies of the HEHR system.

Configuring the HEHR infrastructure is a complex and time-intensive process, taking approximately 6-8 months. To expedite this process, the Office of the Chief Information Officer (OCIO) will work closely with the new contractors. Specific actions will include documenting the existing system architecture and configuration, collaborating with the new contractors to map out necessary changes, and providing training sessions to ensure a seamless transition.

9. Technical or Requirements Program Management Certification: I certify 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.

Manisha Sengupta COR & Deputy Director, DHCS Signature &

Date:

10. Best Value Determination: As the contracting officer, I hereby determine that the anticipated price to the Government for this contract action represents the best value for the Government. As the contracting officer, I hereby determine that the anticipated price to the Government for this contract action represents the best value for the Government.

Based on review of the BAH BPA, for which pricing was determined fair and reasonable through a competitive process, the Contracting Officer determined issuing a sole source Task Order represents the best value to the Government IAW FAR subpart 8.4. The determination considered the BPA holder's demonstrated technical capability, unique qualifications and ability to meet the Government's requirements efficiently, while mitigating unnecessary risk to the requirement timelines, and costly administrative burdens to the Government. Consistent with streamlined ordering guidance, comparison of the proposed task order pricing to the established BPA rates and relevant market indicators confirms the price remains fair and reasonable for the requirement.

11. Contracting Officer (CO) Certification and Approval: I hereby certify that this justification is accurate and complete to the best of my knowledge.

6/24/2026

X Ann Bonis Right-Click "Signature Setup"

Signed by: PIV

Ann Bonis Contracting Officer Signature &

Date: