JOTFOC - 26000079 - Injury Coding Center Bridge Contract_SIGNED.pdf

U.S. Department of Transportation

National Highway Traffic Safety Administration

Justification for Other than Full and Open Competition (JOTFOC)

Bridge Contract – Crash Investigation Sampling System (CISS) Injury Coding Center (ICC)

Authority: 41 U.S.C. 3304(a)(1) and FAR 6.302-1(b)(1)(i), Only One Responsible Source

1. Identification of Agency:

The Agency for this acquisition is the U.S. Department of Transportation (DOT), National Highway Traffic Safety Administration (NHTSA), Office of Acquisition Management (OAM), 1200 New Jersey Avenue, SE, Washington, DC 20590.

2. Description of Action:

NHTSA proposes to award a new sole-source bridge contract to American Automotive Safety Research (AASR) under the authority of 41 U.S.C. 3304(a)(1) and FAR 6.302-1, Only One Responsible Source. The current contract expires on June 20, 2026. This bridge contract will ensure uninterrupted support for the Crash Investigation Sampling System (CISS) Injury Coding Center (ICC).

The anticipated period of performance includes a 12-month base period and one 12-month option period. This bridge action is required to maintain mission-critical injury coding for investigative operations while NHTSA completes the competitive acquisition process for the follow-on requirement.

3. Description of Supplies/Services and Estimated Value:

The National Highway Traffic Safety Administration (NHTSA) requires continued contractor support for the Crash Investigation Sampling System (CISS) Injury Coding Center (ICC) to fulfill its statutory authority under 23 U.S.C. §403 to conduct research, data collection, and analysis in support of motor vehicle traffic safety.

The CISS program is NHTSA’s primary field investigation-based crash data collection system and consists of three integrated components: (1) the Primary Sampling Unit (PSU) Operations Center, (2) the Quality Control Center (QCC), and (3) the Injury Coding Center (ICC). This acquisition is limited to the ICC component.

The ICC performs highly specialized medical injury coding and data processing services in support of nationwide crash investigations. The contractor is responsible for:

● Conducting detailed clinical assessments of occupant injuries resulting from motor vehicle crashes;

● Reviewing, analyzing, and interpreting medical records, trauma documentation, diagnostic reports, and related clinical materials;

● Coding injuries using standardized injury severity classification systems, including the Abbreviated Injury Scale (AIS), and other NHTSA-approved coding methodologies;

● Ensuring accuracy, consistency, and completeness of injury coding data prior to submission;

● Processing, validating, and transmitting coded injury data to the National Center for Statistics and Analysis (NCSA);

● Providing technical expertise and consultation regarding injury coding standards, methodology updates, and data quality improvements.

These services require specialized subject matter expertise, knowledge of crash injury epidemiology, and familiarity with NHTSA’s established CISS injury coding protocols and data systems.

The estimated value of this bridge contract is $4,764,706 ($2,346,707 Base Year and $2,417,999 OY1) for the anticipated bridge period of performance. This bridge action will ensure continuity of mission-critical injury coding operations while NHTSA completes the competitive acquisition process for the follow-on requirement.

Failure to maintain uninterrupted ICC services would delay crash investigation processing, adversely affect injury data accuracy and timeliness, and disrupt NHTSA’s ability to meet statutory data collection and reporting obligations.

4. An identification of the statutory authority permitting other than full and open competition.

This acquisition is conducted pursuant to 41 U.S.C. § 3304(a)(1), as implemented by FAR 6.302-1(b)(1)(i), which authorizes contracting without full and open competition when only one responsible source is capable of satisfying the agency’s requirements and no other supplies or services will meet those requirements.

NHTSA has determined that the incumbent contractor is the only responsible source capable of providing uninterrupted Injury Coding Center (ICC) services during the bridge period while the competitive acquisition for the follow-on requirement is completed.

5. Demonstration that the Proposed Contractor’s Unique Qualifications or the Nature of the Acquisition Requires Use of the Authority Cited:

The proposed contractor, AASR, is the incumbent provider of CISS Injury Coding Center (ICC) services and possesses unique institutional knowledge, technical expertise, and system familiarity that are essential to ensuring continuity of operations during the bridge period.

AASR has supported the U.S. Department of Transportation (DOT) and NHTSA for over ten (10) years in performing specialized injury coding, quality control, and injury causation analysis under the CISS program. The contractor’s principal personnel possess more than twenty-five (25) years of experience in injury coding quality control and have extensive familiarity with NHTSA-specific coding methodologies, protocols, internal review standards, and system interfaces.

The ICC function requires not only application of the Abbreviated Injury Scale (AIS) coding system, but also integration with NHTSA’s established CISS case management processes, medical record interpretation standards, injury causation methodologies, and data validation procedures. The contractor performs detailed linkage of occupant injuries to vehicle components and environmental sources across approximately 9,500 crash investigation cases annually generated by seventy-three (73) Primary Sampling Units (PSUs).

The ICC services are closely integrated with the CISS Primary Sampling Unit (PSU) Operations Center and Quality Control Center (QCC). AASR’s familiarity with existing workflows, data structures, and quality control processes enables timely and accurate injury coding that supports national crash data reporting and research.

Transitioning to a new contractor during the bridge period would require significant ramp-up time to establish personnel security clearances, system access, medical record handling protocols, AIS coding calibration, and quality control alignment. Such transition would introduce substantial risk of data inconsistency, processing delays, and disruption to ongoing crash investigations and national reporting timelines.

Due to the highly specialized nature of the ICC function, the integration with existing CISS infrastructure, and the immediate need to maintain uninterrupted injury coding operations, AASR is the only responsible source capable of meeting the Government’s requirements during the bridge period while the competitive acquisition for the follow-on requirement is completed.

6. Description of efforts made to ensure that offers are solicited from as many potential sources as is practical.

In accordance with FAR Subpart 5.2, “Synopses of Proposed Contract Actions,” NHTSA will publish a notice of intent to award this bridge contract on SAM.gov to provide public notification of the proposed action.

This notice will afford potential sources the opportunity to express interest and demonstrate capability to satisfy the Government’s requirements during the bridge period.

The Justification for Other Than Full and Open Competition will be made publicly available in accordance with FAR 6.305, “Availability of Justification.”

Competition is not feasible for this bridge action due to the specialized nature of the CISS Injury Coding Center services, the incumbent contractor’s integration with existing systems and processes, and the significant transition risk associated with introducing a new contractor during ongoing crash investigation operations.

This bridge contract is a temporary measure to maintain uninterrupted mission support while NHTSA completes the competitive acquisition process for the follow-on requirement. The follow-on contract will be competed in accordance with applicable procurement regulations to maximize participation and ensure fair opportunity.

7. A Determination by the Contracting Officer that the Anticipated Cost to the Government will be Fair and Reasonable:

The Contracting Officer has determined that the anticipated pricing will be fair and reasonable based on the historical pricing from prior NHTSA motor vehicle crash data collection contracts and the labor rates as set forth in AASR’s contract and in accordance with the Service Contract Act Wage Determination.

In NHTSA’s experience, AASR has historically remained within the cost parameters of the contract and has consistently been rated as satisfactory or better for cost control in performance reviews.

This combination of historical pricing analysis, wage determination compliance, and strong cost control performance provides the Contracting Officer with a high degree of confidence that the anticipated cost for this bridge contract is fair and reasonable in accordance with FAR 6.303-2(a)(7).

8. A Description of the Market Research Conducted and the Results or a Statement of the Reason That Market Research Was Not Conducted:

NHTSA conducted comprehensive market research in July and September 2024 to assess the availability of qualified sources capable of performing the CISS Injury Coding Center (ICC) requirements.

Market research activities included:

● Review of Acquisition Gateway and GSA eLibrary

● Review of GSA OASIS and MAS vendors under NAICS 541990

● Review of similar contracts and industry capability documentation

● Publication of a Sources Sought Notice

● Placement of a Request for Information (RFI) through GSA’s Market

Research as a Service (MRAS) tool

The Sources Sought Notice resulted in three capability statements, including the incumbent contractor, American Automotive Safety Research (AASR), and two other vendors. Additional responses were received through the MRAS tool.

The market research confirmed that while there are firms with general crash research or analytical experience, no other vendor demonstrated the existing infrastructure, trained AIS-certified injury coding personnel, operational familiarity with the seventy-three (73) Primary Sampling Units (PSUs), established medical record handling protocols, and immediate deployment capability necessary to perform the ICC requirement without substantial transition time and program disruption.

The ICC requirement involves large-scale injury coding using the Abbreviated Injury Scale (AIS), immediate intake and processing of high-volume crash cases (approximately 9,500 annually when fully operational), and coordination with multiple data collection centers. Performance requires personnel with specialized AIS coding expertise, familiarity with NHTSA-specific coding protocols, and secure handling of sensitive medical records.

