Justification and Approval.pdf

Request for Sole Source Justification Format >SAT

VHAPG Part 806.3 OFOC Page 1 of 5 Revision: 04 Effective Date: 12/15/25 Acquisition ID#: 36C241-26-AP-0912

DEPARTMENT OF VETERANS AFFAIRS

Justification and Approval (J&A) For

Other Than Full and Open Competition (>SAT)

Acquisition Plan Action ID: 36C241-26-AP-0912

1. Contracting Activity: Department of Veterans Affairs, VISN 01, VA Connecticut

Medical Center. Purchase request number 689-26-2-7304-0001.

2. Nature and/or Description of the Action Being Approved: This is a new contract that will be a Firm Fixed Price (FFP) service contract for providing Residential Rehabilitation Treatment Program (RRTP) and Post-Traumatic Stress Disorder (PTSD) beds. This short-term contract period allows time for the necessary processes to take place for implementing a new, long-term contract without causing any service interruptions. Essentially, it serves as a bridge to maintain continuity of care while a comprehensive long-term contract is being finalized and put into place.

It is requested to enter a Sole Source procurement for RRTP/PTSD beds needed for the VA Connecticut Healthcare System (VACHS). These inpatient residential beds located in the community provide for the much needed home like environment within close geographic location to VACHS West Haven Campus, so the VA Mental Health (MH) RRTP program teams and providers manage and provide all clinical programming to the Veterans during their stay. This hybrid-style model of care is needed within very close proximity, not more than 10-15 minutes’ drive so the RRTP/PTSD providers can easily access the residence. VA leadership has recognized the ongoing need for RRTP/PTSD beds to maintain continuity of care for the Veteran population at VACHS.

3. Description of Supplies/Services Required to Meet the Agency’s Needs: The total estimated cost for this contract is $1,539,700.00 for a period of performance (POP) of 2/1/2026- 4/30/2026. Firm Fixed rate for the RRTP is $475.00 each bed day of care (BDOC) for eighteen (18) beds and for the PTSD residential beds is $875.00 each BDOC for ten (10) beds. The firm fixed rate is all inclusive and covers the necessary services for a length of stay (LOS) up to twenty-one (21) days and not to exceed (NTE) twenty-eight (28) days for RRTP and fifty-six (56) days NTE sixty-three (63) days for PTSD. Continuum of Care Inc. provides residential and housing in the community with a homelike environment with close geographic location to VACHS. Veterans are clinically assessed and evaluated by the VISN 01 centralized screening committee and if accepted, referred into one (1) of the treatment specialty beds. A Liaison within VACHS MHRRTP program will be assigned to oversee and assist as in past practice with this contract. Transportation is then arranged for transfer to the program.

VHAPG Part 806.3 OFOC Page 2 of 5

Acquisition ID#: 36C241-26-AP-0912

4. Statutory Authority Permitting Other than Full and Open Competition:

( x ) (1) Only One Responsible Source and No Other Supplies or Services Will

Satisfy Agency Requirements per 41 USC §3304(a)(1) as implemented by

RFO 6.103-1;

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

( ) (3) Industrial Mobilization, Engineering, Developmental or Research Capability or Expert Services per 41 USC §3304(a)(3) as implemented by RFO 6.103-3;

( ) (4) International Agreement per 41 USC §3304(a)(4) as implemented by RFO 6.103-4

( ) (5) Authorized or Required by Statute per 41 USC §3304(a)(5) as implemented by RFO 6.103-5;

( ) (6) National Security per 41 USC §3304(a)(6) as implemented by RFO 6.103-6;

( ) (7) Public Interest per 41 USC §3304(a)(7) as implemented by RFO 6.103-7;

5. Demonstration that the Contractor’s Unique Qualifications or Nature of the Acquisition Requires the Use of the Authority Cited Above (applicability of authority): Continuum of Care Inc., has extensive experience and a proven track record of successfully supporting Veterans within close geographic proximity to the VA Connecticut Healthcare System, West Haven campus. The services provided by Continuum of Care Inc. allow VACHS Veterans to receive care in a residential-like setting, where they can benefit from clinical programming provided by the VACHS Mental Health RRTP staff and this ease of access is imperative to the veteran’s overall treatment process. The treatment regime includes a comprehensive assessment to develop individualized service plans by utilizing the interdisciplinary team approach in collaborating with the Veteran’s outpatient and other community providers. The services provided include at a minimum, case management and residential support, life skills training that covers areas of cooking, budgeting and personal grooming to maximize independence, as well as learning to make healthy choices; opportunities for socialization through participation in group activities to enhance integration into the community and support in the development of independent skills and interests including employment or other natural supports.

Resulting in the average LOS of 21-28 days for RRTP and 56-63 days for PTSD.

During this comprehensive and coordinated residential care provided by Continuum of Care Inc., the Veterans have structured daily activities that focus on mental health and/or substance abuse recovery needs. Daily and regular on-site supervision and monitoring of Veterans on 24-hour basis. This includes monitoring the needs of the Veterans to ensure while in the RRTP/PTSD beds that they receive the services, care and resources necessary to protect their health, safety and overall well-being.

The incumbent contractor, Continuum of Care Inc. has been providing RRTP and PTSD beds to the VA Connecticut Healthcare System since 2021 under contract #36C24121C0020. Continuum of Care Inc. offers a unique hybrid residential treatment model that integrates VA clinical programming with community-based housing in a home-like environment. This model is tailored to VACHS requirements and is not currently available from other providers in the area.

