Justification CCSS Bridge final NRP-JB-S_Redacted.pdf

Corporate Consolidated Control Number VA-26-00013597 Support Services 1.0 Extension

JUSTIFICATION

FOR AN EXCEPTION TO FAIR OPPORTUNITY

1. Contracting Activity: Department of Veterans Affairs (VA)

Office of Procurement, Acquisition and Logistics Technology Acquisition Center 23 Christopher Way Eatontown, NJ 07724

2. Description of Action: The proposed sole source action is for a Firm-Fixed-Price (FFP)

Task Order (TO) modification to be issued under Transformation Twenty-One Total Technology Next Generation (T4NG) Contract VA118-16-D-1011 TO 36C10B21N10110004 with CivitasDX LLC, 9920 Pacific Heights Blvd, Suite 150, San Diego, CA 92121-4361. This TO modification will definitize a Letter Contract effective on October 3, 2025, and will provide Corporate Consolidated Support Services (CCSS) for the Corporate (CORP) Portfolio products listed in Section 5 below. This TO modification will serve as a bridge until protest activities are completed on the competitive acquisition that was awarded on September 22, 2025, under TO 36C10B25N10200014 with Sprezzatura-GovernmentCIO Joint Venture LLC (SCIO).

3. Description of the Supplies or Services: The proposed action will provide continued

CCSS technical and sustainment services to support the CORP Portfolio Product Lines and Information Technology (IT) products listed in Section 5. This TO focuses on critical technical support activities such as ensuring essential support services to the Financial Management System (FMS) and resolution of technical issues, system outages, and software malfunctions for the other supported applications listed. This support consists of over 60 contractor staff supporting 19 product teams responsible for the management and operational support of products spanning multiple service lines, providing services corresponding to numerous customer agreements. The work provides a substantial portion of the product team’s composition, including system administrators, database administrators, testers, and configuration managers, who work collaboratively with the CORP Portfolio and Business Managers supporting distinct and dependent product team functions such as cybersecurity, information technology infrastructure, as well as sustainment and break-fix activities. The support for CORP’s extensive portfolio includes repair, configuration, release orchestration for critical releases only and other critical work activities to ensure security, availability, performance and business value measures meet VA’s mission priorities and objectives. CORP requires that the services outlined above, previously being provided under TO 36C10B21N10110004, continue without interruption to prevent a negative impact to multiple projects. This proposed action will provide for continuity of these critical support services. The period of performance for this proposed action shall be four months, from October 3, 2025 through February 2, 2026. The total estimated value of the proposed action is The period of performance will provide support through February 2, 2026, to ensure there will be no lapse in support due to protest activities. CORP requires a minimum of four months to allow for the Government Accountability Office (GAO) protest decision and, if GAO denies or dismisses the protest, the four months will allow CCSS to continue while preparing for support to resume under a contractual award, as intended and adequately planned for in the initial pre-protest timeline.

4. Statutory Authority: The statutory authority permitting an exception to fair opportunity is

Section 41 U.S.C. 4106(c)(1) as implemented by the Federal Acquisition Regulation (FAR) 16.505(b)(2)(i)(A), entitled “The agency need for the supplies or services is so urgent that providing a fair opportunity would result in unacceptable delays.”

5. Rationale Supporting Use of Authority Cited Above: The proposed source for this action is CivitasDX LLC, 9920 Pacific Heights Blvd, Ste 150, San Diego CA, 92121.

CivitasDX LLC was the incumbent contractor on the previous TO, 36C10B21N10110004, which has not expired due to the transition tasks that were underway after award of the competitive acquisition. The follow-on CCSS TO was awarded as a result of a competitive action under T4NG on September 22, 2025, under Service-Disabled Veteran-Owned Small Business (SDVOSB) Set-Aside procedures to SCIO. On September 26, 2025, a GAO protest was filed by CivitasDX LLC on the competitive follow-on TO award, which resulted in a stop-work order issued to SCIO. A decision on the protest from GAO is not expected until January 5, 2026, and as a result, VA was faced with a gap in service. As such, a Letter Contract was issued to CivitasDX LLC on October 2, 2025, and effective October 3, 2025, to avoid any gap in support for the critical systems for the reasons detailed below.

