Justification for Other Than Full and Open Competition_FA800326P0008_Redacted.pdf

CUI

JUSTIFICATION AND APPROVAL (J&A) FOR OTHER THAN FULL AND OPEN

COMPETITION

PROJECT/REQUIREMENT: Accelerated CAPTE-Accredited Physical Therapist Assistant (PTA) Associate Degree Training Program for Air Force Enlisted Personnel (AFSC 4J0X2)

ESTIMATED CONTRACT VALUE:

AUTHORITY: 10 U.S.C. 3204(a)(1), as implemented by FAR 6.103-2

1. CONTRACTING ACTIVITY

Agency: Department of the Air Force (DAF)

Contracting Activity: 771 Enterprise Sourcing Squadron (ESS)/EGA, Wright-Patterson AFB OH

Requiring Activity: Air Force Medical Readiness Agency (AFMRA) and the 59th Training Group

Document Identification: Justification for Other Than Full and Open Competition (J&A)

2. NATURE AND/OR DESCRIPTION OF ACTION BEING APPROVED

This justification authorizes and approves a sole-source, firm-fixed-price contract to Alamo Community College District (St. Philip's College), situated in San Antonio, TX, within a 10-mile radius of Joint Base San Antonio (JBSA) Fort Sam Houston. This action is taken under the authority of 10 U.S.C. 3204(a)(2), as implemented by FAR 6.103-2, Unusual and compelling urgency.

3. DESCRIPTION OF SUPPLIES OR SERVICES REQUIRED TO MEET THE AGENCY’S

NEEDS

Scope: The requiring activity requires an accelerated, structured hybrid, accredited educational partnership with a local college in San Antonio, TX, to provide the Phase II training block of the Physical Medicine Advance Course. This program must culminate in a Physical Therapist Assistant (PTA) Associate Degree for 12 Air Force enlisted members in the 4J0X2 career field.

As part of the training it is required that they also register the students for the licensure test to be taken after.

Technical Requirements:

a) Accreditation: The academic institution must hold programmatic accreditation through the Commission on Accreditation in Physical Therapy Education (CAPTE).

b) Cohort Structure: The program must support twelve (12) students completing classroom, laboratory, and clinical coursework within 174 training days.

c) Credit Transfer & CCAF Acceptance: The institution must accept and transfer prior credits from the 4J0X2 Phase I initial training (comprising the 15-day preparatory course and 81-day apprentice course conducted at the Medical Education Training Campus (METC) at JBSA Fort Sam Houston) and fully accept Community College of the Air Force (CCAF) credits.

d) Licensure Support: The contractor must prepare, schedule, and cover the cost for all graduates to sit for the National Physical Therapy Examination (NPTE) for PTA licensure.

e) Location Constraints: To avoid extensive student travel costs, preserve local clinical rotation agreements, and ensure tight integration with JBSA Fort Sam Houston, classroom and lab facilities must be located within a strict 10-mile radius of Fort Sam Houston. Clinical experiences must be within the greater San Antonio, TX metropolitan area.

Timeline: The training must occur on a continuous 5-day-per-week schedule to ensure active duty cohorts remain unified and complete the program in the designated accelerated 174-day window.

4. STATUTORY AUTHORITY PERMITTING OTHER THAN FULL AND OPEN

COMPETITION

The statutory authority permitting other than full and open competition is 10 U.S.C. 3204(a)(2), as implemented by FAR 6.103-2, Unusual and compelling urgency.

5. DEMONSTRATION THAT THE PROPOSED CONTRACTOR’S UNIQUE

QUALIFICATIONS OR NATURE OF THE ACQUISITION REQUIRES USE OF THE

AUTHORITY CITED

Use of the authority cited is necessitated by the following academic, geographic, and statutory mandate-driven requirements:

a) Statutory Licensure Mandate (NDAA Compliance): The 2017 and 2019 National Defense Authorization Acts (NDAA) explicitly mandate that military medical personnel acquire professional state licenses and certifications. To qualify for the state licensing exam (NPTE), graduates must hold an associate degree from a CAPTE-accredited institution.

