Justification and Approval Complete_Redacted.pdf

Attachment 1: Sole Source Justification

VHAPG Part 806.3 OFOC Page 1 of 6 Revision: 04 Effective Date: 12/15/25 Acquisition ID#: 36C255-26-AP-3131

DEPARTMENT OF VETERANS AFFAIRS

Justification and Approval (J&A)

For Other Than Full and Open Competition (>SAT)

Short Term Sole Source Contract for Beneficiary Ambulance Services

Acquisition Plan Action ID: 36C255-26-AP-3131

1. Contracting Activity:

Department of Veterans Affairs, Network Contracting Office (NCO) 15 and Eastern Kansas Health Care System supporting the Dwight D. Eisenhower VA Medical Center located at 4101 S. 4th St, Leavenworth, KS 66048 and Colmery-O'Neil VA Medical Center located at 2200 Gage Blvd, Topeka, KS 66622.

2237:

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

The Eastern Kansas Health Care System (EKHCS), including its main campuses in Leavenworth and Topeka, associated Community-Based Outpatient Clinics (CBOCs), and affiliated clinics, requires continuous, uninterrupted ground ambulance transportation services to support Veteran access to care.

Under this action, the contractor shall furnish all personnel, management, vehicles, equipment, supplies, dispatch capability, VetRide Vendor Portal integration, licensing, insurance, and reporting necessary to provide emergent and non-emergent stretcher ambulance transport, Basic Life Support (BLS), Advanced Life Support (ALS), and Critical Care Transport (CCT) Tier I–III services on a 24 hours per day, 7 days per week basis, including weekends and holidays.

Services shall be performed in accordance with the EKHCS Performance Work Statement (PWS), “AMBULANCE (Ground),” which incorporates Federal Specification KKK-A-1822F, Kansas EMS regulations, applicable Department of Transportation rules, Joint Commission standards, and VA clinical, privacy, and security requirements.

The contemplated contract type is firm-fixed-price, indefinite-delivery/indefinite-quantity (IDIQ), with unit prices established for the Schedule of Services, Price Schedule (e.g., A0422 ALS1 emergency transport, A0429 BLS non-emergency transport, A0426 non-emergent ALS1, A0434 critical care transport, psychiatric transport, additional beneficiary transport, mileage outside base rate, and waiting time), consistent with historical EKHCS utilization under contract 36C25521D0017.

The estimated value of this bridge contract for the 12-month ordering period is $750,000.00, based on historical transport volumes, mileage, and wait time charges and assuming similar demand patterns as the current contract.

The period of performance will be a one-year ordering period beginning August 1, 2026, immediately following expiration of contract 36C25521D0017 on July 31, 2026, with no options contemplated under this J&A; only the minimum quantity of services necessary to avoid a break in critical medical transportation will be ordered under this urgent bridge.

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

The contractor shall furnish all labor, supervision, vehicles, equipment, licensing, insurance, communications capability, GPS tracking, VetRide integration, safety and privacy compliance, training, and attendant support necessary to provide continuous beneficiary transportation services.

Required services include 24/7 wheelchair vans, stretchers, bariatric, and sedan transportation; pick-up and drop-off at VA medical centers, community-based outpatient clinics, non-VA medical facilities, residences, and commercial transit hubs; and compliance with all applicable vehicle, driver, attendant, safety, and operational requirements identified in the performance work statement (PWS).

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These services directly support oncology, dialysis, primary care, mental health, rehabilitation, and emergency care operations. Any interruption in transportation would impair Veteran access to care and could delay or prevent medically necessary appointments, transfers, and discharges.

The anticipated period of performance is 8/1/2026 – 7/31/2027.

