Limited Source Justification EHRS_Redacted.pdf

Rev.:5/2024

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION

IT Procurement Office (ITPO)

LIMITED-SOURCES JUSTIFICATION

For Electronic Health Record System, 1 Year Base Period plus 4 Option Years

This is a Limited-Sources Justification (LSJ) prepared by the National Aeronautics and Space Administration (NASA) IT Procurement Office (ITPO).

This acquisition will be conducted under the Multiple-Award Schedule (MAS) Program (Title 41 U.S.C. 152(3)). This action is for a sole source firm-fixed price delivery order for the acquisition of the Electronic Health Record System (EHRS), 1 Year Base Period plus 4 Option Years.

It is anticipated that award will be made to Cority Software Inc. under General Services Administration (GSA) Federal Supply Schedule (FSS) GS-35F-0032U.

The total estimated price of the proposed order is . The estimated period of performance is Base Year: 10/01/2025 - 09/30/2026, Option Year 1: 10/01/2026 - 09/30/2027, Option Year 2: 10/01/2027 - 09/30/2028, Option Year 3: 10/01/2028 - 09/30/2029, Option Year 4: 10/01/2029 - 09/30/2030.

Authority Cited and Rationale:

FAR 8.405-6(a)(1)(A). An urgent and compelling need exists, and following normal procedures would result in unacceptable delays.

FAR 8.405-6(a)(1)(B). Only one source is capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized.

FAR 8.405-6(a)(1)(C). In the interest of economy and efficiency, the new work is a logical follow-on to an original GSA FSS order provided that the original order was placed in accordance with the applicable GSA FSS ordering procedures. The original order or BPA must not have been previously issued under sole-source or limited-sources procedures.

FAR 8.405-6(b), Items Peculiar to One Manufacturer. An item peculiar to one manufacturer can be a particular brand name, product, or a feature of a product, peculiar to one manufacturer. A brand name item, whether available on one or more schedule contracts, is an item peculiar to one manufacturer.

Rationale:

Cority is the sole source provider for this requirement as described below.

NASA has built extensive infrastructure and systems around Cority EHRS, with 15 years of successful implementation. This significant financial investment would not be recovered through competition, making continued use of Cority financially prudent. NASA has invested over in the Cority software application and related services, plus substantial additional costs from contractors supporting implementation and operations.

This is an extension of the EHRS contract which is a cornerstone of NASA’s efforts to maintain the health, safety, and productivity of its workforce. With a highly specialized scope, the EHRS contract supports the management of critical health information for NASA’s 100,000 employees, including medical records, industrial hygiene data, exposure tracking, and medical certifications.

This system is not only essential for maintaining compliance with workplace health and safety standards but also plays a vital role in ensuring operational efficiency and readiness for NASA’s ambitious missions.

In 2024 alone, the EHRS processed over 62,000 records weekly, managed 27,000 clinic visit records, and oversaw nearly 600 exposure group protocols. Beyond this, the EHRS team demonstrated its value by performing a full business analysis that led to the consolidation of health records systems across several Centers. This effort resulted in a projected annual cost savings of over in software costs and an additional in startup and transfer fees, showcasing the team’s commitment to fiscal responsibility. The system’s seamless management and ongoing updates enable NASA to provide high-quality occupational health services at a low cost per employee, reduce administrative burdens, and enhance workplace safety and well-being.

Cority has been customized to accept NASA-specific diagnostic codes for Occupational Health exams (including regulatory-required classifications) conducted at all NASA clinics. The Cority EHRS for NASA has also been configured in the following functional capacities specific for NASA, and a new system would also require this configuration:

o Secure NASA Access Management System (NAMS) authentication when using the software for each employee hired to provide NASA’s occupational health services.

o Secure electronically transfer of NAMS data into new occupational health records for all new employee hires across the agency.

o Secure data transfer from wide range of diagnostic equipment at all NASA clinics use including hearing tests devices and pulmonary exam devices into EHRS.

o Secure and direct data transfer from accounts for majority of NASA clinics to receive results from national clinical sample analysis labs (Quest and LabCorp) o Secure record management for Employee Assistance Program services across 6 NASA centers.

o Digital interface to achieve Fitness Center health clearances.

o Capacity to complete digital exchange of employee medical records between NASA center clinics within minutes of employee reassignment to another center.

After a thorough evaluation of the potential benefits and drawbacks of switching to a new EHRS, we recommend maintaining our current Cority EHRS. Several key factors support this conclusion:

1. Cost of Integration and Legacy Data Migration: Transitioning to a new EHRS would require significant financial investment, both in terms of the initial purchase and the integration process. Incorporating years of legacy data into a new system is a complex and expensive task. Data migration often involves the conversion of thousands of records and the need for customized interfaces to ensure continuity of patient care and accurate historical data access. These costs—both direct and indirect—could be prohibitive, particularly considering the associated risks of data loss or integration delays.

2. Billing Focus is Unnecessary: Many of the new EHRS in the market are heavily focused on billing functionalities, making them ideal for organizations that rely on revenue generation through patient billing. However, since NASA does not charge in the traditional sense for services, we do not require a billing centric EHRS. Investing in a system that includes billing features would be unnecessary and would drive up costs without offering any tangible benefit to our operations.

