P03 Call Center Services JA FAR Part 6 FE_Redacted.pdf

Justification and Approval (J&A) on behalf of the Department of Veterans Affairs (VA), Veterans

Experience Office (VEO)

6. Commission publishes PL addition;

notice issued to Contracting Officer, NPA, and CNA; contract award authorized after effective date AbilityOne Total Estimated PALT 150 Days

Once Step 6 of AbilityOne’s PALT is completed at approximately 150 Days or 5-months, the Contracting Officer may begin moving forward with the acquisition which shall consist of the following PALT:

Procurement Objectives PALT

1. Prepare pre-solicitation documents for review.

2. Submit pre-solicitation documents for compliance review.

3. Rectify compliance review comments

4. Submit pre-solicitation documents for legal review.

5. Rectify legal review comments.

6. Issue Solicitation.

7. Evaluate Proposal.

8. Negotiate Pricing.

9. Make award decision.

10. Prepare pre-award documentation.

11. Repeat Step 2-5 with pre-award documentation.

12. Award Contract

Steps 1-12 Collectively 120 days

Contracting Estimated PALT 120 Days Total PALT (AbilityOne and Contracting) 270 Days (9-months)

Once awarded, the transition process can begin which consists of the following:

Transition Objectives PALT

1. Onboarding Staff (required before step 2) 21 Days to award

2. Nesting Period 1 (senior staff shadow Government Full Time Employees)

35 days to award

3. New Hire Virtual Training (Call Agents) 35 days to award

4. Nesting Period 2 (agents) 49 days to award

5. All Staff Prepared for Production 63 days to award Transition PALT 63 days Total PALT (AbilityOne, Contracting, Transition) 333 days (11-months)

The onboarding and training timeline for the new contract is detailed below. With this timeline, all onboarding activities, managerial and supervisor training, virtual classroom new hire training, and nesting is expected to be completed for supervisors, senior agents, and frontline agents by close of business on Day 63 of contract award. Production will start on the next calendar day.

Onboarding The onboarding process for new staff takes approximately 21 calendar days. This process involves steps required for security clearance, submissions of forms, issuance of PIV cards, and issuance of Government furnished equipment. All of these steps are necessary for a new staff member to be granted access and to start training.

Training The training for staff is conducted sequentially since key staff are required to be onboarded and trained first to assist with the onboarding and nesting (double jacking) of frontline agents. The Program Manager (PM), Deputy Program Manager (DPM), and PMAAs are required to be onboarded and ready for training within 10 business days of contract award. Of this group, only the PM is Key Personnel, but the DPM and PMAAs also play critical roles in the onboarding process of all other staff. Since onboarding requires an average of 21 days, the contractor may need to ensure these positions (PM, DPM, & PMAAs) are recruited and hired prior to the contract award, so that they are onboarded and prepared for training by 10 business days (14 calendar days) of contract award. Additionally, since the initial two-week virtual classroom training would start 21 days post contract award, the other key personnel (Supervisors and Senior Agents) would need to be onboarded by that date.

Timeline (in calendar days) from contract award to productions for Managers, Supervisors, Senior Agents, and Agents (Contact Representatives):

14 days post contract award: Start one-week managerial training of PM, DPM, and

PMAAs (performance standards, QASP, monthly reporting requirements, workforce management, quality standard, and orientation to the Operations team).

21 days post contract award: Start two-week new hire virtual classroom training for PM, DPM, Supervisors, and Senior Agents. This training includes VA overview, information about VA benefits and services managed by the Veterans Benefits Administration (VBA), Veterans Health Administration (VHA), and National Cemetery Administration (NCA), other contact center resources, VA.gov technical support, service recovery, and documentation.

35 days post contract award: Start two-week double jacking of PM, DPM, Supervisors, and Senior Agents with their Government Full Time Employee (FTE) counterparts to shadow and experience the respective positions.

35 days post contract award: Start two-week new hire virtual classroom training for cohort of Contact Representatives (frontline Agents).

49 days post contract award: Start two-week double jacking of Contact Representatives (Agents) with contract Supervisors and Senior Agents. The contract Supervisors and Senior Agents will complete and certify Agent competencies based on a checklist provided by the Government to ensure they are prepared for production.

63 days post contract award: Supervisors, Senior Agents, and Agents complete double jacking and are ready for production, provided they successfully complete required competencies, have all required equipment and access, and are scheduled for duty.