CORP Portfolio requires that CCSS continue without interruption to prevent a negative impact to multiple key systems while the protest is being resolved. This bridge will enable continuity of product teams supporting critical areas to include the following:

a) Financial Management System (FMS): FMS is a VA mission-critical application that serves as the accounting system of record for VA. It manages funds control, budget execution, standard general ledger and cost accounting while ensuring compliance with congressional mandates and oversight agency directives. FMS is a VA-customized system that automates and integrates VA accounting systems. It is VA’s primary financial data repository. Although it originated as a customized version of Federal Financial System, an accounting application created by American Management Systems, FMS is now a highly evolved system. It is a legacy mainframe application which processes transactions from VA stations, payroll and other financial activities. It features one-time transaction processing that simultaneously posts these transactions to the general ledger and to all subsidiary ledgers and tables. FMS facilitates disbursements to the US Treasury. It integrates data from 80+ interfaces managing daily financial operations. Data is batch processed into FMS from interfacing systems. Additionally, it plays a key role in identifying payroll discrepancies, generating 1099 tax forms, and transmitting tax information to the Internal Revenue Service (IRS). An interruption of the tasks executed by the FMS team supporting this VA mission critical application would immediately result in the following:

• Delay in Congressionally Mandated FMS Annual Close: This will affect FMS availability, severely impacting Veteran payments and financial reporting to the Treasury

• Financial data errors: Timely corrections of data errors will be hindered, delaying financial reporting to the Treasury, Office of Management and Budget (OMB), and Congress

• Veteran payments: Regular payments post-Annual Close will be delayed that will have severe impact on Veterans’ health and services

• 1099 preparations: Delays in 1099 preparations will push back the January mailing date, missing the IRS deadline

• Security risks: Failure to remediate risks in FMS, Financial Reporting Data Warehouse, Management Information Exchange, Financial Reporting System, and Financial Content Management will pose significant security threats to the VA financial systems. If any of the first four points occur, especially during Annual Close, it will directly affect Veterans and require Congressional notification from VA leadership

b) Space and Equipment Planning System Military Standard (SEPS/MIL/STND):

SEPS/MIL/STND is a data-driven planning tool critical to the Strategic Capital Investment Process (SCIP) for the VA. It ensures that SCIP investment decisions comply with VA facility construction and acquisition regulations, primarily found in Title 38 of the U.S.C., Parts 17 and 59, which govern VA healthcare facility operations and grants for state veterans’ homes - services that SCIP projects must support. SEPS also ensures compliance with Title 48 of the U.S., Parts 836 and 852, which cover construction and architect-engineer contracts that must be followed when developing new VA hospitals and clinics.

Ultimately, SEPS incorporates VA design guides, DoD standards, and federal healthcare regulations. An interruption of the tasks supported by the SEPS application would shut down the critical SCIP for VA. In turn, VA would fall out of compliance with Title 38 of the U.S. Code, Parts 17 and 59, which govern VA healthcare facility operations and grants for state veterans homes - services that SCIP projects must support. Additionally, SEPS ensures compliance with Title 48 of the U.S. Code, Parts 836 and 852, which cover construction and architect-engineer contracts that must be followed when developing new VA hospitals and clinics.

c) Veterans Canteen Service (VCS) Automated Information System (AIS): VCS AIS provides merchandise and services to specified classes of people, such as veterans of the Armed Forces who are hospitalized or domiciled in hospitals and homes of the VA, at reasonable prices. VCS directly supports the needs of 9.8 million Veterans, 14.7 million family members, caregivers, VA employees, volunteers, and visitors ensuring access to essential goods and services offered at VA hospitals and centers nationwide. VCS AIS consists of Oracle Financial and Retail, Employee Payroll Deduction, Oracle Analytics for Reporting, Mainframe Batch used for script scheduling, and Electronic Data Interchange used to communicate with vendors for retail operations. Several ancillary systems are used by interfaces to move data between systems both internal to AIS and external. An interruption of the tasks executed by VCS AIS would result in not receiving the essential technical labor support necessary for fulfilling its legislative mandate as established under Title 38 Chapter 7801 of the U.S.C. in 1946, which states that VCS aims to offer Veterans merchandise and services essential to their comfort and well-being. If support is not provided, operations within Canteens all over the country will be halted; corrupted financial information would prevent compliance with the Prompt Pay Act, leading to delays in receiving and paying for merchandise as required by law, and Veterans use of Veterans Canteen Services will be stifled.

d) VCS Point of Sale (POS): VCS POS provides merchandise and services to specified classes of persons, such as veterans of the Armed Forces who are hospitalized or domiciled in hospitals and homes of the VA, at reasonable prices.

