Limiting-Competition-under-SAT Polysomnography Equipment RAHC -Final_Redacted.pdf

Polysomnography Equipment

Version – February 2017

Memorandum for Record – Limiting Competition at or below the Simplified Acquisition Threshold

1. Contracting Activity: Fort Hood Health Contracting Branch, (FHHCB), Fort Hood, Texas, 76544-4752.

2. Description of Action: Polysomnography Equipment

Nature: New Requirement Follow-on Requirement

Contract Vehicle: Purchase Request Number PR 0012306733

Pricing/Contract Type: Fixed

Funds: Other Funds: __DHP_X____ FY: ____FY25___

Name of Proposed Contractor(s) and Address:

Brand Name Buy: Yes No

3. Description of Supplies:

The Reynolds Army Health Clinic (RAHC), Fort Sill, Oklahoma, 73503-9042, has a need for additional PSG (polysomnography) and EEG (electroencephalogram) sleep study equipment for an additional room being prepared to increase efficiency from five to six rooms at Reynolds Army Community Hospital, Fort Sill, Oklahoma. The request is for PSG in-lab acquisition and PSG Review Station with installation per the sleep lab salient characteristics valued at

4. Authority:

FAR 13.106-1(b)(1): For purchases not exceeding the simplified acquisition threshold (SAT), only one source reasonably available, urgency, exclusive licensing agreements, brand name, or industrial mobilization.

5. Reasons for Authority Cited:

Per the customer and Original Equipment Manufacturer (OEM) sole source letter provided by the vendor on 16 July 2025, “Any equipment must be compatible with existing Government-owned equipment currently in place at the facility. Nihon Kohden America, LLC. is the original equipment manufacturer (OEM) for the equipment currently in the facility and the equipment requested. They have no authorized distributors for this equipment at this time, and as such, are the only vendor capable of providing the requested equipment with the required compatibility.”

A sources sought was not posted as there are no third-party providers available.

Awarding to another vendor other than the OEM will void any warranty and or equipment will not be compatible with the existing sleep lab systems.

6. Publicizing Contract Actions: For FAR Part 13 actions, the public display and synopsis requirements of FAR 5.101 and FAR 5.203 do not apply due to the $ threshold, apply and will be followed, or do not apply due to an exception at 5.202 ______________________.

Requirement to post justification in accordance with FAR 8.405-6(b)(3), FAR 13.105(c), or FAR 16.505(a)(4)(iii)(A)

Action is NOT a brand name restriction and is under $250K, no posting required.

Action is a brand name restriction, under $25K, no posting required.

Action is a brand name restriction, over $25K. It will be redacted and posted with the solicitation.

7. Market Research: Market research was conducted to determine the extent of competition available. The contract specialist conducted a dynamic small business search (DSBS) at https://search.certifications.sba.gov/ with the NAICS code “334510” and keywords “polysomnography equipment”. No small businesses were found. This is in keeping with Nihon Kohden’s statement they do not have third party distributors. The manufacturer, Nihon Kohden, cage code 63580, was searched in the SBA website and not found.

The market research results revealed there are no small businesses that can fill this requirement.

Results from this search did not identify any small businesses that could provide polysomnography equipment.

The contract specialist conducted the market research on 9 & 16 July 2025. After conducting the market research, the contracting officer determined the recommended source and the company used in accordance with FAR § 13.106-1(b)(1), for purchases not exceeding the simplified acquisition threshold (SAT), only one source reasonably available, urgency, exclusive licensing agreements, brand name, or industrial mobilization, is the only large business. There are no other small or large businesses that can provide the requested polysomnography equipment.

8. Other Facts:

a. Procurement History: Previous contract information provided below and FPDS-NG was reviewed for “Stryker” and “J065”. 2832 results were returned for all government agencies. Four of the most recent were selected for price comparison and provided below.

Previous contracts for pricing comparison:

W81K00-25-P-0010, 01 January 2025 – 30 September 2028, Nihon Kodhen America LLC, Sleep Lab Maintenance, - $15,517.00.

W81K00-25-P-A056, 31 May 2025, Nihon Kodhen America LLC, Sleep Lab Equipment, - $52,528.55.

Other Contracts reviewed on Federal Procurement Data System-Next Generation:

36C25925P0573, 20 May 2025 – 01 April 2026, Nihon Kodhen America LLC, Polysomnography Equipment, - $305,474.28.

36C25224P0199, 19 December 2023 – 03 February 2024, Nihon Kodhen America LLC, Polysomnography,- $121,282.44.

36C24623P0925, 18 April 2023 – 31 August 2023, Nihon Kodhen America LLC Polysomnography Sleep lab system, - $157,929.83.

b. Other facts. No other necessary facts to include that have not been covered in previous sections.

9. Technical/Requirements Certification: I certify 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.