3. Unnecessary Investment in Data Analytics: While advanced data analytics is an essential feature for many organizations, we do not need to pay extra for an EHRS that specializes in this area. Cority already provides foundational data analytics tools tailored to health and environmental metrics, and additional analytics capabilities can be incorporated separately if needed. Given the flexibility of Cority and the availability of specialized analytics tools in the market, there is no need to transition to a new system solely for enhanced analytics features.

4. Environmental Health Compliance and Regulatory Requirements – Cority is already in use by the NASA Environmental Health team for documenting and managing environmental health data, which is critical for OSHA compliance and other federal regulatory obligations. Cority’s built-in environmental health tracking tools support workplace safety monitoring, exposure documentation, and compliance reporting.

Switching to a different EHRS could introduce compliance risks and require costly customizations to maintain the same level of regulatory adherence.

5. FedRAMP Authorization and Government Compatibility: Cority is FedRAMP authorized and has a strong track record of supporting government agencies and organizations with regulatory compliance requirements. This ensures that we are meeting all necessary federal standards for security and privacy, particularly in terms of workforce health and safety management. Given the regulatory landscape, continuing with a FedRAMP-compliant system like Cority is advantageous, as it meets our current needs without additional compliance risk or overhead.

6. Streamlined Workflow and Familiarity: We have spent significant time and resources configuring and optimizing Cority to suit our specific needs, and our staff is already familiar with its user interface and workflows. Switching to a new EHRS would introduce a learning curve, disrupt daily operations, and require additional training. The long-term benefits of staying with Cority far outweigh the short-term disruptions associated with transitioning to a new system.

7. Cost-Effectiveness: Cority's pricing is significantly more affordable compared to other systems on the market, especially given its focus on workforce health and environmental health data. With its current pricing model, Cority is a highly cost-effective solution that offers robust features without the financial burden associated with other more complex systems.

8. No Need for Standard Medical Interoperability and Specialty Follow-Up: As our organization primarily performs occupational health exams and urgent care, we do not require specialty follow-up capabilities typically offered by other EHRS focused on more complex medical needs. Our focus is on efficient, streamlined care for immediate medical conditions and workplace health monitoring. Therefore, the additional features related to specialty care follow-ups, often found in more generalized EHRS, are not necessary for our operations and would only add unnecessary complexity and cost.

In the broader context of the U.S. EHRS market, it is evident that there is a strong push toward interoperability, cloud-based solutions, and data analytics. However, many of the newer, larger, and more complex systems—such as , , and —are geared toward organizations with a significant focus on patient billing and complex workflows. These systems are often accompanied by substantial implementation and operational costs, not necessary for government agencies or organizations without complex billing needs.

Additionally, as highlighted in the market research, federal agencies face stringent compliance requirements, including FedRAMP authorization, which Cority already meets. The integration of environmental health data within Cority also offers a valuable feature not widely available in other EHRS, especially those tailored to more traditional healthcare settings.

Given the considerable costs and risks associated with transitioning to a new EHRS, the lack of necessity for billing-focused functionality, and the proven capabilities of our current Cority system—particularly its compliance, flexibility, and cost-effectiveness—it is recommended that we continue using Cority. Transitioning to a new EHRS would not provide enough additional value to justify the significant investment required, and Cority's specialized features and FedRAMP compliance align perfectly with our organizational needs. Therefore, maintaining our current system is the most prudent and cost-effective decision.

Determination by the contracting officer that the order represents the best value consistent with FAR 8.404(d):

GSA has already determined the fixed-price supplies and services under schedule contracts to be fair and reasonable. Therefore, ordering activities are not required to make a separate determination of fair and reasonable pricing. By placing an order against a schedule contract using the procedures in 8.405, the ordering activity has concluded that the order represents the best value and results in the lowest overall cost alternative to meet the Government’s needs.

Market Research:

Market research was conducted on SEWP, GSA, and the open market to determine the availability of an EHRS that is capable of meeting NASA’s requirement. While other vendors provide EHRS, only Cority EHRS provides the unique capability required by NASA.

Other Facts:

Previous Procurements with Cority Software Inc. for this requirement:

o GSA Contract# GS-35F-0032U; Delivery Order# 80NSSC21F1411 o GSA Contract# GS-35F-0032U; Delivery Order# 80NSSC18F1684 o Purchase Order# NNK16OR03P o GSA Contract# GS-35F-0032U; Delivery Order# NNK15OB04T o GSA Contract# GS-35F-0032U; Delivery Order# NNK14OL67T

A statement of the actions, if any, the agency may take to remove or overcome any barriers that led to the restricted consideration before any subsequent acquisition for the supplies or services is made:

The Agency will continue to monitor SEWP, GSA, and the open market to review the capabilities of existing service providers. In addition, the Agency will continue to survey the market to identify new entrants in the EHRS market to determine if other vendors can provide the unique services required by NASA.

Electronic Health Record System

LIMITED SOURCES JUSTIFICATION

SIGNATURE PAGE

I certify that the supporting data presented in this justification are accurate and complete.

I hereby certify that this justification is accurate and complete to the best of my knowledge and belief. In addition, I hereby determine that the anticipated price(s)/pricing of the order will be fair and reasonable.