VCS directly supports the needs of 9.8 million Veterans, 14.7 million family members, caregivers, VA employees, volunteers, and visitors ensuring access to essential goods and services offered at VA hospitals and centers nationwide. VCS POS system functions as a non-customer facing, point-of-service (payment) application. VCS employees process sales and/or retail transactions with POS commercial-off-the-shelf software applications that reside on the cash register which allows VCS to provide merchandise and services to our Veterans, and their families at local VA hospitals. An interruption of the tasks executed by VCS POS resulted in operations within Canteens all over the country being halted, disabling Veterans use of Veterans Canteen Services.

e) Corporate and Regional Matrixed Budget System (CRMBS): CRMBS provides a flexible and configurable platform to support VA's Construction and Facilities Management (CFM) budget and spend plans business practices. This product improves financial business processes such as spend controls, approval workflows, and financial analytics. CFM provides a single source for Major Construction, segregation of duties and approval documentation critical for CFM financial audits and implements financial policies on approval thresholds. CFM provides the capability for decentralized acquisition with centralized oversight and control and segregates multiple appropriations to assure funds are used in accordance with the governing General Ledger. Accurate financial management allows CFM to ensure proper oversight of the projects executed to support the provision of facilities for health and burial use as required by OMB Circular A-123, Management's Responsibility for Internal Control, the Federal Financial Management Act of 1996, the Chief Financial Officers Act of 1990 and in support of Generally Accepted Accounting Principles and the Federal Accounting Standards Advisory Board. An interruption of the tasks executed by CRMBS would result in CFM not being able to provide real-time, synchronized, coordinated budget execution, data reporting and audit capabilities. CRMBS is how 717 contractors are paid. If it doesn’t work, VA is liable for late payment charges on existing contracts, and all funding efforts will not have a request and management system.

f) Technical Information Library Management System (TIL- MS): TIL- MS is a critical resource for managing VA technical design, construction, and facility standards.

TIL-MS incorporates national and federal building codes including: National Fire

Protection Association101 (Life Safety Code) - Fire protection and emergency egress. American Society of Heating, Refrigerating and Air-Conditioning Engineers

- heating, ventilation, and air conditioning and energy efficiency in VA medical facilities, Americans with Disabilities Act Standards for Accessible Design - Ensuring compliance with 38 Code of Federal Regulations (CFR) and VA patient accessibility requirements, and United States Pharmacopeia (USP) 797 & USP 800 - Pharmacy and hazardous drug handling facility design. TIL-MS use and governance also fall under several VA and federal regulations related to construction. TIL-MS stores and distributes VA technical design guides, technical specifications, and technical manuals that are required by VA Acquisition Regulations (VAAR) (48 CFR Part 836) and Federal Acquisition Regulations (FAR) Parts 1-53. Architects, engineers and contractors working on VA projects must follow TIL-MS technical standards referenced in VA contracts governed by 48 CFR part 852. For example, a contractor bidding on a VA hospital renovation must review TIL-MS plumbing, electrical, and safety guidelines to ensure that their proposal meets CFR and VAAR requirements. Failure to comply with TIL-MS can result in contract penalties, delays, or project rejection. An interruption of the tasks executed by TIL-MS would result in VA not being able to meet requirements to execute Licensing and Permits which consists of all activities associated with obtaining the appropriate construction and occupancy permits and managing the associated inspections and approvals in accordance with all applicable Federal, State and municipal requirements.

g) Construction and Facilities Management Support System (CFMSS): CFMSS provides the tools and functionality that facilitates the VA CFM staff the ability to manage all major construction projects . The system is comprised of 4 major functionalities. The first functionality is, the construction project management functionality. This provides CFM with the ability to plan, manage, schedule, track, capture milestones and report on all construction and preservation efforts. The second major functionality is financial management. This provides CFM the insight into budgeting, tracking, transactional data, and reporting of all CFM related funds. The financial components pull data, at intervals, from FMS to provide the most up to date information. The third functionality of CFMSS supports CFM, the Office of Real Property and the Office of Acquisition, Logistics, and Construction and is the historical document search and storage. Examples of the documents stored are leases, deeds, memos, plans and other legal documents related to these efforts. The fourth major functionality is the robust reporting functions. The reports generated support several ancillary activities such as budget planning, new facilities planning, and even Congressional reporting requirements.