If there were to be a lapse in services, there would be significant impact to Veterans, beneficiaries, dependents, advocates, transitioning active-duty service members, as well as those who have experienced military sexual assault. This contact center serves as the front door to Veterans accessing VA’s benefits and services, functions as the general information and directory assistance line, and is responsible for intake of Veteran concerns, reports of sexual assaults and sexual harassment, handling of threats and suicidal risks, among others. In addition, the contact center provides navigational assistance, login assistance, and technical support to callers accessing the VA.gov website which is a critical resource for Veterans. The contact center often supports additional initiatives such as email and text campaigns alerting Veterans to expansion of services or important submission deadlines. The impact of the contact center is demonstrated in part by call volume, which was 1.5 million in Fiscal Year 2024 across all business lines. The contact center handles calls from vulnerable populations including victims of fraud (by managing the White House fraud line), victims of identity theft, those experiencing suicidal ideations and sexual assault, and military sexual trauma.

Based on the above information, a contract cannot be established with AbilityOne or re-competed by the required award date of February 5, 2025, based on the timelines detailed above. Conducting a limited solicitation would require additional time to prepare solicitation materials, evaluate proposals, and make an award decision. Given the urgency of this requirement, these steps would delay the process and potentially impact mission-critical operations. A limited sources solicitation would require 120 days to complete and an additional 63 days to begin the transition before a new awardee could perform the required services under this contract. In total, this process would take 183 days, thereby causing a complete lapse in mission critical services. Even a limited solicitation involves a formal evaluation of proposals to ensure compliance and determine the best value. This process would extend the timeline and reduce the responsiveness of the procurement to meet the immediate need. As stated, onboarding and training are necessary for any new contractor. Adding more time for solicitation and evaluation would further compress the already limited timeline for ensuring the contractor can meet the operational requirements effectively.

(4) An Identification of the statutory authority permitting other than full and open competition.

The statutory authority permitting other than full and open competition is 41 U.S.C.

Section 3304(a)(2), as implemented by the Federal Acquisition Regulation (FAR) 6.302- 2, Unusual and Compelling Urgency, which permits contracting without providing for full and open competition in situations where 1) an unusual or compelling urgency precludes full and open competition, and 2) delay in award of a contract would result in serious injury, financial, or other, to the Government. The Agency’s need for continuation of services is of such that the Government would be seriously injured unless the Agency is permitted to limit the number of sources from which it solicits bids or proposals and where any delay in services under this contract will result in serious injury to the Government.

(5) A demonstration that the proposed contractor’s unique qualification or nature of the acquisition requires the use of the authority cited:

Bowen is uniquely positioned and able to carry out the current needs for the Veterans, while providing the competitive pricing, meeting of schedule demands, and continuous mission and operational capabilities the Agency requires. The primary reasons why the VEO contact center is so important: Veterans often face a wide range of issues, including healthcare, benefits, housing employment, and mental health challenges. The VEO contact center provides a single point of contact to navigate the complexities of multiple programs and agencies. Most importantly, Veterans in crisis or facing urgent needs (e.g., homelessness or mental health issues) require immediate assistance, and could result in the potential injury or loss of life should services lapse.

The VA VEO contact center is the primary mechanism through which Veterans and their families access critical support services, report issues, and receive guidance for navigating VA benefits and care systems. An interruption in these services would significantly impair the VA’s ability to fulfill its mission of providing timely assistance to Veterans. The urgency arises from a potential lapse in service should this bridge contract not be awarded.

The current contract supporting the VEO contact center expires February 5, 2025, and there is a continuing need for these mission critical services. The Government anticipated meeting the contracted support services requirement detailed herein, even issuing unrestricted solicitation 36C10X24R0048 to contract opportunities on May 24, 2024. The Government received a significant volume of outreach including over 400 questions from industry and interest from SDVOSB/VOSB vendors which ultimately led to the cancelation of the solicitation on June 25, 2024, for two reasons 1) better define the requirements within the Performance Work Statement (PWS) and 2) conduct additional market research into SDVOSB/VOSB capabilities.

Any delay in securing these services would lead to a degradation of support for Veterans, including:

1. Increased wait times for call responses, potentially causing distress for Veterans in crisis.

2. Inability to address urgent issues such as benefit delays, appeals, or medical referrals.

3. Erosion of trust in the VA’s ability to deliver on its promises to Veterans.

This level of service interruption directly contradicts the VA’s mandate to provide reliable and accessible support to veterans, particularly for those facing critical needs.

While the VA values the principles of competition, the time required to complete this process would result in an unacceptable gap in service. The VA has determined that the immediate award of a bridge contract is the only feasible solution to prevent a disruption of these vital services. The urgency is not the result of a lack of planning but rather due to unforeseen operational challenges driving immediate demand.