Obtaining independent CAPTE programmatic accreditation for a new military-only schoolhouse is an exceptionally lengthy, complex, and cost-prohibitive process. The current technical school is not accredited and therefore ultimately impacts mission readiness across the USAF. Partnering with an established, accredited institution is the only viable method to comply with the NDAA.

b) Geographic and Operational Constraints: Per the Statement of Need, students must complete classroom and lab training on a physical campus within a 10-mile radius of Fort Sam Houston, with all clinical rotations kept within the San Antonio area. This operational constraint is mandatory to:

i. Eliminate costly student Travel/Temporary Duty (TDY) and Permanent Change of Station (PCS) expenses for the 36 students trained annually.

ii. Ensure seamless coordination and proximity to the Phase I training facilities at METC and the 59th Training Group command element.

iii. Retain students within close proximity to military support structures and local military treatment facilities (MTFs).

Sole Source Rationale: Market research indicates that Alamo Community College District (St.

Philip's College) is the only CAPTE-accredited, degree-granting academic institution situated within the required 10-mile radius of JBSA Fort Sam Houston. Because no other accredited institution is located within this mandatory geographic limit, meet this time frame, and because the Air Force cannot utilize non-CAPTE-accredited programs under NDAA licensing rules, the proposed contractor is the only source capable of satisfying the technical, administrative, and geographical requirements of this program without causing unacceptable operational delays and excessive, duplicative transition costs.

6. DESCRIPTION OF EFFORTS TO OBTAIN COMPETITION

Synopsizing: In accordance with FAR 5.101(b)(2), a public synopsis/notice is not required for this acquisition because we are using other than full and open competition while using unusual and compelling urgency procedures.

Direct Inquiries: A formal search and query on the government-wide point of entry (SAM.gov) revealed that while multiple commercial and academic vendors possess the capability to perform physical therapy assistant and clinical training, the proposed contractor is the only source that can perform this training within the critically compressed readiness timeline required by the Air Force and operate within the mandatory geographic boundary (10-mile radius of JBSA Fort Sam Houston) designated to accommodate the training students.

7. DETERMINATION BY THE CONTRACTING OFFICER THAT THE ANTICIPATED

COST TO THE GOVERNMENT WILL BE FAIR AND REASONABLE

The Contracting Officer will ensure that the final contract price is fair and reasonable. Price analysis will be conducted by:

Comparing the proposed tuition, fees, exam administration costs, and materials pricing against the contractor’s standard, publicly available commercial course catalogs.

Assessing publicly available price lists through other colleges with comparable course work.

8. DESCRIPTION OF THE MARKET RESEARCH CONDUCTED

Methods: Requirements personnel reviewed the database of CAPTE-accredited programs in the state of Texas, analyzed local San Antonio colleges, and conducted comprehensive searches on the System for Award Management (SAM.gov) to identify potential federal training contractors.

Results: A search on SAM.gov revealed that while multiple commercial and academic vendors possess the capability to perform physical therapy assistant and clinical training, none can satisfy the Air Force's operational requirements. Specifically, the proposed contractor is the only source that can perform this training within the critically short preparation timeframe required to maintain medical readiness, and within the mandatory 10-mile geographic radius designated to accommodate the training students. Utilizing other vendors identified on SAM.gov would fail the geographic constraint, necessitating daily student transit times exceeding acceptable military training day limitations, creating clinical scheduling conflicts, and incurring significant travel costs.

9. ANY OTHER FACTS SUPPORTING THE USE OF OTHER THAN FULL AND OPEN

COMPETITION

Failing to secure this training via this sole-source vehicle will result in Air Force physical medicine apprentice graduates being unable to sit for the licensure exam. This directly impacts clinic staffing and capabilities at MTFs, embedded units, and deployed environments, as un-licensed or un-certified graduates cannot legally act as assistants to physical therapists. This degrades medical readiness, limits standard rehabilitative care for active-duty airmen, and shifts a heavier patient-care burden onto external private-sector referrals.

10. LISTING OF SOURCES, IF ANY, THAT EXPRESSED, IN WRITING, AN INTEREST IN

THE ACQUISITION

To date, no other sources have expressed a written interest in this requirement.

11. ACTIONS THE AGENCY MAY TAKE TO REMOVE OR OVERCOME ANY BARRIERS

TO COMPETITION

The 771 ESS and the 59th Training Group will continue to monitor the local academic and clinical landscape. Should another educational institution within the designated geographic boundary establish a CAPTE-accredited physical therapist assistant program and demonstrate the capacity to accept the specialized CCAF credit transfers, the Air Force will evaluate the feasibility of competing future Phase II training requirements.