This system supports: Executive Order 13327 Federal Real Property Asset Management and VA Directive 7815 Acquisition of Real Property by Lease and by Assignment from General Services Administration (GSA). An interruption of the tasks executed by CFMSS would result in the Office of CFM not being able to plan, manage, fund, and track major construction efforts at the VA. Lack of IT services would cause delays in CFM's ability to provide critical facilities such as medical centers, community-based clinics, regional offices, and national cemeteries, that all serve our Nation’s Veterans.

h) Space Management Support System (SMSS): SMSS is used by the VA Office of

Administration (OA) to assign workspaces and conference rooms to VA Corporate Office (VACO) tenants. SMSS provides a graphical representation of VACO buildings with offices, cubicles, and meeting rooms on each floor. The offices, cubicles, and meeting rooms are available for reservation for use by VA personnel.

Reservations can be hourly, daily, or monthly, dependent on the needs of the personnel. This system supports: Executive Order 13327 Federal Real Property Asset Management. An interruption of the tasks executed by SMSS would cause the system to fall out of compliance with VA security standards, possibly compromising the VA network and impacting the availability of reserving conference rooms at the OA at VACO. This could impact decision makers that can affect Veterans, families, and caregivers.

i) Forms and Publications Orders (FP Orders) and Integrated Supply Management

System (ISMS): FP Orders and ISMS maintains approximately 1,500 line items such as forms, publications and flag sets that are utilized by all VA locations.

These items may be ordered using FP Orders through the Austin Automation Center. FP Orders users can access a complete listing of stocked hard copies of forms and publications, as well as flag sets. Flag set orders are used to replenish stock at the VA facilities by request. The Office of Procurement, Acquisition and Logistics team maintains inventory control, replenishment analysis, receiving, packing and shipping of all VA forms, publications and flag sets, creates and updates the digital catalog and performs initial distributions as required for new forms/publications specified by the department responsible for the original item. FP Orders support VA initiatives under 38 U.S.C. § 1720F (Veterans' Mental Health and Suicide Prevention Programs), which mandates suicide prevention efforts, crisis support services, and mental health outreach, ensuring veterans have access to critical resources through standardized forms and publications. Similarly, 38 U.S.C. Chapter 23 (Burial Benefits) governs VA-provided burial and memorial benefits, requiring the timely processing of flag sets for cemetery services. The system also aligns with Occupational Safety and Health Administration regulations (29 CFR § 1910) by improving access to emergency and workplace safety procedures and the Health Insurance Portability and Accountability Act (HIPAA) (45 CFR § 164.520) mandates the posting of HIPAA Privacy Notices to inform veterans of their medical privacy rights. Ensuring these forms and publications are easily accessible enhances the VA's ability to provide timely suicide prevention resources, burial benefits, patient rights information, and critical regulatory notices while complying with VA Directive 6300 (Records and Information Management) and VA Directive 6500 (Cybersecurity Program) for IT security, cloud modernization, and efficient information governance. ISMS is a digital catalog of non-expendable inventory equipment. VA locations across the enterprise utilize ISMS to identify category stock numbers that are associated with items in those VA locations inventory. FP Orders and ISMS have an integrated code base. An interruption of the tasks executed by FP Orders and ISMS would result in extended periods of downtime resulting in unplanned problems and/or incidents. If this system becomes inoperable, paper-based forms needed by Veterans and beneficiaries to request benefits may not be available. In addition, Veteran burial flag sets may not be requisitioned and distributed to where they are required. VA inventory managers across the enterprise will lose access to the standardized catalog used to identify Category Stock Numbers (CSNs) for over 1,500 non-expendable equipment items. This disruption would result in inconsistent item identification, increased manual errors, and degraded interoperability across VA supply chain systems, undermining the ability to conduct accurate asset lifecycle management. Without ISMS, VA facilities would be unable to comply with established logistics policies, including VHA Directive 1761 and VA Directive 7002, which require the standardized tracking and reporting of non-expendable equipment.

j) Centralized Administrative Accounting Transaction System (CAATS): CAATS is an electronic input and approval system for accounting source documents and transactions. It enhances internal controls, standardizes accounting entries, provides electronic audit trails, and ensures separation of duties. CAATS is the central interface to the FMS for both the Veteran’s Benefits Administration and the National Cemetery Administration. An interruption of the tasks executed by CAATS would result in the following: Financial Data Errors which would negatively impact timely correction of data errors, delaying financial reporting to the Treasury, OMB, and Congress. Veteran Payments would be delayed. These delays would severely impact Veterans' health, services, and benefits. Vendor Payments would be delayed, which would affect Veteran support programs such as Paralympics and education.