At the time of the cancellation and on the merits of the market research conducted; there was not two or more SDVOSB/VOSB capable of handling the call volume within the performance metrics required under this effort. Because award to an SDOVSB/VOSB was not feasible, this required the Government to work with AbilityOne as a mandatory source.

AbilityOne was contacted prior to the issuance of the solicitation, but determined they could not meet the award timeline of August 5, 2024, thereby giving their understanding of the Government’s need to procure this acquisition unrestricted. Because the solicitation was canceled on June 25, 2024, this left approximately one (1) month to award a contract to prevent a lapse in services, therefore, the Government exercised a six (6) month option to extend services to February 5, 2025. Given the new timeline provided via the six (6) month extension, the Government began working with AbilityOne again on August 17, 2024. AbilityOne believed the new timeline was sufficient to get to an award and promised a completed Impact Determination Statement by September 30, 2024, which is used by the AbilityOne committee to determine the risk this requirement would have on a business and if AbilityOne would ultimately add this requirement to their procurement list. The Impact Determination Statement was not provided by September 30, 2024, as promised;

however, the Government granted an extension of the due date to November 1, 2024.

Again, AbilityOne did not provide the Impact Determination Statement. On November 6, 2024, a meeting was conducted with AbilityOne to analyze the timeline and discuss feasible solutions to ensure continuity of services. During the meeting, the decision was made to move on from AbilityOne again, after it was clear an award and transition would remain unfeasible.

Due to the time to implement a new contract and the need to not have delays in critical services being provided to Veterans, there are several reasons justifying the use of unusual and compelling urgency. Bowen, the incumbent contractor, has been providing uninterrupted contact center staffing to the VA since August 5, 2019. These services are required to protect the health and safety of our Veterans. Any delay could result in unacceptable risks, including injury, illness, or loss of life, if Veterans were not able to access the VEO contact center. The VEO contact center is crucial for Veterans because it serves as a central hub for addressing their needs, improving access to services, and ensuring they receive timely and appropriate support.

If this 12-month bridge contract for the VEO contact center were not awarded, several significant harms could occur, affecting both the Government and the Veteran community it serves. These include:

1. Reduced Access to Critical Services for Veterans

Delays in Assistance: Veterans and their families may face significant delays in accessing information, support, and services, potentially impacting their health, well-being, and financial stability. Some specific services that would be disrupted include:

healthcare appointments, connecting Veterans in crisis to the Veterans Crisis Line, appropriate mental health services, homelessness and suicide prevention resources, timely support in life-threatening or emergency situations, and supporting Veterans in navigating the claims process for disability compensation, pensions, or other benefits.

Increased Frustration: Without a dedicated contact center, Veterans may struggle to navigate Government systems, leading to dissatisfaction and erosion of trust in the

VA.

A lapse in service means that up to 1.5 million (the number of calls received on the current contract) and more Veterans would be unable to timely obtain needed medical appointments, and millions of Veterans would become at risk for meeting application for benefits deadlines, etc.

2. Decreased Government Efficiency

Overburdened Systems: Other VA offices or contact centers may be forced to absorb the workload, leading to longer wait times and reduced service quality across multiple programs.

Operational Disruption: Without a structured contract, there may be no streamlined processes, standardized training, or efficient staffing to handle the volume of inquiries.

3. Negative Public Perception and Loss of Trust

Reputational Damage: Failure to maintain a functional support system for Veterans could lead to widespread criticism of the Government’s commitment to Veterans' welfare.

Loss of Confidence: Veterans and their families may perceive the Government as failing to honor its promises, undermining public trust in its ability to deliver essential services.

4. Missed Opportunities for Data and Feedback

Lack of Insights: The VEO contact center provides valuable data on Veterans’ concerns and needs. Without this resource, the Government could miss critical feedback necessary to improve its services and policies.

Reduced Innovation: Delays in awarding the contract might hinder the implementation of new technologies or initiatives aimed at enhancing the Veteran experience.

5. Impact on Crisis Management

Increased Risk for Veterans in Crisis: Veterans experiencing mental health crises or other urgent issues may face barriers in accessing timely support, potentially leading to severe consequences, including harm or loss of life.

By not awarding the contract, the Government risks compromising its ability to provide reliable, high-quality service to Veterans, jeopardizing its mission to care for those who have served the nation.

The potential consequences of a disruption in services are significant and would directly impact the well-being and safety of Veterans, their families, caregivers, and survivors.

