Justifictaion-Columbia.pdf

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Columbia VA Health Care System Home Oxygen and Ventilator Services
Solicitation number
36C24726D0030
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This is a Justification and Approval (J&A) document for a sole source award to a Service-Disabled Veteran-Owned Small Business (SDVOSB) under the authority of VAAR 819.7008.

The Department of Veterans Affairs, Veterans Integrated Service Networks (VISN) 07, Columbia VA Health Care System is awarding a 3-month bridge contract for home oxygen and ventilator services to TransOx, Inc., a certified SDVOSB. The contract period runs from June 1, 2026 through September 30, 2026. The acquisition is structured as a Fixed Price (FFP) procurement to prevent service interruption, as the current home oxygen contract (36C24726D0015) expires on May 31, 2026, and the new long-term procurement is pending a Court of Federal Claims decision. The services required include medical oxygen systems, cylinders, accessories, delivery, setup, preventive maintenance, and repair of both contractor- and government-owned equipment at veteran patient homes. The statutory authority permitting this non-competitive procurement is 41 USC §3304(a)(5) and 38 U.S. Code §8127(c), as implemented by RFO 6.103-5. Market research was conducted across multiple sources including AbilityOne, GSA eLibrary (0 IDVs identified), SBA Dynamic Small Business (582 SDVOSBs identified under NAICS 621610), and SAM.GOV (identifying 10,280 previous VA actions and multiple certified SDVOSBs including TransOx, Inc., Eagle Home Medical Corp, and Panakeia, LLC). The Contracting Officer determined the anticipated cost to be fair and reasonable based on current contract comparison, IGCE, and market survey analysis. The justification was certified by Leonard Robinson, Contract Officer, RPO-East, Network Contracting Office 07, located in Tucker, Georgia.

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Request for SDVOSB/VOSB Sole Source Justification Format IAW VAAR 819.7008/9

VHAPG Part 819.7008/7009 Sole Source Awards to SDVOSB/VOSB Page 2 of 4 Revision: 05 Effective Date: 12/15/2025

The nature of the new FFP procurement is to create a bridge contract to prevent a break in services (Continuation of Services). The current home oxygen and ventilator services contract 36C24726D0015 expires on May 31, 2026 and the new long-term procurement is pending the Court of Federal Claims decision. With the current contract expiring on May 31, 2026, and the additional time required for the current procurement, a bridge contract is necessary to avoid a service gap and ensure uninterrupted veterans' care.

3. Description of Supplies/Services Required to Meet the Agency’s Needs: The Columbia VA Health Care System has an ongoing and continuous need to contract for home oxygen supplies and services. The incumbent shall provide medical oxygen systems, including medical oxygen cylinders and related accessories, delivery, setup, preventive maintenance, and repair of both contractor- and Government-owned equipment at the homes of VA Medical Center patients to meet the needs of VA beneficiaries. The requested period of performance is as follows: June 01, 2026 to September 30, 2026.

4. Statutory Authority Permitting Other than Full and Open Competition: 41 USC §3304(a)(5), 38 U.S. Code § 8127(c), as implemented by RFO 6.103-5 (Authorized or Required by Statute). COs may use the non-competitive (sole source) procedures authorized in VAAR 819.7008 (DEVIATION) or VAAR 819.7009 (DEVIATION)- up to $5,000,000. Check the specific VAAR clause used below:

(X) 819.7008 Sole source awards to a certified service-disabled veteran-owned small business

5. Demonstration that the Contractor’s Unique Qualifications and/or Nature of the Acquisition Requires the Use of the Authority Cited Above (applicability of authority): The Government does not have the capability to provide home oxygen services. A review of potential acquisition alternatives was conducted, considering prior acquisitions of this service, their impact on these alternatives, and related in-house efforts. The best acquisition method was identified as a separate contract award, based on the time required to award the new home oxygen contract, resulting from the new long-term requirement pending the Court of Federal Claims decision. TransOx, Inc., the incumbent, provides services and has the qualifications to meet the demands of setting up and delivering home oxygen services, providing

VHAPG Part 819.7008/7009 Sole Source Awards to SDVOSB/VOSB Page 3 of 4 Revision: 05 Effective Date: 12/15/2025 education and operating instructions directly to veteran recipients on the safe use of home oxygen machines. TransOx, Inc., has been performing satisfactorily with no complaints for the Columbia VA Health Care System. In addition, it is in the Government's best interest to sole-source this acquisition to TransOx, Inc., to prevent a break in services (Continuation of Services).

