Limiting_Sources_Justification_OVER_SAT - KCVA Coding 9.2.25.pdf

Request for Limited Sources Justification Format >SAT

VHAPG Part 808.405-6 Limiting Sources Page 1 of 4 Revision: 01 Effective Date: 09/01/2024 Acquisition ID#: 36C255-25-AP-3004

LIMITED SOURCES JUSTIFICATION

ORDER >SAT

FAR PART 8.405-6

Acquisition Plan Action ID: 36C255-25-AP-3004

Contracting Activity: Department of Veterans Affairs, Network/Program Contracting Office 15, located at 3450 S. 4th Street, Leavenworth, KS 66048, in support of VISN 15 Health Information Management (HIM) at the Kansas City VA Medical Center, 4801 East Linwood Boulevard, Kansas City MO 64128. The purchase request number for this acquisition is

1. This will be a follow-on to FSS order 36C25522N0255 that was terminated for convenience on March 4, 2025, by the direction of the Department of Government Efficiency (DOGE).

Since the termination of this order, proper justifications and approvals have been obtained.

Order against: FSS Contract Number: GS23F0019T 36C10G21A0004

Name of Proposed Contractor: Maxim Healthcare Staffing Services, Inc Street Address: 7227 Lee Deforest DR City, State, Zip: Columbia, MD 21046 Phone: 312-577-7524

(3) Description of Supplies or Services:

The estimated value of the proposed action is $496,034.04. The National BPA ends on 6/30/2026.

The purpose of order is to secure services to assign the current appropriate International Classification of Diseases; Current Procedural Terminology; and Healthcare Common Procedure Coding System Level II codes based on electronic health record documentation of outpatient, surgical, and inpatient care and services provided at or under the auspices of a Veterans Health Administration facility, to include all community outpatient clinics, when applicable, and to conduct coding audits of inpatient and outpatient episodes as requested by a Veterans Health Administration facility. The Contractor shall provide all resources necessary to accomplish the deliverables described in the Performance Work Statement except as may otherwise be specified.

This order will be written from the National HIMS BPA. There will be no option years since the National BPA ends 06/30/2026. The National BPAs were competitive, and three awards were issued.

https://www.acquisition.gov/far/part-8#FAR_8_405_6

VHAPG Part 808.405-6 Limiting Sources Page 2 of 4 Revision: 01 Effective Date: 09/01/2024 Acquisition ID#: 36C255-25-AP-3004

(4) Identify the Authority and Supporting Rationale (see below and if applicable, a demonstration of the proposed contractor’s unique qualifications to provide the required supply or service.

FAR 8.405-6(a)(1)(A): An urgent and compelling need exists and following the ordering 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 Federal Supply Schedule order provided that the original order was placed in accordance with the applicable Federal Supply Schedule ordering procedures. The original order must not have been previously issued under sole source or limited source procedures.

While fair opportunity is normally required, I have determined that an exemption to fair opportunity is necessary since the original order was terminated prematurely at no fault of the contractor and the Government need was still there. The program office was unsuccessful at justifying the need for the Medical Coding orders since it was designated as a consulting contract because of the NAICS code used on the National BPA, which flowed down from the GSA contract the BPAs were written from. Since the terminations on the original orders could not be rescinded, a new order is required.

FAR 8.405-6(b): Items peculiar to one manufacturer:

A patent, copyright or proprietary data limits competition. The proprietary data is:

These are “direct replacements” parts/components for existing equipment.

The material/service must be compatible in all aspects (form, fit and function) with existing systems presently installed/performing.

(5) Describe Why You Believe the Order Represents the Best Value consistent with FAR 8.404(d) to aid the contracting officer in making this best value determination: The National HIMS contracts were competitively procured, and pricing will be no more than the unit prices already found fair and reasonable.

VHAPG Part 808.405-6 Limiting Sources Page 3 of 4 Revision: 01 Effective Date: 09/01/2024 Acquisition ID#: 36C255-25-AP-3004

(6) Describe the Market Research Conducted among schedule holders and the results or a statement of the reason market research was not conducted. Market research was conducted for the National HIMS contracts. Three awards were made to small-businesses and decentralized so local contracting officers can award competitive orders. Additional market research was not conducted beyond the national contracts.

(7) Any Other Facts Supporting the Justification: None

(8) 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 Strategic Acquisition Center (SAC) is currently in the beginning stages of establishing a new National Contract for Medical Coding. These contracts are expected to be competitively awarded and decentralized. Once the current BPAs expire on 06/30/2026; we expect the new National Contracts to be available to place competitively awarded orders for each VA Medical Center. If a National Contract is not pursued, then a VISN- `15 contract may be pursued.

(9) 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. I understand that processing of this limited sources justification restricts consideration of Federal Supply Schedule contractors to fewer than the number required by FAR Subpart 8.4. (This signature is the requestor’s supervisor, fund control point official, chief of service or someone with responsibility and accountability.)

Name: Cristina M Love Title: Asst. Chief of HIMS Facility: KCVAMC

(10) Approvals in accordance with the VHAPM Part 806.3 OFOC SOP: This requirement was approved by VACO in accordance with VISN-15 requirements Concurrence procedures. The https://dvagov.sharepoint.com/sites/VHAProcurement/VHAPM2/VHAPM_Part_806.3.aspx https://dvagov.sharepoint.com/sites/VHAProcurement/VHAPM2/VHAPM_Part_806.3.aspx

VHAPG Part 808.405-6 Limiting Sources Page 4 of 4 Revision: 01 Effective Date: 09/01/2024 Acquisition ID#: 36C255-25-AP-3004 approval is documented in the eCMS file at tab P-16. Additionally, the Contracting Officer is the approval authority for exemptions to fair opportunity up to $750K.

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

09/02/2025

CONTRACTING OFFICER SIGNATURE DATE

Robert Bleichner, Contracting Officer NCO-15______________________ __

NAME AND TITLE FACILITY/NCO/PCO