Veterans rely on the contact center for assistance with scheduling medical appointments, accessing referrals, and navigating the VA healthcare system. Without this support, veterans may experience delays in receiving critical medical care, including treatments for chronic conditions, mental health services, or urgent care. Gaps in care coordination could lead to worsening health conditions and, in some cases, life-threatening consequences.

Veterans seeking help with claims for disability compensation, pensions, or other benefits would face significant delays without the contact center's guidance. Unprocessed or delayed claims could result in financial strain, especially for Veterans who depend on these benefits for basic needs like housing, food, or medical expenses. Disruptions could also hinder the resolution of overpayments, appeals, or fraud-related issues, exacerbating financial stress. The contact center often serves as a critical link between Veterans in crisis and life-saving resources such as the Veterans Crisis Line or mental health services. Without this safety net, at-risk Veterans may have fewer options for immediate support, leading to an increased likelihood of suicide or self-harm. The inability to address mental health crises promptly would directly undermine suicide prevention efforts and the VA’s mission to protect Veterans’ lives. Also, Veterans facing housing insecurity rely on the contact center for connections to resources like VA housing programs and community support. A disruption in these services could lead to a rise in homelessness among Veterans, compounding social and economic challenges.

The contact center supports Veterans in understanding and benefiting from new programs or legislative changes. Disruptions could result in Veterans missing out on time-sensitive benefits or opportunities, violating the VA’s legal and ethical obligations to ensure equitable access. The contact center collects vital data through surveys and feedback to improve VA services and adapt to evolving needs. A halt in these activities would hinder the VA’s ability to identify systemic issues, address gaps, and make data-driven decisions.

Without the contact center acting as a centralized point of contact, other VA offices and facilities would face an increased volume of direct inquiries, overwhelming their capacity.

This could further delay services and create bottlenecks across the VA system. In the event of a national emergency or disaster, the VEO contact center is a vital resource for providing timely information and assistance to Veterans affected by the crisis. A disruption would compromise the VA’s ability to respond effectively, leaving Veterans without critical support during emergencies.

The contact center connects Veterans to life-saving services like the Veterans Crisis Line, housing assistance, or healthcare appointments. Many Veterans struggle with navigating bureaucracy or understanding eligibility requirements for various benefits. The VEO contact center simplifies the process, ensuring Veterans can access information without frustration. In urgent situations, such as natural disasters or personal crises, the contact center provides immediate assistance and referrals. It ensures Veterans receive critical help during emergencies, reducing harm and stabilizing their situations. By providing consistent, reliable, and high-quality service, the VEO contact center builds trust between Veterans and the VA. The VEO contact center is more than a helpline-it’s a lifeline. In summary, the bridge is essential to preventing any delay that could result in unacceptable risks, including injury, illness, or loss of life, if Veterans were not able to access the VEO contact center.

(6) A description of efforts made to ensure that offers are solicited from as many potential sources as is practicable, including whether a notice was or will be publicized as required by subpart 5.2 and, if not, which exception under 5.202 applies:

Market research was conducted, details of which are in the market research section of this document. This effort yielded a source that can meet the Government’s requirements but would require a minimum of five months just to be approved by the AbilityOne Committee.

In summary, there are no sources that can fulfill the Governments requirement by February 5, 2025. Due to the anticipated performance period being limited and the complexity of the requirement, meaningful competition is not anticipated. Additionally, the Government will publicly post this justification in accordance with 6.305(b): “The justification shall be posted within 30 days after contract award.” Although this justification will be made publicly available, the VA will not post a notice of proposed contract action required by FAR Subpart 5.201 to SAM.gov in accordance with the posting exception found at FAR Subpart 5.202(a)(2).

(7) A determination by the contracting officer that the anticipated cost to the

Government will be fair and reasonable:

The Contracting Officer has determined the anticipated cost to the Government for the services covered by this J&A will be fair and reasonable. The formal price analysis will be conducted in accordance with FAR Subpart 15.404-1, Proposal analysis techniques, and documented in the best value determination prior to award.

(8) A description of the market research conducted and the results or a statement of the reason market research was not conducted:

The market research conducted shows there is only one identified SDVOSB capable of providing the required services. In accordance with FAR 8.002 if an award is not made to a certified SDVOSB/VOSB listed in the SBA certification database, services are required to be procured from a mandatory source. Due to the Government not anticipating award to a SDVOSB/VOSB, contact was made with AbilityOne to procure the required services from them. It was ultimately determined that the strategies they proposed would not allow for continuity of services due to the needed ramp up and transition times. The VA is committed to doing business with AbilityOne but that must be balanced with mission needs.

