P03 - FAR 13.5 SSJ - Over SAT - Teleradiology Services - NMVAHCS - Extension Signed.pdf

VHAPG Part 813.5 Simplified Acquisition Procedures for Certain Commercial Items

Request for Sole Source Justification >SAT-$7.5M under FAR13.5

Effective Date: 11/15/24 Page 1 of 5

REVISION: 01

Acquisition ID#: TBD

DEPARTMENT OF VETERANS AFFAIRS

SOLE SOURCE JUSTIFICATION UNDER SIMPLIFIED PROCEDURES FOR

CERTAIN COMMERCIAL ITEMS IN ACCORDANCE WITH FAR 13.5

Acquisition Plan Action ID: TBD

1. Contracting Activity: Department of Veterans Affairs, VISN 22, New Mexico VA Health Care

System (NMVAHCS), by the Network Contracting Office (NCO) 22; 2237: TBD.

2. Nature and/or Description of the Action Being Processed: The NMVAHCS, Radiology

Department, is requesting for to extend current contract for teleradiology services. NMVAHCS requests for a contractor to provide board certified Radiologists to perform teleradiology interpretation services. Currently, contract: 36C26225D0027 is set to end on May 31, 2025, while the long-term contract is currently being procured and estimated to be awarded by December 1, 2025.

Therefore, an extension to current contract is required to prevent lapse in services. Failure to secure this extension would significantly disrupt VA patient care by creating delays in critical diagnostic services. This is a sole source Fixed Price (FP), Indefinite Delivery, Indefinite Quantity (IDIQ) contract awarded previously for six (6) months. The extension needed will be for six (6) months.

3. Description of Supplies/Services Required to Meet the Agency’s Needs: The contractor shall furnish board certified Radiology Physician services in accordance with the specifications contained in the

Performance Work Statement (PWS) to the beneficiaries of the Department of Veterans Affairs (VA) and the NMVAHCS. The contract physician(s) shall be responsible for providing, including, but not limited to; General Radiologic Procedures (Plain Film, X-ray), Computed Tomography

Scans/Computerized Axial Tomography (CT/CTA Scan), Magnetic Resonance Imaging/Magnetic

Resonance Imaging (MRI/MRA), Nuclear Medicine (NM) and Ultrasound (US) including Vascular

Ultrasound (Doppler/Duplex) Exams. The VA Radiology Department follows the standards and guidelines set forth by American College of Radiology (ACR). Therefore, the contractor providing teleradiology services shall provide services consistent with The Joint Commission (TJC) and that meet or exceed VA and the ACR guidelines. Contract physician(s) shall be available Monday through

Friday from 16:00 PM to 07:00 AM, Saturday and Sunday from 0000 - 2400 and all Federal Holidays from 0000-2400. Services shall be provided off-site at the contractor’s location. The contactor’s physicians are expected to interpret an estimated 9,154 radiologic exams starting June 1, 2025 through November 30, 2025. The estimated value of this six (6) month requirement is $545,109.25.

4. Statutory Authority Permitting Restricted Competition:

FAR 13.5 Simplified Procedures for Certain Commercial Items. The statutory authority for applying the Simplified Procedures for Commercial Items of FAR 13.5 is 41 U.S.C. § 1901 and is implemented by FAR 13.106-1(b)(2) for restricting competition on this procurement. Competition is restricted on this procurement for the reason below:

(X) Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency

Requirements

( ) Unusual and Compelling Urgency

( ) Industrial Mobilization, Engineering, Developmental or Research Capability or Expert

Services

Effective Date: 11/15/24 Page 2 of 5

Acquisition ID#: TBD

( ) International Agreement

( ) Authorized or Required by Statute

( ) National Security

( ) Public Interest

5. Demonstration that the Contractor’s Unique Qualifications or Nature of the Acquisition

Requires the Use of the Authority Cited Above (applicability of authority): VetMed Group, a

Service-Disabled Veteran-Owned Small Business (SDVOSB), has an extensive experience in providing teleradiology services. VetMed Group has a comprehensive history of providing teleradiology services to several VA facilities across the country, including VISN 9, VA Atlanta, VA

Denver, and more. This extensive experience with VA-specific requirements and workflows makes them uniquely qualified to handle the intricacies of VA contracts, particularly when compared to other vendors with limited VA experience. VetMed Group processes approximately 1,200 studies per day, with half being emergency cases. Their expertise in managing high-demand and high-volume of teleradiology services, including demonstrated success in delivering critical services within required timeframes, makes them highly reliable in handling demanding needs. VetMed Group uses a robust technology stack that includes IntelePACS, Mirth, and Fluency for Imaging, which is fully compliant with VA data protection standards. VetMed Group also has a VA-approved National IT

