Justification and Approval - PTSD Training Published.pdf

JUSTIFICATION AND APPROVAL

FOR OTHER THAN FULL AND OPEN COMPETITION

FAR Subpart 6.302-1 PTSD Evidenced Based Treatment, PTSD Assessment, and Military Culture Training

1. Contracting Activity:

Department of Veterans Affairs Office of Procurement, Acquisition and Logistics (OPAL) Strategic Acquisition Center (SAC) 10300 Spotsylvania Ave, STE 400 Fredericksburg, VA 22408

2. Description of Action:

The proposed action is for a twelve (12) month firm-fixed price (FFP) contract with four (4), twelve (12) months option periods for procurement of PTSD assessment, military culture and evidenced-based PTSD treatments training.

The proposed action is to provide PTSD Training services. It is to conduct trainings for providers that are treating Veterans in their private practice. One of the goals is to improve the lives of our Veterans whether or not they seek treatment in the VA. The contractor shall conduct three separate trainings over the course of the 12-month contract period. Each training will be approximately a 2-day training for approximately 75 non-VA mental health providers, for a total of approximately 225 providers. It is intended to acquire this training by the Henry Jackson Foundation (HJF) beginning in September 2021. The Independent Government Cost Estimate (IGCE) and market research revealed an estimated total value of $994,075.65 with a base period estimate valued at , and four twelve (12) month option periods estimated value at

3. Authority:

The statutory authority permitting other than full and open competition is 41 U.S.C.3304(a)(1) as implemented by the Federal Acquisition Regulation (FAR) Subpart 6.302-1 entitled, “Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.”

4. Rationale Supporting Use of Authority Cited Above:

The proposed requirement is to provide training in Evidenced-Based Treatments for PTSD, PTSD Assessment training and Military Culture training to providers treating Veterans. This is a highly specialized training that requires both competency in Evidenced based training for PTSD as well as military culture and Veteran mental health and recovery. The Henry Jackson Foundation is the only non-VA organization with the Prolonged Exposure (PE) training expertise required that focuses solely on training providers who treat Veterans and service members. Their PE training offers a unique focus on military combat trauma and/or the experience of military sexual trauma. They are recognized as a leader in military culture training.

This is critical because aspects of military culture interfere and complicate reactions to trauma making it more difficult to treat PTSD. They have also trained other DoD providers and using this source would allow for continuity in the quality of the training for Veterans who were seeking care while in the military and to continue this when they are discharged from the military.

5. Efforts to Obtain Competition:

Market research was conducted, details of which are in the market research section of this document. This effort did not yield any additional sources that can meet the Government’s requirements. There is no competition anticipated for this acquisition. Additionally, the proposed action will be synopsized on the Federal Business Opportunities Page in accordance with FAR

5.201. Any proposals that are received shall be evaluated.

6. Actions to Increase Competition:

The long-term solution for PTSD treatment training is to increase the number of psychologists trained in Evidence Based treatments for PTSD. Psychologist are a hard to fill position at the VA and in general filling psychologist and psychiatrists nationwide are difficult. This is a long term issue without a quick solution. In addition, a Request for Information (RFI) was published on April 29, 2021, in order to gauge interest from any other possible sources. Results and details of the RFI are detailed in section 8 of this document. The Government will continue to conduct market research to ascertain if there are changes in the marketplace that would enable future actions to be competed.

7. Market Research:

For historical purposes: An RFI, dated 29 June 2018, was initiated to gauge market availability (under the previous contract vehicle 36C1018P0008) of responsible an capable vendors that could meet the stated requirement of providing medical professional certified training specifically tailored to the manual titled Prolonged Exposure Therapy for PTSD: Emotional Process of Traumatic Experiences - Therapist Guide (Treatments that Work) by Edna Foa, Elizabeth Hembree, and Barbara Rothbaum; consistent with prior trainings deployed throughout the VA, along with service training provider that are capable of traveling to designated rural locations throughout the country as identified in the statement of work. In addition to the RFI the program office conducted their own market research to identify all clinically appropriate trainers available in the marketplace. Although several trainers exist, only two are nationally recognized, and evidence-based. The other trainer, Dr. Foa, offers this training in Philadelphia, Pennsylvania (PA) for which the personnel would all have to travel to PA for the training which would further increase the cost of this training and would also limit the scope of this requirement as many clinicians would not be able to leave their homes for a 5 day training course with an additional 2 days of travel. Further research was conducted via the Federal Supply Schedule to ascertain if it would be possible to procure the required specialized evidence-based training with travel requirement through the contracting vehicles listed under the eLibrary. There was no acceptable schedule found as required for this procurement.