Estimated Value:

4. Statutory Authority Permitting Restricted Competition:

RFO 12.102(b) Simplified Procedures for Certain Commercial Items. The statutory authority for applying the Simplified Procedures for Commercial Items of RFO 12.102(b) is 41 U.S.C. § 1901 and is implemented by RFO 12.102(b) for restricting competition on this procurement. Competition is restricted on this procurement for the reason below:

(x) (2) Unusual and Compelling Urgency per 41 USC §3304(a)(2) as implemented by RFO 6.103-2;

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 “Unusual and Compelling Urgency” authority is applicable as the current EKHCS ambulance contract expires July 31, 2026, and failure to award a follow-on bridge contract before that date will result in a break in critical medical transportation services and significantly impair Veteran access to care and constituting serious injury to the Government and Veteran patients.

This bridge contract is limited to the minimum services necessary to avoid disruption, and competition for a longer-term follow-on requirement will be pursued once sufficient time exists for licensing, fleet staging, VetRide integration, and staffing by additional vendors.

Techs Inc is the incumbent contractor for EKHCS Emergency Ambulance Transportation Services under contract 36C25521D0017 and is currently performing emergent and non-emergent stretcher, BLS, ALS, and CCT Tier I–III transports across EKHCS’s service area.

Market research conducted in July 2026 confirmed that Techs Inc:

Holds active Kansas EMS licensing covering the EKHCS counties and zip codes listed in the PWS service area, enabling ambulance operations across the full geographic scope.

Maintains 24/7 ALS and CCT fleets, including vehicles capable of supporting one CCT Tier III transport concurrently with three additional stretcher/BLS/ALS transports as required by the PWS.

Has fully implemented VetRide Vendor Portal integration, including the ability to receive and respond to electronic trip requests, use VA-issued vendor passes, submit electronic HCFA-1500 claims, and update trip status and notes in real time.

Employs staff meeting PWS-specified qualifications (EMT, paramedic, CCTP licensure and certification), TB testing, background investigations, HIPAA and OSHA compliance, and VA security and privacy requirements.

EKHCS contract records for 36C25521D0017 show that Techs Inc has consistently met PWS response time standards for emergent and urgent transports (generally within 30–60 minutes) and maintained acceptable performance for scheduled transports within the required ±15-minute windows.

Techs Inc performs all ambulance services in-house, without subcontracting, using its own vehicles, equipment, and personnel, and has demonstrated reliable VetRide usage, invoice timeliness, and compliance with EKHCS clinical and administrative requirements.

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By contrast, SAM.gov and SBA Dynamic Small Business Search (DSBS) queries under NAICS 621910 and keywords “ambulance,” “EMS,” and “medical transport” within a 250-mile radius identified other ambulance providers, but none with the combination of:

Current Kansas EMS licensing covering the EKHCS service area.

Established CCT Tier III capability with drug and equipment inventories aligned to EKHCS Attachment A

Critical Care Transport Capabilities Confirmation.

24/7 fleet readiness and staffing sufficient to meet EKHCS’s simultaneous transport and response-time requirements.

Existing VetRide integration and demonstrated ability to comply with EKHCS’s detailed PWS requirements by August 1, 2026.

Transitioning EKHCS’s ambulance services to a non-incumbent provider would require substantial lead time for state EMS licensing, fleet acquisition and staging, credentialing and background checks, TB testing, VetRide interface onboarding, and staff training on PWS and VA protocols.

This lead time is incompatible with the immediate need to avoid a break in service at contract expiration, and attempting to stand up a new provider at this juncture would cause unacceptable delays in fulfilling the agency’s requirements and risk serious injury to Veteran care.

Accordingly, Techs Inc is the only firm capable of providing the supplies and services described in Section 3 above without the Veterans Health Administration experiencing substantial duplication of cost that could not be expected to be recovered through competition and unacceptable delays in fulfilling its requirements.