Although certain vendors indicated general capability, none demonstrated the ability to deploy fully trained and qualified personnel at the required scale within the limited timeframe of this bridge action without incurring significant transition costs, delays, and interruption of nationally representative crash data collection.

Accordingly, the market research concluded that AASR is the only responsible source capable of performing the required services within the necessary timeframe to avoid interruption of mission-critical CISS operations.

This bridge contract is a temporary measure to maintain continuity while the follow-on requirement is competed.

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

The CISS Injury Coding Center (ICC) function is mission-critical to NHTSA’s ability to collect, process, and analyze nationally representative crash injury data.

Any interruption in ICC services would result in delays in injury coding, disruption to data integration from the seventy-three (73) Primary Sampling Units (PSUs), and potential gaps in nationally representative crash data collection.

The ICC requirement involves the application of the Abbreviated Injury Scale (AIS) coding system to high volumes of medical records, development of injury causation scenarios, and secure handling of sensitive medical information.

Performance requires personnel with specialized AIS certification, familiarity with NHTSA’s established coding protocols, and experience working within the CISS operational framework.

The incumbent contractor currently maintains trained personnel, operational workflows, quality control procedures, and data integration processes necessary to perform the requirement without delay. Transitioning to a new contractor at this stage would require significant ramp-up time for recruitment, AIS training, medical record security onboarding, and coordination with PSUs, which would result in unacceptable disruption to the CISS program.

This bridge action is limited in scope and duration and is necessary to maintain continuity of operations while NHTSA completes the competitive acquisition for the follow-on requirement. The need for this bridge is not the result of lack of advance planning, but rather the time required to complete the competitive acquisition process for a complex, specialized requirement.

Failure to award this bridge contract would significantly impair NHTSA’s ability to fulfill its statutory mission to improve motor vehicle traffic safety through timely crash investigation and injury data analysis.

10. A Statement of the Actions, if any, the Agency May Take to Remove or Overcome Any Barriers to Competition Before Any Subsequent Acquisition for These Services:

This bridge contract is a temporary measure necessary to maintain continuity of CISS Injury Coding Center operations while NHTSA completes the competitive acquisition for the follow-on requirement.

To promote full and open competition for the subsequent acquisition, NHTSA will take the following actions:

● Advance Acquisition Planning: Continue early and comprehensive acquisition planning to ensure sufficient lead time for development, solicitation, and award of the follow-on contract prior to expiration of this bridge action.

● Expanded Market Research: Update and expand market research to identify capable sources, including targeted outreach to small businesses and firms with AIS-certified injury coding and crash research experience.

● Industry Engagement: Utilize industry engagement tools such as Requests for Information (RFIs), industry days, and pre-solicitation conferences to obtain feedback on draft requirements, encourage participation, and assess vendor capability.

● Requirement Structuring Review: Evaluate the structure of the follow-on requirement, including contract type, performance approach, and potential segmentation of work, to reduce barriers to entry where practicable.

● OCI and Contract Structure Review: Assess organizational conflict of interest (OCI) considerations and contract structures to ensure they do not unnecessarily restrict competition in the future acquisition.

11. Contracting Officer Certification That the Justification Is Accurate and Complete to the Best of the Contracting Officer’s Knowledge and Belief:

As confirmed by the signature below, the Contracting Officer hereby certifies that the facts and representations included in this justification are accurate and complete to the best of her knowledge and belief.

SIGNATURE PAGE

TECHNICAL/REQUIREMENTS CERTIFICATION

I certify that the facts and representations under my cognizance which are included in this justification are complete and accurate to the best of my knowledge and belief.

Technical Cognizance :

Paul Barron (COR) Date

I certify that this justification is accurate and complete to the best of my knowledge and belief.

Sherese Gray Date Contracting Officer (CO)

Date

Date

PAUL DENNIS BARRON Digitally signed by PAUL DENNIS BARRON Date: 2026.03.02 07:11:44 -05'00'

SHERESE A GRAY

Digitally signed by SHERESE A

GRAY

Date: 2026.03.16 11:31:07 -04'00'

SHERESE A GRAY

Digitally signed by SHERESE A

GRAY

Date: 2026.03.19 08:05:21 -04'00'

SEAN METRICE

CLAYTON

Digitally signed by SEAN

METRICE CLAYTON

Date: 2026.05.07 17:38:06 -04'00'

Signature Pg_JOTFOC - 26000079 - Injury Coding Center Bridge Contract.pdf