k) Capital Asset Management-Business Intelligence (CAMS-BI): CAMS-BI supports

Capital Investment Planning, mandated by the Mission Act. It is the primary system of record for VA Enterprise, assessing VA healthcare markets, capacity, performance, condition of facilities, and future improvement opportunities. CAMS- BI is crucial for various reporting requirements to OMB, Office of the Inspector General (OIG), and GSA, Congress, VA senior management, and other stakeholders. An interruption of the tasks executed by CAMS-BI would have the following impacts: 1) Non-compliance with active FRPP reporting due to Congress by December 2025 which is a violation of federal laws and reporting requirements from Congress, OMB, OIG, and GSA; 2) Failure to provide a compliant, secure, and well-functioning System of Record, vital to VA’s mission: 3) Inaccuracy in capital budget requests, resulting in lost construction funding and decreased access to care for Veterans.

l) PayVA: PayVA is the application that verifies debt payments for Veterans and their families before they are sent to pay.gov. Authorized debt payment activities will continue during the lapse in appropriations. An interruption of the tasks supported by the PayVA application would result in Veterans VA debt payments not being successfully verified prior to being submitted to pay.gov.

m) Child Care Records Management System (CCRMS): CCRMS is a pivotal web-based platform that allows VA employees to apply for Child Care Subsidy Program benefits online. CCRMS facilitates the submission of applications by enabling users to upload supporting documentation and capture detailed information about Child Care Providers. It verifies all required application information electronically, reviews and verifies submitted applications, and determines the eligibility of applicants for approval or denial. Additionally, CCRMS manages user accounts, supports the termination of participation as needed, and provides status updates via email. The system also plays a crucial role in the payment process by accepting and storing monthly payment requests, tracking subsidy amounts, recertifying eligibility annually, monitoring Provider License expiration dates, and generating necessary reports. This system greatly enhances the efficiency of providing childcare benefits to the VA employees, ensuring timely access and proper management of subsidy payments. An interruption of the tasks supported by CCRMS would result in VA having to revert to a manual paper-based system, requiring the maintenance of a large-scale filing system for over 12,000 nationwide VA staff who use this service. This would significantly increase the administrative burden and result in substantial delays in processing and delivering childcare benefits to eligible VA employees. These delays could lead to decreased performance and morale among VA staff who rely on these benefits for their daily childcare needs. Without full funding, the sustainment and break-fix support would be compromised, making it challenging to address changing business needs, such as implementing the Integrated Financial and Acquisition Management System commonly referred to as iFAMS or adjusting benefit amounts based on income eligibility. Furthermore, maintaining compliance with legislative mandates, such as the United States Office of Personnel Management Child Care Subsidy Legislation (Public Law 107-67, Title 5, CFR, Part 792), and VA Child Care Subsidy Program Policy, would be at risk. CCRMS also supports the Return-to-Work initiatives outlined in the Presidential Executive Orders. A new contract plan, including sustainment services, aims to increase the efficiency of CCRMS in processing online applications and managing subsidy benefit payments nationwide. Without this investment, the effectiveness and reliability of the childcare subsidy program would be significantly undermined, affecting the overall quality of life and work-life balance for VA employees.

n) Human Capital Management (HCM)-Data Warehouse (DW): HCM-DW is the VA's key data warehouse, designed to enhance HCM operations. It oversees the entire data lifecycle, starting with the ingestion of raw human capital data from trusted sources, such as IBM, which undergoes rigorous cleansing and transformation to ensure integrity and compliance. Utilizing advanced Power BI reporting and analytics, HCM-DW provides leadership with essential insights into workforce trends, payroll, staffing, and performance. Its role is vital in connecting various Human Resources (HR) systems, reducing data performance risks from transactional systems like HR Smart, and ensuring access to curated, cleansed data for analytics, governance, and audit readiness. An interruption of the tasks supported by the HCM-DW team would result in a disruption of services which would negatively impact the VA's ability to manage and analyze critical human capital data effectively. Without proper data ingestion, cleansing, transformation, and reporting processes, VA leadership would lack essential insights into workforce trends and payroll integrity. This breakdown would create unnecessary pressure on transactional systems, such as HR Smart, forcing users to generate reports directly from production environments. Such practices jeopardize not only availability but also the performance of essential services for HR staff, risking the overall efficiency of our operations. Moreover, the loss of HCM-DW capabilities would jeopardize the precision and timeliness of dashboards that are crucial for governance decisions, budget allocations, and strategic hiring initiatives. Such setbacks could lead to delays in recruiting key personnel, ultimately having a detrimental impact on the experience of Veterans. Inaccurate HR data also heightens audit risks and compliance challenges. HCM-DW is indispensable in providing leadership with a reliable foundation of human capital intelligence, enabling informed and critical decision-making for the benefit of all.