This conclusion is based on the following: Techs Inc already has fully licensed EMS coverage across the EKHCS service area, a 24/7 ALS/CCT Tier I–III fleet, trained personnel meeting all PWS clinical and security requirements, and proven VetRide integration, all currently in use under the incumbent contract. Awarding the short-term bridge to a new provider would require recreating these capabilities, obtaining licenses, acquiring and staging vehicles and CCT equipment, credentialing and training staff through EKHCS processes, and implementing VetRide and compliance programs, at significant additional cost that cannot reasonably be recovered over the limited bridge period. Given the imminent expiration of the current contract and the critical nature of ambulance services to Veteran access to care, the time required for a non-incumbent to become fully operational, credentialed through EKHCS, and compliant would cause service disruptions and delays that the Government cannot accept.

6. Description of Efforts Made to ensure that offers are solicited from as many potential sources as possible (including whether a notice was or will be publicized as required by RFO Part 5 and, if not, which exception under RFO Part 5 applies):

In light of the urgent need to avoid a break in ambulance services at EKHCS, the Contracting Officer focused market research and outreach on identifying any potentially capable and available sources rather than issuing a formal competitive solicitation for this short-term bridge. As documented in the Market Research Report dated July 21, 2026, EKHCS conducted the following efforts:

Reviewed the SBA Veteran Small Business Certification (VetCert) / Small Business Search (SBS) database under NAICS 621910 (Ambulance Services) using a Kansas statewide geographic filter to identify verified SDVOSB and VOSB firms capable of meeting the EKHCS PWS requirements and start-of-performance date. No such firms were identified.

Queried SAM.gov and SBA Dynamic Small Business Search (DSBS) using NAICS 621910 and the keywords “ambulance,” “EMS,” and “medical transport” within a 250-mile radius of EKHCS, and screened identified firms for Kansas EMS licensing, 24/7 ALS/CCT capability, and VetRide integration.

While several providers exist in the broader marketplace, none other than Techs Inc currently possesses the

VHAPG Part 806.3 OFOC Page 4 of 6 Revision: 04 Effective Date: 12/15/25 Acquisition ID#: 36C255-26-AP-3131 full combination of licensing, fleet, staffing, and VetRide capability required to meet the EKHCS PWS by August 1, 2026.

Reviewed EKHCS acquisition history and internal contract records for contract 36C25521D0017 to confirm demand patterns, performance requirements, and incumbent performance experience, and consulted EKHCS program staff regarding operational feasibility of transitioning services to another provider within the available timeframe.

Given the imminent expiration of the current contract, the time required for any non-incumbent to obtain EMS licensure across the EKHCS service area, acquire and stage an ALS/CCT fleet, complete credentialing and background checks through EKHCS, and implement VetRide integration, the Contracting Officer determined that conducting a competitive procurement for this bridge period would not be practicable without risking a disruption in critical ambulance services.

Accordingly, no sources-sought notice or full competitive solicitation was issued for this interim action, and this justification requests approval to proceed with a sole-source award to Techs Inc for the minimum quantity of services necessary to maintain continuity of care.

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

The Contracting Officer has determined that the anticipated cost of this contract is fair and reasonable based on the following considerations:

The estimated contract value of for the 12-month ordering period is derived from historical utilization and pricing under the current EKHCS Emergency Ambulance Transportation Services contract, 36C25521D0017, including average annual transport counts by service type (stretcher, BLS, ALS, CCT), mileage, and wait-time charges.

The unit prices in the Schedule of Services – Price Schedule (e.g., A0422 ALS1 emergency transport, A0429 BLS non-emergency transport, A0426 non-emergent ALS1, A0434 critical care transport, mileage outside the base rate, and waiting time) are based on Techs Inc’s incumbent rates, which were previously determined fair and reasonable through competition or price analysis and remain consistent with customary commercial practices for ambulance services in the region.

Market research confirms that ambulance transport is a commercial service typically priced on a per-trip, mileage, and time basis, and that EKHCS’s rate structure aligns with prevailing industry standards for licensed ambulance companies providing BLS, ALS, and CCT services.

Prior EKHCS experience with Techs Inc under contract 36C25521D0017 demonstrates that billed charges have been within expected ranges for the level of service provided and consistent with VA ambulance contracts at other facilities, with no indication of excessive pricing or unbalanced rates.