6. Description of Efforts Made to ensure that offers are solicited from as many potential sources as deemed practicable, including whether a notice was or will be publicized as required by RFO 6.301 and, if not, which exemption under RFO 5.101(b)(1) applies: Based on the current contract status for home oxygen services, there is a need to ensure that direct patient care is not interrupted. An interruption in services could cause harm or death to patients. The current home oxygen contract is expiring, and the new long-term procurement will require additional time pending the Court of Federal Claims decision. As a result, the requirement is to be awarded to TransOx, Inc., as a sole source, to prevent a service interruption and to allow time to award the new long-term contract.

7. Determination by the CO that the Anticipated Cost to the Government will be Fair and Reasonable: The cost to the Government was deemed fair and reasonable based on the current contract comparison to the current contract, the IGCE, and the market survey comparing prices to similar supplies and services. The current monthly cost ranges between . The proposed price for services remains unchanged.

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

In accordance with RFO 8.102, AbilityOne was considered; however, no sources were found to satisfy the requirement.

The GSA eLibrary website was searched to identify potential GSA and VA FSS contracts. GSA eLibrary identified 0 IDVs capable of satisfying the services.

The SBA Dynamic Small Business website was searched to identify small businesses capable of satisfying the requirement. The search identified and found the following certified small businesses information under the

NAICS 621610:

-SDVOSB-582

-VOSB-628

-EDWOSB-168

-HUBZONE-40

-WOSB-415

-8(a) and 8(a) Joint Venture-45

Conducted a search on SAM.GOV to collect data on previous awards using the keyword(s) “Home Oxygen Services” and Department of Veterans Affairs as the search criteria. The result identified 10,280 previous actions from the Department of Veterans Affairs. Several SDVOSBs were identified during the search, including TransOx, Inc., Panakeia, LLC, and Eagle Home Medical Corp.

-TransOx, Inc – Certified SDVOSB -Eagle Home Medical Corp – Certified SDVOSB -Panakeia, LLC – Certified SDVOSB -Hometown Veterans Medical, LLC – Certified SDVOSB -Veterans First Healthcare - Certified SDVOSB

VHAPG Part 819.7008/7009 Sole Source Awards to SDVOSB/VOSB Page 4 of 4 Revision: 05 Effective Date: 12/15/2025

The Supply Chain Master Catalog website was searched to identify potential IDVs. SCMC identified multiple IDVs. The IDVs identified were for the awarding agency's use only or could not satisfy the requirement.

9. Any Other Facts Supporting the Use of Other than Full and Open Competition: There are no other supporting details, as the requirement will be sole-sourced IAW U.S.C 8127(c).

10. Listing of Sources that Expressed, in Writing, an Interest in the Acquisition: TransOx, Inc. is the only source sought as a result of the requirement being sole-sourced to the incumbent. The long-term contract had multiple SDVOSBs interested in the Columbia VA Health Care System Home Oxygen and Ventilator Services.

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: Due to unforeseen circumstances, Columbia VA Health Care System's long-term requirement for home oxygen and ventilator services is currently requiring additional time due to the Court of Federal Claims case. To avoid such barriers in the future, an acquisition package will be sought earlier from program offices.

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.

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

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

Leonard Robinson Date Contract Officer RPO-East, Network Contract Officer 07

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

LEONARD

ROBINSON

Digitally signed by LEONARD

ROBINSON

Date: 2026.05.14 13:06:24 -04'00'

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