Memorandum of Understanding (MOU) in place, further ensuring that their technology and security measures align with federal standards. This is critical in maintaining the integrity and security of patient data, especially in a highly sensitive environment like VA healthcare. The company guarantees 100% uptime with real-time monitoring and immediate response to disruptions. Their relationship with the National IT Control Desk ensures any technical issues are resolved promptly, minimizing downtime during high-demands and high-volume of teleradiology services. VetMed

Group has around 35 radiologists, many of whom are already credentialed with other VA sites, allowing for a streamlined credentialing process. Their radiologists are highly specialized in areas such as neuro, breast, and thoracic imaging, and their familiarity with VA hospitals further supports their qualifications. Most of contractor’s radiologists anticipated to perform teleradiology services for

NMVAHCS will already be credentialed with other VA Medical Center (VAMC). Therefore, credentialing will be efficient. The company is accredited by The Joint Commission since 2020 and has maintained strict adherence to HIPAA and VA-specific regulations. Their strong compliance record and internal peer review processes meet or exceed ACR guidelines, which further ensures quality and accountability in their service delivery. Based on their capabilities and experiences providing same services, their established technology and infrastructure, and current credentialed radiologist with other VAMC, VetMed Group is the only one responsible source that can meet this extension requirement.

6. Description of Efforts Made to ensure that offers are solicited from as many potential sources as deemed practicable: Market research was previously conducted in accordance with FAR Part 10.

It identified two (2) verified SDVOSB vendors are interested and can provide teleradiology services

VetMed Group and Rockjoi Medical Imaging. Furthermore, market research inquired between the two interested SDVOSB entities were requested to provide additional information. The request was in a questionnaire form regarding each company’s capability to provide teleradiology services. The questionnaire including, but not limited to; experience and expertise, technology and infrastructure, staffing and credentials, turnaround time and performance, compliance and accreditation, capacity and scalability, customization and adaptability, and lastly, references and past performance.

The results of the previous market research indicates that VetMed Group has the experience providing teleradiology services and is currently providing the same services with six (6) awarded

VA contracts. Of the six (6) awarded VA contracts, four (4) were alone awarded in 2024. In comparison, Rockjoi Medical Imaging subcontracted for teleradiology services to support 13

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Acquisition ID#: TBD

VAMCs through VetMed Group and the contract was awarded in 2017. Since then, Rockjoi Medical

Imaging has not had any VA awarded contracts for similar services. Currently, VetMed Group has the necessary technology and infrastructure that is compliant and can meet the VA’s data protection and this requirement, while Rockjoi Medical Imaging does not currently have the technology and infrastructure that can meet this requirement. While both vendors have the staffing to meet this requirement, VetMed Group already has staff that are VA credentialed and privileged, while Rockjoi

Medical Imaging’s last VA contract was awarded 2017, therefore, credentialing will be efficient when awarding to VetMed Group. Both vendor’s turnaround time and performance are within the needs of

NMVAHCS, however, VetMed Group average STAT is about 30 minutes less than Rockjoi Medical

Imaging. This will benefit the Radiology Department providing faster services in reading the exams, which ultimately help alleviate the number of exams required for this acquisition. Additionally, VetMed Group can manage high-demand periods and large volumes of cases by maintaining on-call

Radiologists to help decompress worklist. Rockjoi Medical Imaging will provide additional radiologists if needed after the additional Radiologists clear credential and privilege processing.

Lastly, VetMed Group can meet cost and pricing structure of this requirement. They will price by modality to keep invoicing and tracking efficient. VetMed Group do not have any additional cost as they are a per-study model company and therefore, if the VA does not use them, there are no charge.

However, Rockjoi Medical Imaging pricing is based on Medicaid/Medicare reimbursement for the modalities and wants to charge an additional $7,500 for the cost of Health Level Seven (HL7). The

HL7, is a range of global standards for the transfer of clinical and administrative health data between applications with the aim to improve patient outcomes and health system performance. However, VetMed Group uses IntelePACS by Intelerad, Mirth router for HL7 interfacing.

New market research was conducted for the option to extend the current contract. Commercially, three vendors (National Diagnostic Imaging, OnRad Inc, and Experity) are not able to meet this requirement. Collectively these vendors are not able to provide pricing for the required modalities, not able to provide services within the hours needed, and/or not participating in any government contract. Additionally, the three commercial vendors are not able to provide some of teleradiology services for complexed radiologic interpretations of CTs, MRIs/MRAs, Nuclear Medicine and/or

Ultrasounds. GSA/FSS cannot meet this requirement. Based on a review of the available Special Item