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The incumbent contractor’s familiarity with the program and patients ensures continued high-quality care without the inefficiencies and potential risks associated with bringing a new contractor up to speed. This short-term contract will allow for continued services without interruption, which is critical for Veterans enrolled in the RRTP and PTSD residential programs. Interruption of services is not an option due to the clinical and safety needs of the Veterans at VACHS.

The key qualifications that make Continuum of Care Inc. the only responsible source are the contractor’s ability to successfully provide critical care services to Veterans with a consistent record of meeting performance standards for over five (5) years and ensuring continuity of care through case management and residential support as described above. The contractor’s facilities are located within 10-15 minutes of the VACHS West Haven Campus, enabling VA Mental Health RRTP teams to provide essential on-site clinical programming and oversight. Continuum of Care Inc.

has demonstrated having the necessary infrastructure, trained staff, and familiarity with VA protocols to ensure seamless coordination with VA clinical teams immediately upon award, without requiring a transition period.

Continuum of Care Inc. can meet the requirement in its entirety immediately upon award of this short-term contract and no other contractor can satisfy the agency’s needs as defined. Therefore, under 41 USC §3304(a)(1) and RFO 6.103-1(b), Continuum of Care Inc. is the only responsible source capable for this short-term contract.

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): The Mental Health Service Line has done an extensive search to locate facilities that may provide the same and/or comparable residential services within the geographic location area, but none were located that met the emergent standard of care, direct access and geographical requirement to be within 10-15 minutes’ drive to VACHS West Haven Campus, so the MH RRTP Team of providers can assist in overseeing and providing clinical programming to these referred Veterans for improved quality of care. Continuum of Care Inc. has two houses which has housed VACHS two residential programs with VA Site designations for the past five (5)+ years.

The Contracting Officer performed further market research by utilizing keywords residential rehabilitation treatment program, NAICS Code: 623220 and PSC Code Q518, Medical-Psychiatry Services when querying Government Databases using FPDS-NG, DSBS which provided no results. The Contracting Officer reviewed the contract #36C24121C0020, Period of Performance 2/1/2021-1/31/2026, with a rate of $475.00 per day for 18 for RRTP beds and $875.00 per day for 10 PTSD beds with Continuum of Care Inc. for similar services. Hence, this facility was a viable option for the needs to VAMC Connecticut. The Contracting Officer posted a Notice https://www.acquisition.gov/far-overhaul/far-part-deviation-guide/far-overhaul-part-5 https://www.acquisition.gov/far-overhaul/far-part-deviation-guide/far-overhaul-part-5 https://www.acquisition.gov/far-overhaul/far-part-deviation-guide/far-overhaul-part-5

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Acquisition ID#: 36C241-26-AP-0912 of Intent to Sole Source #36C24126Q0117 on Contract Opportunities on 12/2/2025 with no response received. The Notice of Intent to Sole Source set forth unique characteristics required and invited any interested vendor to submit a capability statement for consideration.

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

Fair and Reasonable: Continuum of Care Inc. cost for 18 beds with a firm fixed rate of $475.00 for RRTP and 10 beds $875.00 for PTSD with all-inclusive including nursing and transportation beside room and board for a three (3) month period. The current short-term contract is a firm fixed price of $475.00 and $875.00 per each BDOC for a period of 2/1/2026-4/30/2026. This contract action for the Residential Rehabilitation Treatment Program (RRTP) and Post-Traumatic Stress Disorder (PTSD) beds is designed to ensure continuous service provision without disrupting ongoing care. The proposed contract will mirror the prices of the current contract #36C24121C0020 which expires on 1/31/2026. The Contracting Officer has determined that the anticipated cost of this contract will be considered fair and reasonable.

8. Description of the Market Research Conducted and the Results, or a Statement of the Reasons Market Research Was Not Conducted: Contracting performed market research by utilizing NAICS Code: 623220 and PSC Code Q518, Medical- Psychiatry Services. This market research was conducted in FPDS-NG, DSBS. A notice of intent to Sole Source was posted on Sam.gov on 12/2/2025 for potential sources which yielded no responses. Large Business (LB) Continuum of Care Inc. is the only responsible source that can provide comprehensive community based residential and support services in the area. Considering a current contract #36C24121C0020 in place with this facility for similar services that was awarded in 2021, it has been determined that it is in the best interest of the Government to do a Sole Source award to Continuum of Care Inc. because of its proximity to the medical center and because it offers the services as defined by the requirement. This is a service contract and it is not applicable to BAA in FAR Part 25.

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:

None

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: VA will continue to conduct appropriate market research to identify other firms that can meet this requirement, like the steps outlined in Paragraph 8, in order to attempt pursue competitive acquisitions in the future.

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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.

Name: Sarah Knudsen Date Title: Health System Specialist Facility: VA Connecticut Healthcare System

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

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

Name: Portia Fredua-Agyemang Date Title: Contracting Officer Facility: NCO1

b. One Level Above the Contracting Officer (Required over SAT but not exceeding $900K): I certify the justification meets requirements for other than full and open competition.

Name: Laura A. Taylor Date Title: Branch Chief

Facility: NCO1

c. VHA RPO HCA Review and Approval: I have reviewed the foregoing justification and find it to be complete and accurate to the best of my knowledge and belief and recommend approval (if over $90 million) or approve ($900K to $90 million) for other than full and open competition.

Name: Gerald F. Jacobs Date

Title: Executive Director, Regional Procurement Office East VHA Head of Contracting Activity (HCA) https://dvagov.sharepoint.com/sites/vhapromanual/SitePages/VHAPM-Part-806.3.aspx