Therefore, it is with the support of AbilityOne and the decision of the Contracting Officer, that the best acquisition strategy for this requirement is a bridge award to the incumbent, Bowen, for a period not to exceed 12-months to ensure continuity of services while the VA continues to work to re-compete and award this requirement by February 5, 2026. This is the only solution that provides adequate time to re-compete, transition, and award a new requirement. The urgency of this procurement is such that any additional time spent conducting limited competition (e.g., preparing solicitations, evaluating proposals, and onboarding multiple vendors) would directly conflict with the timeline required to meet critical needs.

(9) Any other facts supporting the use of other than full and open competition:

A shorter bridge contract would not allow sufficient time to conduct a competitive procurement or facilitate a phased transition without risking a disruption in services.

The lead time required for planning, soliciting, evaluating, and awarding a competitive contract typically exceeds the duration of a short-term bridge contract, especially for a service of this complexity and criticality. The VEO contact center provides mission-critical support that cannot tolerate interruptions. A shorter bridge increases the likelihood of delays or service gaps due to administrative challenges or unforeseen delays in procurement processes. Negotiating multiple short-term contracts could result in higher administrative and operational costs compared to a single, more stable procurement solution. Additionally, contractors may charge higher rates for short-term contracts due to the increased risk and reduced economies of scale. Contractors may face difficulties in maintaining stable staffing levels for a short bridge, as employees may seek more secure, longer-term opportunities elsewhere. This could degrade the quality of service during the critical bridge period.

Transitioning the VEO contact center to AbilityOne or re-competing the requirement before the expiration of the current contract involves significant logistical and operational challenges. A phased transition cannot be implemented within the available timeframe without risking service interruptions. The transition process typically requires months of coordination, including approval from the AbilityOne Commission and oversight to ensure compliance with federal regulations. The AbilityOne provider may not have immediate access to the specialized training, systems, and processes required for seamless contact

Experience Office (VEO)

Epiq Corporate Restructuring, LLC Exceed, LLC.

F.H. Cann & Associates, Inc.

Fairwater Associates, LLC

Fusion BPO General Dynamics Information Technology, Inc.

General Informatics, Inc. (GI) Glimpspire, LLC.

Goodwill Industries of San Antonio SK Support Servi es, LLC

Home Care Advantage, Inc.

Human Capital Resources and Concepts, Inc.

Roadrunner Express Consulting, LLC Innovation At Work, Inc.

IT Concepts, Inc.

KECH, Inc.

McCright & Associates, LLC.

Meticulous Hands Cleaning Services, LLC

Mighty Muscle Facilities Management Magellan Solutions USA Inc

Napollo Software Design, LLC National Industries for the Blind

National Telecommuting Institute, Inc.

Nebula Virtual Solutions, LLC

Nelnet Government Services, LLC North End

North South Consulting Group, LLC. (NSCG) Nuaxis, LLC

SupportU, LLC OptumServe Health Services, Inc

Palmetto GBA, LLC Pearl Interactive Network, LLC

Resolution-One Revelations Counseling and Consulting, LLC

RV Global Solutions, Inc.

Savilinx, LLC Serco, Inc.

Signature Performance, Inc.

Smart IT Pros, Inc.

SourceAmerica

SteerBridge Strategies, LLC Systems Integration, Inc.

The Bowen Consulting Group, LLC The Chicago Lighthouse for the Blind or Visually

Impaired Titan Facilities, Inc.

TMAX Government Solutions, LLC TTEC Government Solutions, LLC Veteran First Technologies, LLC

VetVantage, LLC DGG Technology Services, LLC

Vision Tech Group, LLC Mccray Group Ventures, LLC

PGBA, LLC

(11) A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition for the supplies or services required.

To remove or overcome barriers to competition in future acquisitions, the agency will continue working with the requiring activity to re-compete this requirement. A Request for Information (RFI) was published to Contract Opportunities and the General Services Administration (GSA) on December 12, 2024, to better understand small business capabilities and interest. If the Government is able to identify two or more capable SDVOSB/VOSB, a solicitation will be issued set-aside for SDVOSB/VOSB. If it is determined that award cannot be made to an SDVOSB/VOSB, the Government will begin the process outlined above to add this requirement to the Procurement List maintained by AbilityOne. This period of performance will not exceed the time necessary for the agency to enter into another contract for the required services.

By possibly transitioning to AbilityOne, expanding market research efforts, refining the PWS, and adopting a long-term acquisition strategy, the agency will ensure greater competition and compliance with procurement regulations in future acquisitions. These planned actions demonstrate the agency’s commitment to addressing barriers to competition.