o) Human Resource-Payroll Application Services (HR-PAS): HR-PAS functions as a centralized repository and middleware platform for integrating HR and Payroll data.

As middleware, HR-PAS facilitates the secure exchange of data between VA financial and HR systems, ensuring the seamless integration of critical data elements. It manages both inbound and outbound data flows with internal VA systems and select external entities, streamlining data management processes and supporting accurate, timely payroll and workforce operations. An interruption of the tasks supported by HR-PAS would result in the risk of delayed or inaccurate payroll processing for VA employees presenting a significant threat to workforce morale, ultimately eroding trust in the institution. When there are interruptions in data flows among the VA's financial, HR, and external systems, it can lead to incomplete or inconsistent records, jeopardizing the integrity of operations. Failure to comply with federal requirements for financial and HR data integrity, as mandated by OMB, Government Accounting Office, and OIG audits, could lead to serious compliance issues for the VA. Systems relying on HR-PAS may encounter significant data quality issues, resulting in operational bottlenecks and delays that impact various VA programs and initiatives. The financial burden associated with emergency remediation, the need for manual workarounds, and the reliance on contractor surge support significantly outweigh the ongoing costs of adequately funding HR-PAS operations. Most importantly, disruptions to payroll and HR services for VA employees can compromise workforce stability and efficiency, ultimately leading to delays or impairing the delivery of essential benefits and healthcare services to Veterans.

p) VA Transportation Benefit Program (TBP): VA TBP is a comprehensive, web-based system modeled after the Department of Defense (DoD) Form 2845, serving as an electronic replacement for VA Form 0722. This system enables the Department of Veterans Affairs (DVA) employees to apply for federally subsidized transportation benefits online, allowing them to modify their enrollment information or withdraw from the program as needed. It supports an efficient verification and approval process for applicant information, providing the VA TBP Program Office with the capability to monitor application statuses and generate essential reports.

For the submission and tracking of applications, including new applications, changes, annual recertifications, and withdrawals, the system ensures seamless management. In addition, it includes functionalities for account set-up and maintenance, such as preparing and submitting applications for new accounts, processing changes to existing accounts, setting up approving officials, and establishing threshold limits. The VA TBP system also manages the procurement and distribution of transit subsidy media, offers support and guidance for transit subsidy use, and maintains policies, procedures, and training related to transit subsidy usage. An interruption of the tasks supported by VA TBP System would result in significant and far-reaching repercussions. Without the electronic benefits facilitated by the VA TBP Application Portal, over 5,000 employees in the National Capital Region (NCR) would be unable to access Public Transit Fund Benefits, which are managed and tracked for transit benefit allocations. This loss of benefit would degrade the overall quality of life for VA employees and negatively impact employee retention rates. Additionally, the VA would lose the ability to continue digitizing its paper-based business processes, making it impossible to automate the benefits determination process; thus, it would revert to a time-consuming and error-prone manual filing system for thousands of recipients. Electronic processing of payments would be replaced by manual methods, potentially causing delays in fund disbursement and creating financial hardships for employees who depend on these funds for their transportation needs. These delays could hinder employees' ability to perform their duties effectively, subsequently affecting the quality of healthcare and benefits delivered to veterans. Furthermore, maintaining compliance with legislative mandates such as Executive Order 13150, Federal Workforce Transportation, Title 26 of the U.S.C., Section 132(f), which governs the qualified transportation fringe benefits, and the Federal Clean Air Incentive Act Public Law 103-172, would be at risk. The VA TBP System also supports the Return-to-Work initiatives outlined in the Presidential Executive Orders.

