NIH_ODSS_STS_LSJ_-_SAM_Redacted_1.pdf

LIMITED-SOURCES JUSTIFICATION

AUTHORITY: FAR 8.405-6, 40 U.S.C 501

Solicitation 140D0426Q0132 Scientific and Technical Support (STS)

This acquisition is conducted under the authority of the Multiple Award Schedule Program.

1. Identification of the agency and the contracting activity, and specific identification of the document as a “Limited-Sources Justification.”

This document is a Limited Sources Justification for the Department of the Interior (DOI), Interior Business Center (IBC), Acquisition Services Directorate (AQD), Division II Branch II on behalf of the Department of Health and Human Services (HHS), National Institutes of Health (NIH), Office of Data Science Strategy (ODSS).

2. Nature and/or description of the action being approved.

This proposed action is a limited sources logical follow-on award based on an NIH awarded single-award Blanket Purchase Agreement (BPA) 75N98024A00074 and subsequent BPA Calls.

The original BPA was competed via General Services Administration (GSA) Multiple Award Schedule (MAS) as a full-and-open competition and award was made to Covalent Solutions, LLC against their GSA MAS Contract No. 47QTCA23D008J.

3. A description of the supplies or services required to meet the agency’s needs (including the estimated value).

The purpose of this Task Order is to provide scientific and technical support for the ODSS and ODSS Chief Artificial Intelligence Officer (ODSS/CAIO) mission to catalyze new capabilities in biomedical research and development (R&D) by providing trans-NIH leadership and coordination on a broad range of NIH-wide data science and Artificial Intelligence (AI) activities.

This logical follow-on award is being requested to avoid a significant interruption in service while AQD competes a new Task Order for these services on behalf of ODSS.

4. The authority and supporting rational (see 8.405-6(a)(1)(i) and (b)(1)) 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)(i)(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 or BPA must not have been previously issued under sole-source or limited-sources procedures.

Covalent Solutions, LLC has been providing mission critical services to NIH ODSS since February 14, 2024. Due to circumstances outside of ODSS’ control, the Government was not able to exercise the most recent option period prior to the expiration of the period of performance. Due to the anticipated lead time for a new competitive acquisition of this nature, and in order to avoid a long term break in mission-critical services, the Government is awarding a short-term logical follow-on Task Order until a new competitive contract vehicle can be awarded.

Covalent is uniquely qualified to provide these highly specialized biomedical data science services given their successful history supplying these services to ODSS. Continued support is vital to sustaining NIH-wide data operations, transparency, and modernization in biomedical research; specifically for implementation of the NIH Strategic Plan for Data Science and ODSS support for key federal mandates under the 21st Century Cures Act and Public Health Service Act, NIH compliance with Executive Orders (e.g., 14212 and 14028), Office of Management and Budget (OMB) policy (e.g., M-13-13, M-21-31, Circular A-130) and legislative directives (e.g., PL 114-255, PL 115-435, PL 118-47). The contractor is responsible for providing the following statutorily and operationally critical functions via this Task Order:

Maintain compliance with the Antideficiency Act and execute complex NIH disbursement processes, including direct Common Accounting Number (CAN) citations requiring specialized training and negotiation with Institutes, Centers, and Offices (ICO) grants management staff. Loss of this support would disrupt ODSS/OCAIO funding operations, including congressionally mandated expenditures and enterprise-wide co-funding for data science initiatives across NIH Institutes and Centers.

Support mandated activities under Executive Orders 14212 and 14179, including management of the Other Transaction Agreement for the Generalist Repository Ecosystem Initiative (GREI)—a named component of NIH's Strategic Plan for Data Science—and administration of NIH's Artificial Intelligence (AI) Use Case Inventory with 200+ cases as required by OMB M-25-21. Coordinate seven Other Transaction awardees developing collaborative approaches for data management and sharing of NIH-funded data lacking dedicated repositories, overseeing technical deliverables and the development of cohesive capabilities, services, and metrics across generalist repositories to lower barriers to data sharing and reuse. The contractor is also responsible for administering NIH's AI Use Case Inventory with 200+ cases as required by OMB M-25- 21.

Provide essential landscape analysis, stakeholder mapping, and program development to advance open data initiatives (Science and Technology Research Infrastructure for

Discovery, Experimentation, and Sustainability (STRIDES), Generalist Repository Ecosystem Initiative (GREI)) and support the coordination of NIH-wide AI activities in compliance with the Further Consolidated Appropriations Act, 2024. The contractor is responsible for managing complex, multi-stakeholder programs including the Data Management Center of Excellence contract award (educating researchers on Findability, Accessibility, Interoperability, and Reusability (FAIR) principles for data findability, accessibility, interoperability, and reusability) and the NIH-wide data repositories and knowledgebases program comprising 40 extramural awards across 17 Institutes and Centers. The contractor’s interdisciplinary expertise in life sciences, biomedical informatics, public health, and data analytics is essential for administering flagship modernization efforts, organizing Principal Investigator (PI) meetings to foster technical and social collaborations, and supporting sustainable software initiatives critical to implementing the NIH Data Management and Sharing Policy.

Serve as the dedicated point of contact for AI and data science training across NIH, managing the NIH Coursera Learning Program and the Azure cloud infrastructure used by ODSS in compliance with NIH cybersecurity guidelines. The contractor provides technical implementation expertise (Python, SQL, Logic Apps, Azure Automation runbooks) to develop monitoring dashboards and streamline application processing, while facilitating workshops on data-sharing protocols and interoperability standards. The contractor analyzes learner engagement and skills development to align workforce competencies with evolving NIH priorities, directly supporting Executive Order 14277's workforce development mandate and the Strategic Plan's goal to strengthen data science competencies at all career levels.

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

Covalent’s GSA Schedule rates were previously determined to be fair and reasonable at the time of contract award by GSA. Even though FAR 8.404(d) indicates that the rates for services offered at hourly rates under schedule contracts are fair and reasonable, additional discounts will be requested. As a result, it has been determined by the Contracting Officer that the follow-on award will represent the best value to the Government considering price, administrative costs, and the potential costs associated with a gap in services.

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.

Market research indicated that Covalent’s GSA MAS Contract is current until May 15, 2028.

Additional market research on other GSA MAS vendors was not conducted as this is a logical follow-on to a previously competed GSA MAS Task Order.

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 of supplies and services is made.

AQD is currently in the process of competing a new contract vehicle which will include these services. The anticipated award date for the new competitive vehicle is no later than quarter 2 of fiscal year 2027 (FY27). This limited sources Task Order will only be utilized until the support can be transitioned to the new contract vehicle.