Limited Sources Justification - FAR Part 8 Redacted.pdf

Brand Name DSS Supply CONTROL NUMBER VA-26-00023382 Chain GUI Overlay Renewal

LIMITED-SOURCES JUSTIFICATION

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: This proposed action is for the award of a firm-fixed price task order issued on a sole source basis to Document Storage Systems Incorporated (DSS), located at 12575 US Highway One, Suite 200, Juno Beach, Florida 33408 under the terms and conditions of its General Services Administration (GSA) Multiple Award Schedule (MAS) contract number 47QTCA23D005Q for renewal of brand name DSS software maintenance, technical support, and licenses for the Supply Chain Graphical User Interface (SCGUI).

3. Description of the Supplies or Services: The VA Veterans Health Administration (VHA) has a requirement to renew brand name maintenance and support for the currently deployed perpetual software licenses for the production instances of the SCGUI Overlay for the Veterans Information Systems and Technology Architecture (VistA) for VA users at 141 VA Medical Centers (VAMCs), the Employee Education Services (EES), the Consolidated Mail Order Pharmacy (CMOP), and a training instance at the Veterans Affairs Acquisition Academy (VAAA). VA initially procured the brand name DSS SCGUI applications in fiscal year 2013 and deployed across the VA enterprise in fiscal year 2016 to its current footprint. Since then, the software has been continually further developed and enhanced to provide a tiered control and implementation of standardized national, Veteran Integrated Service Network and VAMC business rules, controls, data management, and standardization required to perform the functions relating to VistA’s Integrated Funds Distribution, Control Point Activity, Accounting and Procurement (IFCAP); General Inventory Package (GIP);

Automated Engineering Management System/Medical Equipment Reporting System (AEMS/MERS); Prosthetics Inventory Package (PIP); Equipment Turn-in (EQUIP);

VistA Integration, Revenue and Reporting (VIRR); and Prosthetics and Sensory Aids Services (PSAS). Under this effort, the contractor shall provide operations and maintenance support which includes labor, travel, and expenses for continuation training, operations and maintenance. The operation and maintenance shall include required system fixes, software enhancements, bug fixes, on-site and off-site support as required for the GUI and all updates and upgrades during the contract period.

Additionally, there are two Optional Tasks. The first Optional Task is for the renewal of the test instance licenses of the Above PAR (APAR)/Above Advanced Prosthetics Acquisition Tool (APAT) on a yearly basis. The second optional task would provide VA with technical reviews of how proposed/planned VistA changes (generated from other connected VA systems such as the Electronic Health Record Modernization or Financial Management Business Transformation) may impact APAR and APAT usage if deployed, as well as provide a code review of MUMPS code Impacts for those proposed changes. Help desk services are not required for the test instance.

The proposed Period of Performance shall be an 11-month base period followed by 2 consecutive 12-month option periods, if exercised. There are two Optional Tasks. The Optional Task(s) shall follow the same period of performance in which it is exercised and shall not extend past the Ultimate Completion date of the Task Order. The total estimated value of the proposed action, inclusive of all optional periods and tasks, is

4. Authority: This acquisition is conducted under the authority of the Multiple-Award Schedule Program. The specific authority providing for a limited source award is United States Code (U.S.C.) under 41 U.S.C. 3304(a)(1) as implemented by Federal Acquisition Regulation (FAR) Overhaul VA Deviation 8.401(b) and General Services Administration Manual/Regulation (GSAM/R) 538.7104-3(b)(ii), “Only one source is capable of providing the supplies or services at the level of quality required because the supplies or services are unique or highly specialized.”

5. Rationale Supporting Use of Authority Cited Above: The proposed source for this action is DSS, located at 12575 US Highway One, Suite 200, Juno Beach, Florida 33408. Based on market research, as detailed in Section 8 of this justification, no other source can provide the renewal of the required brand name maintenance and support services or provide the renewal of the test licenses other than the proposed source.

Since fiscal year 2013, VA has utilized and enhanced the APAR and APAT SCGUI applications, eventually deploying the solution to the Enterprise in fiscal year 2016. The brand name DSS APAR and APAT SCGUI applications have been sustained since that time for continued use by VistA users/prosthetics ordering teams at 141 VAMCs, the EES, CMOP as well as a training instance for the VAAA. The brand name SCGUI software applications are utilized to provide a tiered control and implementation of standardized national, Veteran Integrated Service Network and VAMC business rules, controls, data management and standardization required to perform the functions relating to VistA’s Integrated Funds Distribution, Control Point Activity, Accounting and Procurement, General Inventory Package, Automated Engineering Management System/Medical Equipment Reporting System, Prosthetics Inventory Package, Equipment Turn-In , VistA Integration, Revenue and Reporting and Prosthetics and Sensory Aids Services.

DSS is the original software developer of the brand name APAR and APAT SCGUI applications and is therefore the only source that has access to the underlying proprietary software code that these applications were built upon. Access to the proprietary code is strictly controlled by DSS and is not provided to any other entity.

Access to this proprietary source code is critical to develop and provide patches, fixes, updates, support, and maintenance so that any of these actions seamlessly interoperate with the deployed SCGUI applications. Specifically, the proprietary software code that the DSS APAR/APAT applications are based on has been continuously customized and designed to overlay the VistA application and its subsequent updates/changes.

Introduction of software code for maintenance that was not developed by DSS introduces risk that data may be lost, corrupted, or inaccurate while introducing unnecessary security, privacy, and security vulnerability risks without a way to mitigate the risk. Additionally, there is no way to validate how other brand/developed code would interact with or affect the currently deployed software.

Devoid of any maintenance support from DSS, the current APAR/APAT applications could be rendered unusable/inoperable. Without an application that has the ability to interface with the current VistA platform, VA systems users would be required to revert to legacy VistA solutions and ordering procedures, which would significantly impede acquisition and provisioning of medical supplies and prosthetics that the Veterans require. Based on the “Average Days to Close a Prosthetic Consult” metric, this would increase the provisioning by an average of seven (7) days, from the current metric of

3.2 days to 10.2 days. The delay will exponentially compound wait times and degrade service to Veterans. As such, continued maintenance of the current SCGUI is paramount to maintaining timely delivery of healthcare services, supplies, and prosthetics to Veterans.

VA requires system fixes, software enhancements, and updates necessary to maintain the current APAR/APAT interfaces between DMSS, FMBT, and the EHRM solution.

Additionally, VA has a requirement to maintain VHA enterprise reporting, enterprise dashboards, ordering, provisioning, and inventory management capabilities, and data integration that the APAR/APAT applications currently provide. These requirements will require support activities to include software testing and configuration to ensure system interfaces maintain operability While there may be alternative brand solutions that exist which can provide general overlay or medical provision capabilities, none of these solutions can provide all the technical and functional requirements. The introduction of multiple products to meet individual VA requirements creates undue complexity and risks that data is not properly transmitted/received, and ultimately that the Veteran does not receive timely the required Prosthetics. Additionally, none of these alternative brands have access to the proprietary software code necessary to maintain and support the currently deployed brand name DSS perpetual licenses. Without access to the proprietary source code, an alternative vendor would be required to develop a new interface between its software platform and VistA, undergo platform functional and security testing and configuration prior to being able to be deployed across VA. With this approach, however, VA would incur substantive cost and effort. Specifically, VA estimates this action would cost an approximate $30,000,000.00 to develop, deploy, and test the solution given the complexity of the unique, underlying VistA environments.

This does not include the approximate duplication of cost of $9,000,000.00 per year in maintenance costs of the current SCGUI that would also have to be maintained concurrently until the new theoretical system could be deployed. These estimates are based on historical information of deploying solutions of similar size and scope within the Enterprise, a cost analysis conducted as part of the FITARA Acquisition Compliance Review, and market research. The anticipated timeline for any potential new solution is estimated to take up to 36 months. These estimated duplicative costs would not be recouped through competition.

Brand name support from DSS is required to perform review of changes to VistA code to the deployed solution. Specifically, VA Enterprise continues to revolutionize and encompass forward-looking systems such as Financial Management Business Transformation (FMBT) platform and the Oracle Cerner EHRM system. These systems interface with legacy VistA and at times trigger changes to the underlying VistA code.

VA requires technical support services from DSS to validate and document how the legacy VistA changes would affect the deployed APAR and APAT solutions to support VA decision making. In order to perform this analysis, a responsible source needs access to the proprietary software code. As noted above, no other source other than DSS has access to this code.

Based on the above, only the proposed source, DSS, can satisfy all the Government’s operation, technical, maintenance support, and test instances requirements outlined above. Failure to procure these services as described will have a significant, negative effect on VA’s ability to perform its mission of providing world class Veteran centered healthcare, provide medical supplies in a timely manner, and meet the prosthetics needs of Veterans to ensure proper care.

6. Efforts to Obtain Competition: Market research was conducted, details of which are in Section 8 of this justification. This effort did not yield any additional sources that are capable of meeting the Government's requirements. The VA’s technical representative confirmed that there are no authorized resellers of DSS’s proprietary software and associated services through information provided by DSS; therefore, no competition is anticipated for this acquisition. Pursuant to FAR 5.302(a), GSA Manual/Regulation 538.7104-3(b)(i), and 41 U.S.C. 3302(d), “Public Notice Requirements Related to Sole Source Task or Delivery Orders” the resultant award and redacted copy of this Limited- Sources Justification shall be made available on the Contracting Opportunities page within 14 days of award of the order.

7. Actions to Increase Competition Actions to Increase Competition: In order to remove or overcome barriers to competition in future acquisitions for this requirement, the Government’s technical experts will continue to conduct market research to ascertain if changes in the marketplace would enable future actions to be completed.

8. Market Research: Market research was conducted in July and August 2025 through reviewing technical documentation and vendor websites. Specifically, VA technical experts reviewed the web and information pages for similar SCGUI products and services. The websites that were reviewed included Adtroit Information Systems Complete Healthcare Software, CaraSoft Technology Group ShipCom, NXGN Management, LLC Nextgen Healthcare, OptiMantra, Inc. Practice Management

Software, Oracle Government HCM for Government, and Networking Technology, Inc.

RXNT Medical Office Software. While the websites reviewed indicated multiple GUI tools and developers were available in the marketplace, VA technical experts concluded that none of these developers or software providers can maintain or support the existing brand name DSS perpetual licenses for the SCGUI applications as discussed in Section 5 of this justification.

Further, based on review of alternative brand solutions, VA technical experts noted they appear to lack the capability of providing all the technical and functional requirements that DSS currently provides. While competing solutions provide SCGUI capabilities, they have not been developed for use within healthcare environments, do not provide interfaces for the VA’s VistA IFCAP, GIP, AEMS/MERS, PIP, EQUIP, VIRR and PSAS, nor have these competing solutions been hardened enough to meet the security requirements for use within the VA network environment. Additionally, none of these solutions have access to the proprietary source code as mentioned above, nor can they provide the required maintenance services.

Additional market research was conducted by issuing Request for Information (RFI) 36C10B26Q0183 in February 2026 on the System for Award Management (www.sam.gov) website to ascertain if there are any sources other than DSS that were capable of meeting the Government’s technical and operational requirements for this procurement. The RFI yielded four responses which consisted of two small businesses, one business that did not provide business size details, and the proposed source, a large business, DSS. One small business proposed an OEM partnership model, one small business proposed maintenance of the OEM software where they would act as a prime vendor, and the remaining size undetermined business stated interest in the RFI but no other information. The Government’s Subject Matter Experts/Technical Experts reviewed the responses and determined that only DSS can meet VA’s technical and operational requirements, specifically those for maintaining and testing the existing solution. The vendors that responded to the RFI were advised of the VA’s assessment that they are unable to meet all the Government’s requirements. No objections were received.

In discussion with the OEM, DSS stated in February 2026, that for this specific effort, it would not resell the required services to any other vendor. As such, there is no expectation of competition, and this action must be solicited on a sole source basis direct to DSS.

9. Other Facts: None.

Technical/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.

Best Value Determination

I hereby determine that the proposed contract action will represent the best value to the Government. Best Value will be determined by comparing the proposed prices to published price lists, as well as to historical pricing for the same items, and then comparing the proposed price to the independent Government Cost Estimate. GSA has already determined that the prices on the DSS GSA Schedule are fair and reasonable, and any inconsistencies will be addressed via subsequent negotiations held as necessary. Additionally, price discounts will be sought.

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 Head of the Contracting Activity approval is an independently supported decision not wholly reliant on the legal sufficiency determination.

HCA Approval

In my role as Head of the Contracting Activity, based on the foregoing justification, I hereby approve the acquisition of brand name DSS software maintenance, technical support, and licenses for the SCGUI , pursuant to the authority cited in Section 4 above, subject to availability of funds, and provided that the services herein described have otherwise been authorized for acquisition.

LIMITED-SOURCES JUSTIFICATION COORDINATION MATRIX

Supply Chain Graphical User Interface (GUI) Overlay, VA-26-00023382