q) Workers' Compensation-Occupational Safety and Health/Management Information

System (WC-OSH/MIS): WC-OSH/MIS maintains a database of workers' claim information filed with the Department of Labor (DOL). Included in the database are case master information, medical bill payments to care providers, and compensation payments for eligible staff. Various agencies use WC-OSH/MIS to monitor case status, review and reconcile payments for medical bills, and verify authorization for compensation payments. Information in the system, combined with DOL WC data, is used to identify frequently occurring injuries and illnesses, and to develop methods and programs to prevent them. An interruption of the tasks supported by WC-OSH/MIS would result in halting the system's upkeep and ceasing operational maintenance. This means the VA will no longer have access to the database containing important claim information for VA employees, which is currently shared with the integrated Federal Employee Compensation System managed by DOL. Without services administering operational maintenance and sustainment, the VA will be forced to handle the program manually, potentially impacting the well-being of employees. WC-OSH/MIS is crucial for managing workers' compensation claims filed with DOL. It maintains comprehensive records of case master information, medical bill payments, and compensation payments.

Agencies widely use WC-OSH/MIS to monitor case status, scrutinize medical bill payments, and validate authorization for compensation payments. The system's data plays a vital role in identifying common injuries and illnesses, enabling the development of effective preventive methods and programs.

r) Discrimination Complaint Legal Automation Workload System (DCLAWS):

DCLAWS is the system that supports the activities of the VA's Office of Employment Discrimination Complaint Adjudication (OEDCA), which was statutorily established in 1998 by Section 102(a)(1) of the Veterans' Benefits Act of 1997, P.L. 105-114, (38 U.S.C. § 319), and required reporting. Cases are generated from matters brought to OEDCA for consideration, review, and decision.

The system is hosted in the Capital Region Readiness Center (CRRC), VACO Operations environment. The system includes custom developed applications and databases that allow OEDCA to perform legal workload management and administration of activities associated with it and for the purpose of record management for cases to be adjudicated. DCLAWS is a system inherited from the General Counsel Legal Automated Workload System (GCLAWS), with customizations to support OEDCA. An interruption of the tasks supported by DCLAWS will OEDCA not being able to support ongoing litigation or administrative hearings with court-ordered or statutory deadlines, time-sensitive Equal Employment Opportunity complaint processing that, if delayed, could violate statutory or regulatory timelines (e.g., 29 C.F.R. Part 1614), support to exempted personnel (e.g., legal guidance to leadership on EEO matters during the shutdown), and compliance with settlement agreements or consent decrees that require timely action. If there is lapse in services for DCLAWS, the OEDCA will not be able to provide timely final agency decisions or track pertinent data. Resources will not be able to be sufficiently managed to deliver timely decisions as required by federal regulations. Delays in issuing timely decisions have a negative impact on agency employees, management officials, and the agency as a whole. Additionally, the agency may face sanctions, including default judgment, from the Equal Employment Opportunity Commission if decisions are untimely.

s) GCLAWS: VA GCLAWS is the system that supports the activities of the VA's legal practice organization with case management tracking, correspondence control, and statistical analysis. Cases are generated from matters brought to Office of General Counsel (OGC) for consideration, review, response, analysis, and/or comment.

This system of records contains case tracking for time and personnel, as well as case facts and pertinent documents uploaded with case comment activity. The case may include data privileged under the attorney-client relationship. The entire repository is used to provide statistical and other information in response to legitimate and reasonable requests. The system is hosted in the CRRC, VACO Operations environment. The system includes a set of custom-developed applications and databases that integrate with each other that allows the VA OGC to perform legal workload management and administration of activities associated with it. The system is composed of five components including GCLAWS (OGC Legal Automation Workload System), Accreditation (tracking of VA Accreditation as a Veteran Service Organization or Veteran Attorney, Claim Agent or Representative) and Regulations (tracking of VA Regulations). An interruption of the tasks supported by GCLAWS will result in OGC’s inability to support constitutional functions (e.g., protecting life and property), meet litigation deadlines (especially court-ordered or statutory), oversight and compliance (e.g., with ongoing investigations or enforcement), support to exempt personnel (e.g., leadership, emergency operations, or national security), contractual obligations (e.g., legal review of contracts that must continue), and congressional or legal mandates (e.g., subpoenas, FOIA litigation, etc.) during the lapse in appropriations.

If there is lapse in services for GCLAWS, OGC will not be able to provide timely, accurate, and consistent legal advice and representation to the Department.

Resources will not be effectively managed to deliver legal services and comply with applicable Federal Records laws and policies. Delays in accreditation and issues with representatives' data in VA databases and on VA's website will impact Veterans and their benefits claims.