Before award, the Contracting Officer will request a quote from Techs Inc and perform a price analysis comparing the proposed unit prices and estimated annual spend to: (1) historical EKHCS contract pricing and utilization, and (2) available pricing information from similar VA ambulance contracts, to verify that the proposed bridge pricing remains fair and reasonable. If necessary, the Contracting Officer will negotiate downward adjustments to ensure that the final contract pricing is supported by this analysis.

8. Description of the Market Research Conducted and the Results, or a Statement of the Reasons Market Research Was Not Conducted:

In accordance with FAR Part 10 and VAAR 810.001-70, the Contracting Officer conducted and documented market research for this requirement in the EKHCS Emergency Ambulance Transportation Services Market Research Report, dated July 21, 2026. Market research included: (1) review of the SBA Veteran Small Business Certification (VetCert)/Small Business Search (SBS) database under NAICS 621910 using a Kansas statewide filter to identify verified SDVOSB/VOSB firms; (2) searches of SAM.gov and SBA Dynamic Small Business Search (DSBS) under NAICS 621910 and the keywords “ambulance,” “EMS,” and “medical transport” within a

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250-mile radius of EKHCS; (3) review of acquisition history and performance under contract 36C25521D0017;

and (4) consultation with EKHCS program staff regarding operational requirements and vendor capabilities.

This research determined that no verified SDVOSB/VOSB firms in Kansas were capable of meeting the EKHCS PWS requirements within the necessary timeframe and that, while other ambulance providers exist in the broader marketplace, none other than Techs Inc currently possesses the full combination of Kansas EMS licensing for the EKHCS service area, 24/7 ALS/CCT Tier I–III fleet capability, VetRide Vendor Portal integration, and credentialed staff able to meet EKHCS clinical, security, and response-time standards by August 1, 2026.

Ambulance services are commercial in nature and customarily offered under firm-fixed-price, unit-rate structures that align with the EKHCS Schedule of Services but identified non-incumbent firms would require substantial lead time to obtain licenses, stage fleets, complete EKHCS credentialing, and implement VetRide and PWS-specific processes. Accordingly, the VA Rule of Two cannot be satisfied for this urgent bridge requirement, and Techs Inc is the only source currently identified that can provide uninterrupted services in accordance with the PWS by the required start date.

The contracting activity will continue outreach and market research during the bridge period to support the follow-on competitive acquisition and to remove barriers to future competition

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

Additional facts supporting the use of other than full and open competition include the following:

The EKHCS ambulance requirement is highly specialized, combining emergent and non-emergent stretcher, BLS, ALS, and CCT Tier I–III services; strict response-time standards; multi-county geographic coverage; continuous 24/7 operations; and mandatory VetRide integration, all defined in a detailed PWS that has been refined over multiple contract cycles. Developing and competing a new set of specifications for a short-term bridge would not yield additional qualified sources and would delay award beyond the current contract’s expiration.

A new contractor would need to be credentialed through EKHCS, complete TB testing and VA background investigations for staff, implement EKHCS-specific clinical and administrative protocols, and undergo facility onboarding and performance monitoring. These steps, combined with licensing and fleet stand-up, cannot be accomplished in time to prevent a break in service.

Techs Inc performs all ambulance services in-house with its own vehicles, equipment, and personnel, exceeding limitations on subcontracting requirements and providing a single point of accountability for safety, clinical quality, and compliance.

Given the urgent and compelling need to avoid disruption of critical ambulance services and the absence of other fully capable sources that can meet all EKHCS requirements by the required start date, it is not practicable to develop requirements or conduct a competitive procurement for this bridge period. For the longer-term follow-on requirement, EKHCS and the Contracting Officer intend to reassess market conditions, update the PWS as appropriate, and explore competitive acquisition strategies once sufficient time exists for additional vendors to obtain licensing, fleet, VetRide, and EKHCS credentialing necessary to compete.

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

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: