Limited Sources Justification-TRAIN_FINAL.pdf

Learning Management System/Service Justification & Approval for a Limited Sources Award under GSA FSS

JUSTIFICATION AND APPROVAL

FOR A LIMITED SOURCE AWARD UNDER A FEDERAL SUPPLY SCHEDULE

This Limited Source Justification (LSJ) executed upon the basis of the following justification, prepared in accordance with Federal Acquisition Regulation (FAR) 8.405- 6(c), I, as Contracting Officer, hereby approve the use of sources limited to fewer than those required in FAR 8.405-2 and FAR 8.405-3 pursuant to the authority of 41 U.S.C.

251 as implemented by FAR 8.405-6(a)(1)(B) Only One Source Capable. This acquisition is conducted under the authority of the Multiple-Award Schedule Program (41 U.S.C. 251, et seq. and 40 U.S.C. 501).

1. Agency and Contracting Activity:

This procurement is executed by the US Department of Veterans Affairs (VA), Office of Procurement, Acquisition and Logistics (OPAL), Strategic Acquisition Center – Frederick (SAC-F) on behalf of the Veterans Benefits Administration (VBA), Medical Disability Exam Office (MDEO).

2. Description of Action:

The proposed acquisition is for a twelve (12) month firm-fixed price Blanket Purchase Agreement (BPA) with four (4) additional twelve (12) month options with the Public Health Foundation (PHF) a private, non-profit organization, for use of their proprietary TRAIN Learning Network subscription service as a learning management platform.

The proposed effort will be awarded under General Services Administration (GSA) Federal Supply Schedule (FSS) contract 47QTCA18D00LB (Schedule 70) to Public Health Foundation, 1300 L Street, Suite 800, Washington, DC 20005.

3. Description of the Supplies or Services:

PHF is the sole provider of the TRAIN Learning Network, a trusted leader in providing training and other learning opportunities to public health, healthcare, behavioral health, and preparedness; the product is not available through any other vendor. As the sole owner of TRAIN, PHF is the only organization that offers a subscription service to a learning management system platform and associated services that can offer the VBA the following:

• Access to a national catalog of more than 4,500 shared trainings developed by government agencies, academic institutions, and other course providers for professionals who protect the public’s health, including the ability to track registration and completion of this learning content. Most courses are free, and over 45% offer continuing education credits for medical providers, including, but not limited to, Certified Nurse Educator, Continuing Medical Education, and Certified Health Education Specialist certifications.

• National standards such as the Core Competencies for Public Health Professionals, as well as the Public Health Preparedness and Response Core Competencies, Public Health Preparedness Capabilities, 2017-2022 Health Care System Preparedness and Response Capabilities, and Core Competencies for Disaster Medicine and Public Health are fully integrated into TRAIN. Training content can be tagged with these standards (or those specific to VBA), allowing the learner to search for courses by competencies and/or capabilities.

Additionally, TRAIN affiliate agencies, in this case, VA and the MDE contractors, can report both their non-provider and provider training by these standards..

• Ability to train, monitor, and track licensed professionals and other required training in the VBA outside of government staff, such as nurses, medical examiners, etc. (including the healthcare workforce in general) without paying for additional seats. TRAIN charges a flat annual subscription fee and does not charge a per-user or per-license fee.

• Membership on the TRAIN Affiliate Consortium (TAC), a forum for TRAIN’s 26 state, five federal, three tribal, and three national organization affiliates to share training resources, collaborate around workforce development efforts, and provide support on how best to use TRAIN. TRAIN affiliates include state health departments and preparedness agencies as well as the Centers for Disease Control and Prevention, Medical Reserve Corps, and Veterans Health Administration. The TAC communicates through bimonthly calls, annual meetings, a monthly newsletter, and an active email listservice.

The total anticipated cost associated with set up of access to the TRAIN Learning Platform is as follows:

Period of Performance Anticipated Cost Base $1,053,160.00 Option Year 1 $1,083,742.80 Option Year 2 $1,116,236.54 Option Year 3 $1,149,723.64 Option Year 4 $1,184,215.35

TOTAL $5,587,060.33

4. Authority and Supporting Rationale:

Per FAR Subpart 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 supply or services are unique or highly specialized.

The TRAIN Learning Management System (LMS) is a unique and specialized proprietary platform by PHF that will meet the training requirement needs of both internal MDEO employees and MDE contract examiners. The award of a sole-source BPA to PHF is the most appropriate method to quickly assess, provide and track training requirements. This training is on timely topics, such as opioids crisis, emergency preparedness and response, infectious diseases and immunization.

The use of this platform will allow the MDEO staff and examiners the opportunity for continuimg medical education. In addition to the classes already in the TRAIN system, VA has the ability to tailor and add training that is for VA-specific requirements, such as, but limited to, training on how to conduct Spina Bifida, Blue Water Navy, and Traumatic Stress Disorder (PTSD) examinations. Other pressing public health issues, such as the novel coronavirus disease outbreak of 2019 (COVID-19) are covered as well in this platform. Further, MDEO will be able to tailor the training to help the MDEO examinaers, learn how to appropriately fill out the “worksheet” representing the Disability Benefit Questionnaire (DBQ) of the Compensation and Pension (C&P) examination that is a part of the critical piece of evidence for determining the extent of permanent impairment. This training will assist to significantly avoid errors when filling out the DBQ and C&P worksheet, reducing unecessary re-work, producing both time-and money-saving outcomes.

5. A determination by the ordering activity contracting officer that the order represents the best value consistent with FAR Subpart 8.404(d).

The proposed award to PHF represents the best value consistent with FAR Subpart 8.404(d). Services offered on the schedule are priced as an initial set up fee and an annual maintenance and reporting fee, and GSA has already determined the prices of fixed-price services, and rates for services offered under schedule contracts to be fair and reasonable. Therefore, ordering activities are not required to make a separate determination of fair and reasonable pricing, except for a price evaluation as required by FAR Subpart 8.405-2(d). By placing an order against a schedule contract using the procedures in FAR Subpart 8.405, the ordering activity has concluded that the order represents the best value (as defined in FAR Subpart 2.101) and results in the lowest overall cost alternative (considering price, special features, administrative costs, etc.) to http://farsite.hill.af.mil/reghtml/regs/far2afmcfars/fardfars/far/08.htm#P86_13914 meet the Government’s needs in light of the nature of the requirement. Although GSA has already negotiated fair and reasonable pricing, the Contracting Officer will seek additional discounts before placing the order (see FAR Subpart 8.405-4).

6. A description of the market research conducted among schedule holders and the results or a statement of the reason market research was not conducted.

The effort did not yield any additional sources that can meet the government’s requirements. There is no competition for this acquisition. In accordance with FAR Subpart 5.301, this Limited Sources Justification document will be published within 14 days after order award pursuant to FAR Subpart 8.405-6(a)(2)(i).

Extensive market research has been completed and it has been determined that the TRAIN learning platform is only available through Public Health Foundation. There is no comparable service or platform on the open market to allow for full and open competition. To fully understand the marketplace capabilities, a Sources Sought was drafted and placed on the government point of entry (GPE), Contract Opportunities, on December 15, 2020. The Sources sought asked the below questions. In addition, potential vendors were advised to submit a Capability Statement, Socioeconomic Status, GSA contract number, and Points of Contract.

1. Tell us about your learning management network as it relates to providing ongoing clinical education and training to healthcare providers, conus and oconus, for their unique learning needs and ability to maintain clinical subject matter expertise including continuing education credits for licensure.

2. Describe your ability to identify current learners within your network using MDEO rosters to tag demographics (i.e. clinician NPI #) for MDEO to assign, track, and report MDEO training completions for healthcare providers as well as assist in creating new learner accounts.

3. Explain your administrator services and mentoring for specific audiences including learners (finding courses, accessing learner records and certificates, resetting passwords, and other tasks as necessary) , MDEO staff and vendor staff administrators (mentoring and tailored technical assistance regarding administrator role using your system effectively, how to provide customer support services for learners and course providers, establish and use learner demographics, list courses, approve courses and course providers, expiring or removing courses, apply course credit with course completion dates, user account management, performing basic data analysis, and creating ad-hoc reports).

4. Explain your services for designing (includes course curation and training plan), developing, modifying, publishing, and deploying training products ranging in complexity that includes the adaptation of eLearning templates (i.e. Captivate, Articulate Storyline, Lectora, etc.), incorporating stock or MDEO provided images, custom narration, and Section 508 compliant. Development may include video editing, interactive and decision-based lessons, pre- and post-assessments, and evaluations.

5. Explain your ability to tailor data reports based on a variety of demographics including vendor group, clinical specialty group, training product, location, and other demographics as needed as well as provide specific administrator roles tailored to allow specific administrators to retrieve on demand reports and comply with MDEO contractual information sharing security.

6. Information Technology (IT) and Security: Explain your IT & security capabilities to protect PII, limit MDEO course and learner visibility, protect users from 3rd party advertisements and promotions, limit MDEO vendor administrator ability to validate learner’s course completions without the ability to view competing vendors’ learners, provide secure server space for publishing training products of various formats, accessibility to users worldwide, and bandwidth to support thousands of users engaged int raining products simultaneously.

The Sources Sought due date was Friday, December 18, 2020 by 12:00 PM EST. One

(1) vendor submitted a response by the closing date and time:

• The Public Health Foundation (PHF)

PHF’s response was thoroughly reviewed with the additionally requested information and was deemed to satisfy MDEO’s needs, as all questions were adequately addressed.

Concurrent with the GPE sources sought, the government researched GSA e-library and found a potential of 27 vendors under SIN 54151ECOM. Of the 27 vendors, there were (8) Small Busineses, (2) Service Disabled Veteran Owned Small Busineses, and

(4) Women Owned Small Businesses. An email was sent to all 27 vendors requesting a Capability Statement, Socioeconomic Status, GSA contract number, Points of Contact, along with answering the above-mentioned questions, PHF was the only response.

Veteran Information Pages (VIP) was searched using the applicable NAICS and PSC and found 15 potential SDVOSB vendors. Further research indicated no vendor was determined capable of fulfilling the requirement.

7. Any other facts supporting the justification:

If this action is not approved, MDEO may suffer additional lost time in extensive efforts to write, assign and monitor start-up of ongoing training requirements for VA MDE examiners and VA employees. MDEO needs independent access to the TRAIN learning platform in order to monitor required training completion for each of the thousands of unique and individual examiners performing Medical Disability Examinations under contract with MDEO providers.

8. Actions, taken to remove or overcome any barriers to competition before subsequent acquisition for the supplies or services is made:

The government anticipates a continual need for the training for the next five years.

However, the government will make efforts to continually survey the market and make all feasible attempts to remove any and all subsequent barriers to competition for these services in the future.

9. The ordering activity Contracting Officer’s certification that the justification is accurate and complete to the best of the Contracting Officer’s knowledge and belief and evidence that the supporting data that form a basis for the justification have been certified as complete and accurate by technical/program personnel.

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.

Lisa Tomaselli Date: _____________________

Program Manager Signature: _____________________

11. Determination of Best Value/Procuring Contracting Officer Certification: I hereby determine that the proposed contract action will represent the best value to the Government. GSA has already determined that the prices on the FSS contract are fair

January 28, 2021 and reasonable. Further price analysis will be conducted and subsequent discussions held as necessary. Additionally, price discounts will be sought. I certify that this justification is accurate and complete to the best of my knowledge and belief.

Kelly Dempsey Date: _____________________

Procuring Contracting Officer Signature: _____________________

Approval

12. Contracting Activity Competition Advocate Certification: In my role as Contracting Activity Competition Advocate, based on the foregoing justification, I hereby approve the acquisition of the TRAIN Learning Management System/Service, pursuant to the authority cited in paragraph 4 above, subject to availability of funds, and provided that the services herein described have otherwise been authorized for acquisition.

Efrain J. Fernandez Date: _____________________ Local Competition Advocate Director-Strategic Acquisition Center-Frederick Signature: _____________________