Limiting_Sources_Justification_OVER_SAT_Redacted.pdf

VHAPG Part 808.405-6 Limiting Sources Page 1 of 4 Revision: 01 Effective Date: 09/01/2024 Acquisition ID#: 36C252-25-AP-3087

LIMITED SOURCES JUSTIFICATION

ORDER >SAT

FAR PART 8.405-6

Acquisition Plan Action ID: 36C252-25-AP-3087

(1) Contracting Activity: Department of Veterans Affairs, Network Contracting Office 12, located at 115 S. 84th Street, Suite 101, Milwaukee, WI 53214-1476, in support of VISN 12 VA Health Care System to include the following participating facilities:

Northern Tier Facilities:

Clement Zablocki VA Medical Center, 5000 W. National Ave, Milwaukee, WI, 53295-0001 William S. Middleton Memorial Veterans Hospital, 2500 Overlook Terrace, Madison, WI 53705-2286 Tomah VA Medical Center, 500 E. Veterans St, Tomah, WI 54660-3105 Oscar J. Johnson VA Medical Center, 325 East H St, Iron Mountain, MI 49801-4760 Appleton VA Community Based Outpatient Clinic, 10 Tri-Park Way, Appleton, WI 54914 Milo Huempfner Clinic, 2851 University Ave, Green Bay, WI 54311

Southern Tier Facilities:

Rockford Clinic, 816 Featherstone Rd, Rockford, IL, 61107 Edward Hines, Jr. VA Hospital, 5000 S. 5th Ave, Hines, IL 60141-3030 Jesse Brown VA Medical Center, 820 S. Damen Ave, Chicago, IL 60612-4223 Adam Benjamin, Jr. Outpatient Clinic, 9301 Madison St. Crown Point, IN 46307 VA Illiana Health Care System, 1900 E. Main St, Danville, Illinois 61832-5198 James A Lovell Federal Health Care Center, 3001 Green Bay Rd, North Chicago, IL 60064-3048 1007 USS Tranquility Community Based Outpatient Clinic, 3420 Illinois St, Great Lakes, IL 60088

(2) Description of Action: This acquisition is conducted under the authority of the Multiple-Award Schedule Program (41 U.S.C. 152(3) and 40 U.S.C. 501). The action under review and approval pertains to a short-term bridge. The proposed one-time 6-month bridge will serve as an extension to the existing Veterans Integrated Service Network (VISN) Automated Urinalysis Cost Per Reportable Result (CPRR) Blanket Purchase Agreement (BPA) beyond its period of performance, specifically to avoid a lapse in service caused by delays in awarding a new long-term VISN BPA. This bridge will be noncompetitively awarded to the incumbent contractor to ensure the continuation of vital services without any disruption.

This action is a follow-on to the original Federal Supply Schedule (FSS) BPA 36C25220A0007, and it primarily aims to maintain continuity of services until a new long-term VISN BPA can be awarded. The expiring BPA has a modified period of performance from September 1, 2020, to August 31, 2025, and was initially competed among VA NAC/FSS schedule 66III contract holders.

VHAPG Part 808.405-6 Limiting Sources Page 2 of 4

Acquisition ID#: 36C252-25-AP-3087

Order against: FSS Contract Number: V797D-70260

Name of Proposed Contractor: BECKMAN COULTER, INC Street Address: 250 S. KRAEMER BLVD.

City, State, Zip: BREA, CA 92821 Phone: 1-800-526-3821

(3) Description of Supplies or Services: The estimated value of the proposed action is The bridge involves the continuation of automated urinalysis CPRR services essential for patient diagnostics and care within VISN 12 facilities. These services include the operation and maintenance of automated urinalysis machines, such as the automated urine macroscope unit used to complete a chemical analysis of urine to include color, clarity, specific gravity, pH and the presence/absence of leukocytes esterase, nitrites, total protein, glucose, blood/hemoglobin, ketone, urobilinogen, and bilirubin and the automated urine microscope unit used to determine the presence/absence of sediment constituents, such as but not limited to red blood cells, white blood cells, casts, crystals, bacteria, etc. Both machines are proprietary to the incumbent contractor's platform.