A new RFI, dated April 29, 2021, was published, in order to further gauge market availability.

The new RFI’s main purpose was to seek new sources that could provide technical capability statements addressing the particulars of this effort. The RFI closed on May 13, 2021 with two small business vendors submitting capability statements and showing interest in providing the services as described on the published performance work statement.

The Program Management Office (PMO) reviewed the vendors’ submissions and concluded for Nursing CE Central, their nursing capabilities cannot deliver the training required for expert psychologists that specialize in training psychologists on military culture and evidence-based PTSD therapy. For Apogee Solutions, the vendor shows expertise in the case management aspect of suicide and behavioral health though it doesn’t show they would be able to provide evidence-based treatment training on PTSD to psychologists. They state “The PTSD training of Clinicians who treat Veterans, must focus on Evidence Based Treatments used to assess, manage, and monitor Veteran’s well-being through a variety of resources; to focus training Veterans to identify symptoms, be accountable to another, and to de-escalate stressors and integrate learned risk avoidance protocols related to suicide risk-taking behaviors and increase knowledge of Military Culture for clinicians treating Veterans.” There is no evidence of expertise or experience in training providers in the Evidence-Based Treatments for PTSD listed in the VA/DoD Clinical Practice Guideline for PTSD. Though it might be possible this vendor could be able to manage the details of the trainings they don’t seem to have the capability of experts that could provide the training. In contrast, the Henry Jackson Foundation has expert psychologists that specialize in training psychologists on military culture and evidence-based PTSD therapy and have a staff that can arrange all of the details of the training.

Based on the searches during market research there are no Government identified SDVOSBs or VOSBs that have Evidence-Based Treatments for PTSD including Prolonged Exposure Training, Military Culture and PTSD Assessment trainings for PTSD listed. The select services are not readily available on an existing purchasing vehicle (such as a GWAC, Internal IDIQ, GSA FSS, Ability One, etc.)

The Henry Jackson Foundation, doing business as (dba), The Center for Deployment Psychology is the only organization outside of VA with the necessary training and experience to provide the necessary services outlined in this contract due to the time requirement and the high standards set by the developer of the treatment and lack of knowledge on the unique aspects of delivering this treatment to military Veterans. The Henry Jackson Foundation is able to provide the necessary services with no additional training needed.

8. Other Facts:

Regarding sub-contracting opportunities and possibilities: The Uniformed Services University’s (USU) Center for Deployment Psychology (CDP), is a collaborative program between USU and Henry M Jackson Foundation for the Advancement of Military Medicine. CDP has multiple training programs for educating and training behavioral health providers and improve behavioral health care. CDP Personnel have spent the last 10 years developing, testing, and refining programs and curriculum to disseminate and promote the implementation of evidence-based psychotherapy (EBPs) at multiple levels within the Government. Faculty bring over 150 years of experience to teaching and adult learning through in-person and online trainings. CDP has robust program evaluation and process improvement systems that take feedback from thousands of participants every year and conduct complete course reviews every two years.

Faculty attend annual conferences in their specialty area and many are board certified, nationally recognized and well-published in their area. The dissemination of highest quality adult training, education and consultation is what CDP does full-time. The CDP does not allow non- CDP faculty to present HJF training programs, so a sub-contract with a small business would not be an option for any training programs with HJF’s content. HJF does have an established relationship with Alamo Travel Group, which is a small business out of San Antonio, Texas. Any travel conducted under this contract would be coordinated through that company, but these costs are immaterial.

9. Technical and Requirements Certification:

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

Sonya Norman Date PTSD Consultation Program Manager

10. Determination of Best Value:

I hereby determine the proposed contract action will represent the best value to the Government. No award shall be made until the Contracting Officer determines the cost to the Government to be fair and reasonable. Additionally, this determination will include a comparison of current contract pricing, past proposal submissions and an Independent Government Cost Estimate. The Government’s intention is to award based on achieving pricing similar to what has been previously paid and is in the best interest of the Government.

Mauricio Vazquez Date Chief, Acquisition Services Div 4A Contracting Officer

11. For acquisitions over $700,000 but not exceeding $13.5M

In my role as Agency Competition Advocate, based on the foregoing justification, I hereby approve the acquisition of PTSD Evidenced Based Treatment, PTSD Assessment, and Military Culture Training services pursuant to the authority cited in paragraph 3 above, subject to availability of funds, and provided the services herein described have otherwise been authorized for acquisition.

Efrain J. Fernandez Date Director, Strategic Acquisition Center, Frederick (SAC-F) Competition Advocate SAC VA

6/10/2021

06/10/2021

June 14, 2021