Number (SINs) under the GSA/FSS when searching in www.gsalibrary.gsa.gov, shows that while several SINs, such as 621-035 (Diagnostic Radiology Services), appear related to teleradiology and radiology interpretation services, the awarded contracts primarily focus on radiologist staffing services or the provision of equipment and supplies. Specifically, market research revealed that the majority of awarded contracts under these SINs offer radiology staffing support – i.e., placement of radiologists to perform services either on-site or remotely on an hourly basis – rather than providing per-procedure diagnostic interpretation services (e.g., pricing per X-ray, CT, MRI, Nuclear Medicine or Ultrasound interpretation). Additionally, many awards under these categories pertain to imaging equipment, software, and ancillary supplies rather than procedure,-based teleradiology service pricing. As a result, GSA/FSS failed to provide market data directly related to the procedural (per-study) interpretation pricing necessary to support this requirement. According to SAM.gov, in the last

12 months, there have been four (4) awarded contracts to the VA. Three (3) were awarded to VetMed

Group, and one (1) awarded to Valor Network, Inc. Valor Network, Inc. is not interested in providing teleradiology services for NMVAHCS. The National Teleradiology Program (NTP) is unable to take in any contracts as they are overwhelmed with the demands for radiologic interpretations with other

VAMCs.

Based on the previous and current market research, it is clear that VetMed Group continues to show capability in experience and can provide staff who are already have been credentialed/privileged in

NMVAHCS. They have the technology and infrastructure, and personnel that can meet the high-

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Acquisition ID#: TBD demands and large volume of cases for this requirement. This makes them the ideal vendor that suites the needs for this contract extension to start June 1, 2025.

7. Determination by the CO that the Anticipated Cost to the Government will be Fair and

Reasonable: It is anticipated that the cost will be considered fair and reasonable by comparing current VetMed Group’s pricing to other VA awarded vendor’s pricing, and to other company providing teleradiology services. The current contract prices are based on modality rates. Therefore, price comparison will be based on modality pricing rather than Current Procedural Terminology

(CPT) pricing. VetMed Group has waived a 2.0% inflation increase; therefore, the price remains the same as it was determined fair and reasonable at the time of awarding the contract on 12/1/2024.

8. Description of the Market Research Conducted and the Results, or a Statement of the Reasons

Market Research Was Not Conducted: As described in Section 6 above, market research, in accordance with FAR Part 10, was conducted twice. This is an extension requirement, therefore, for the long-term contract, a synopsis of the teleradiology services, advising industry of the pending acquisition and soliciting inquiries from interested parties.

This acquisition does not apply to Buy American Act (BAA) and Trade Agreements Act (TAA) because NMVAHCS is not requesting for products or materials subject to BAA or TAA requirements. This acquisition is for acquiring qualified Radiologists providing teleradiology services.

9. Any Other Facts Supporting the Use of Other than Full and Open Competition: NMVAHCS is back logged regarding credentialing and privileging. The process can take up to 12 weeks. VetMed

Group current Radiologists are already credentialed and privileged in NMVAHCS. The current contract ends on May 31, 2025, therefore, it’s imperative to have this extension in place to prevent delaying in interpreting radiologic examinations for VA patients. Additionally, VetMed Group is uniquely qualified due to their proven capacity to manage both routine and emergency high-volume teleradiology cases, their specialized technology infrastructure that ensures compliance with VA standards, and their extensive experience in working with VA facilities nationwide. This combination of factors makes VetMed Group particularly suited to prevent service disruptions while ensuring a high standard of patient care.

10. Listing of Sources that Expressed, in Writing, an Interest in the Acquisition: VetMed Group Inc.

has expressed and in writing that they will continue to provide teleradiology services for NMVAHCS.

They understand that this is a six (6) month extension to the current contract requiring them to provide coverage when the current contract expires on May 31, 2025. VetMed Group is also interested in the long-term contract which is anticipated to start December 1, 2025.

11. A Statement of the Actions, if any, the Agency May Take to Remove or Overcome any Barriers to Competition before Making subsequent acquisitions for the supplies or services required:

Traditional radiology practices are going out of business. Radiologists are burnt out and demand for imaging keeps increasing. This is a very tough and often a thankless business to keep studies read timely and especially for after-hours reads. This is a very brutal business to be in now fraught with risk. According to PracticeLink.com, Radiology has moved up 3 spots in terms of Most Challenging to Recruit Specialties; and it is the 2nd most in demand Specialty with 0.16 candidates available per job. Both data points indicate a worsening trend in radiology - too many hospitals and groups chasing too few radiologists therefore driving the cost of teleradiology higher.

The agency will expand efforts to identify and engage more potential vendors capable of meeting the

VA’s unique teleradiology needs. This could include outreach through industry forums, VA vendor

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Acquisition ID#: TBD databases, and broader publication of upcoming contract opportunities to attract a large pool of qualified vendors.

12. 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 and belief.

Signature: ______________________

Paul Schmidt

Planner/Program Manager, Chief of Imaging

Radiology Department, NMVAHCS

13. Approvals in accordance with the VHAPM Part 806.3 OFOC SOP:

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

Signature: _____________________________

Danielle Trudeau

Contracting Officer

Network Contracting Office - 22

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

Signature: _____________________________

Jarrod Washington

Contracting Officer, Division Chief

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