Based on market research which can be found in Section 8 of this document, it was determined that Civitas remains the only responsible source capable of satisfying the CORP Portfolio’s CCSS requirements in the required timeframe. Since performance by SCIO is under an automatic stay of performance due to the bid protest, no other source can provide the aforementioned support or continuity of services required as a result of the delays caused by the protest action. This bridge will provide for the timely continuance of this critically needed support to ensure there is no gap in service, where this continuance is crucial to ensure continued daily operations of technical and sustainment support services to the products listed above. The support for Corporate’s extensive portfolio includes ensuring essential support services to FMS and resolution of technical issues, system outages, and software malfunctions for the aforementioned supported applications listed. This includes critical releases and other critical work activities to ensure security, availability, performance and business value measures meet VA’s mission priorities and objectives, while the resolution of the aforementioned protest is pending.

Interruption of any of the above-mentioned critical operational activities and essential service tasks would immediately prevent VA from having the technical support necessary to remain operational. Any source, other than CivitasDX LLC, would require an estimated ramp-up period of approximately 8 weeks to onboard and/or transition of appropriate staff, obtain necessary permissions and access to VA systems, recruit individuals with the appropriate skill sets and properly transition all required tasks and workloads. This 8-week ramp-up period is based on past experience on this effort and similar CCSS contracts. Any lapse in CCSS would prevent VA from receiving the necessary resources required to provide the critical services to the projects listed. The harm that would be incurred if the critical services are not obtained include, but are not limited to, all the business impacts identified above in this section for each system listed.

As such, CivitasDX LLC has the abilities, expertise, and zero-day transition to accomplish the required work in the required timeframe.

6. Efforts to Obtain Competition: Market research was conducted, details of which are in Section 8 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. In accordance with FAR 5.301 and 16.505(b)(2)(ii)(D), the award notice for this action will be synopsized on the Contracting Opportunities website, SAM.gov, and the justification will be made publicly available within 14 days of award.

7. Actions to Increase Competition: The requirements under this effort were initially competed under a competitive acquisition and VA is currently awaiting the decision of the GAO protest. It is anticipated that future acquisitions for these requirements will be competed.

8. Market Research: This requirement is leveraging market research conducted in

November 2024 as part of the competitive procurement which includes support for the same services. As a result of market research, on June 12, 2025, Request for Task Execution Plan (RTEP) T4NG-0748 was issued competitively under SDVOSB Set-Aside procedures amongst T4NG prime contract holders. On June 30, 2025, the RTEP closed, and eleven Task Execution Plans (TEPS) were received. Seven companies were found to be capable of performing the technical requirements. Therefore, in October 2025, the Government reviewed the TEPs for market research on this action.

While those sources were found to be capable of providing the essential support services for the CORP Portfolio, no sources other than Civitas, were found to provide the required services in the timeframe required as outlined in Section 5 of the Justification. Only Civitas would be capable of providing the aforementioned support during this protest period due to their ability to provide properly badged and equipped personnel with the critical knowledge to meet the CORP Portfolio’s critical operational and mission needs without adversely affecting services to programs and projects that support Veterans. This bridge will provide for the timely continuance of this critically needed support in order to ensure there is no gap in service.

9. Other Facts: None.

10. Technical and Requirements Certification: I certify that the supporting data under my cognizance, which are included in this justification, are accurate and complete to the best of my knowledge and belief.

11. Fair and Reasonable Cost Determination: I hereby determine that the anticipated price to the Government for this TO modification action will be fair and reasonable based on a comparison with the Independent Government Cost Estimate and price analysis.

12. Procuring Contracting Officer Certification: I certify that this justification is accurate and complete to the best of my knowledge and belief.

Office of General Counsel (OGC) Review

I have reviewed this document and find it legally sufficient, based on the representations set forth in the documents and, if any, attachments. The Competition Advocate’s approval is an independently supported decision not wholly reliant on the legal sufficiency determination.

Approval

In my role as procuring activity Advocate for Competition, based on the foregoing justification, I hereby approve the acquisition of an extension to continue the Consolidated Corporate Support Services, on an other than fair opportunity basis pursuant to the authority cited in Section 4 above, subject to availability of funds, or an approvedAnti-Deficiency Act exemption due to the lapse in appropriations, and provided that the services herein described have otherwise been authorized for acquisition.