This short-term bridge, covering a 6-month period, is required to ensure uninterrupted service delivery and mitigate risks associated with a break in operations. The expiring BPA, initially valued at $3,096,820.00, facilitated the procurement of these critical diagnostic services, and this bridge will allow sufficient time to approve and award a new long-term BPA.

(4) Identify the Authority and Supporting Rationale:

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.

The authority for this noncompetitive stand-alone bridge award is found under FAR 8.405-6(a)(1)(B), which allows for a limited sources justification when only one source can provide the required services due to the unique or highly specialized nature of those services. The incumbent contractor possesses unique qualifications and proprietary technology necessary to continue delivering the automated urinalysis CPRR services at the required level of quality and performance.

The specific characteristics of the automated urinalysis services, such as compatibility with existing infrastructure, validated equipment, and specialized proprietary technology, limit availability to the incumbent contractor. These factors ensure that only the incumbent contractor can furnish the required services without risking unacceptable delays or diminished quality, thus supporting the decision for a sole-source award.

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

VHAPG Part 808.405-6 Limiting Sources Page 3 of 4

Acquisition ID#: 36C252-25-AP-3087 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

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: The proposed bridge is deemed to represent the best value for the Department of Veterans Affairs (VA) as it ensures continuity of critical diagnostic services, thereby preventing any potential gaps that could negatively impact patient care and VA’s healthcare mission. Consistent with FAR 8.404(d), this limited-source award is expected to deliver the necessary quality and performance essential for uninterrupted service delivery.

By awarding this bridge to the incumbent contractor, who is intimately familiar with the requirements and operational scope, the VA effectively mitigates risks associated with transitioning to a new provider. This decision promotes overall cost-effectiveness, reliability, and continuity, aligning with the best value principles in federal procurement.

(6) Describe the Market Research Conducted: Due to the urgent nature of the requirement and the need to prevent a service lapse, extensive market research was not conducted for this bridge. Given the unique circumstance of the bridge and the incumbent contractor’s proprietary capabilities, market research was deemed impractical. However, the comprehensive analysis and competition during the initial BPA phase ensured that the incumbent contractor meets the VA’s stringent performance and cost criteria.

(7) Any Other Facts Supporting the Justification: The bridge is essential to avoid interruptions in critical urinalysis CPRR services, directly impacting the agency’s ability to fulfill its healthcare mission.

Procedures for obtaining a new acquisition were delayed due to competing end-of-year responsibilities within the VA procurement office, necessitating the need for this bridge.

Additionally, the modification of the expiring BPA’s period of performance due to equipment installation and validation delays underscores the necessity of extending the current arrangement to ensure services are not disrupted. This extension ensures that there is no gap in service while a new long-term BPA is competitively procured and awarded.

(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: To mitigate the need for future bridge awards and ensure timely acquisition processes, the agency will review and optimize its procurement planning and coordination efforts. This will include improving its

VHAPG Part 808.405-6 Limiting Sources Page 4 of 4

Acquisition ID#: 36C252-25-AP-3087 forecasting and scheduling capabilities to avoid conflicts with end-of-year responsibilities and other administrative delays.

As part of continuous improvement, the agency will conduct a thorough evaluation of the current procurement cycle and implement strategic steps to streamline acquisition approvals and avoid similar delays. Additionally, increased engagement with market research and early industry consultations will help identify potential competitive sources well ahead of future contract expirations.

(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.

Courtney Feldmann Business Manager Pathology and Laboratory Medicine

VISN 12

(10) Approvals in accordance with the VHAPM Part 806.3 OFOC SOP:

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

Stacy Massey Contracting Officer Network Contracting Office 12

b. One Level Above the Contracting Officer (Required over the SAT but not exceeding $750K): I certify the justification meets requirements for other than full and open competition.

Parris Weidenbach Branch Chief, Supply Team Network Contracting Office 12

COURTNEY

FELDMANN

Digitally signed by COURTNEY

FELDMANN

Date: 2025.06.11 14:25:35 -05'00'

STACY MASSEY

Digitally signed by STACY

MASSEY

Date: 2025.06.11 15:57:37 -05'00'

PARRIS

WEIDENBACH

Digitally signed by PARRIS

WEIDENBACH

Date: 2025.06.12 09:36:07 -05'00'