P03 - Final JA Over SAT IAW 6.103-1 - Howard Med Carts BPA - REDACTED.pdf

Effective Date: 12/30/2025 Page 1 of 7 Revision: 02 Acquisition ID#: 36C776-26-AP-1686

DEPARTMENT OF VETERANS AFFAIRS

SOLE SOURCE JUSTIFICATION UNDER SIMPLIFIED ACQUISITION PROCEDURES FOR

COMMERCIAL PRODUCTS AND COMMERCIAL SERVICES IN ACCORDANCE WITH RFO PART 12

Acquisition Plan Action ID: 36C776-26-AP-1686

1. Contracting Activity: Department of Veterans Affairs (VA), Office of Acquisition, Logistics, and Construction (OALC), Regional Procurement Office – Central (RPO-C), Supplies & Services Division, 1639 Medical Center Pkwy, Murfreesboro, TN 371129.

Nature and/or Description of the Action Being Processed: This individual Justification and Approval (J&A) is to support a sole source procurement to Minburn Technology Group, LLC, a SBA Small Business certified SDVOSB vendor in accordance with Revolutionary FAR (RFO) 6.103-1 (Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements).

This procurement is for Howard Medical Carts and accessories in accordance with RFO 12.201-1 Simplified Acquisition Procedures, RFO 12.102 for restricting competition, and RFO Supbart 16.7 Agreements. This action will establish a new firm-fixed-price blanket purchase agreement (BPA) with a two-year ordering period to procure new and replacement equipment, set-up, and training as required by VA Medical centers within the Midwest Consortium (MidCon).

The Contracting Officer has determined that a Firm-Fixed Price (FFP) BPA is appropriate for this acquisition.

The estimated total value of the BPA is: $ ($ including the optional six (6) month extension in accordance with RFO 52.217-8 Option to Extend Services)

Year One (1): $ Year Two (2): $ RFO 52.212-8 (6-months): $

The duration of this requirement is for two (2) 12-month ordering periods with an optional six (6) month extension in accordance with RFO 52.217-8 Option to Extend Services:

Ordering Period One (1): October 1, 2026 – September 30, 2027 Ordering Period Two (2): October 1, 2027 – September 30, 2028 RFO 52.217-8 (6-months): October 1, 2028 – April 30, 2029

2. Description of Supplies/Services Required to Meet the Agency’s Needs: The mission of the Midwest Consortium (MidCon) is to enhance the health and well-being of Veterans through coordinated, high-quality care, and efficient resource management. Specifically, ensuring seamless integration of services across all facilities to improve patient outcomes and maintaining high standards of care, patient safety, and compliance with Veterans Health Administration (VHA) policies. To accomplish this mission and vision, MidCon is dedicated to procuring equipment that improves interoperability, efficiency, and standards of patient care region wide.

MidCon and associated VA Medical Centers (VAMCs) have a reoccurring need for the purchase of new and replacement Howard Medical Barcode Medication Administration (BCMA) carts, Howard Medical Workstation on Wheels (WOWs), and Howard Medical Transfer carts along with associated parts and accessories. This Howard Medical equipment is considered to be best-in-class by end-users. VA Medical Centers’ continuity of care requires continued standardization to the Howard Medical BCMA Carts. The Howard BCMA Carts are essential to continuity of care, clinical workflow, and usability by our clinical staff. It is necessary to

Effective Date: 12/30/2025 Page 2 of 7

Acquisition ID#: 36C776-26-AP-1686 standardize nursing carts for RN staff for effective daily use, familiarity, training, maintenance, and patient safety. According to the ScienceDirect article, “Clinican Congnitive Overload and Its Implications for Nurse Leaders,” by Rhonda Collins, DNP, RN, FAAN, studies have indicated cognitive overload is a cause of 80% of medical device errors.1 One way of reducing cognitive overload is standardizing medical equipment in a healthcare facility. Clinician familiarity with equipment, along with medical staff being fully trained on operating this equipment is an important consideration due to staff training costs, operational efficiency, and patient safety. Knowledge and familiarity with the Howard BCMA Carts significantly reduces damage to the equipment and associated repair costs by minimizing regular wear and tear due to the frequency of use.

Medication nursing carts comprise a small segment of the overall medication management system (e.g.

medication procurement, storage, dispensing, transportation, security, administration, and documentation).

Lack of training and unfamiliarity with the use and application of BCMA Carts, can lead to error and unauthorized workarounds that could result in serious injury or death to the patient.2 Patient safety cannot be jeopardized by using multiple brand BCMA carts.

The Contractor shall provide sixteen (16) different types of Howard medical HI-Care E carts, HI-Paradigm carts, and HI-Pinnacle carts in accordance with P02 – Attachment D2 – Howard Medical Carts LINs that offer a choice of various components, storage, accessories, warranties, and technology based on the ordering VA facility’s needs. The contactor shall include all equipment, accessories, materials, installation services, and training services specified in the Statement of Work (SOW). The types of carts required serve the following functions:

Howard Medical BCMA Carts:

A mobile cart that provides an efficient means of storing, organizing, and transporting medications and supplies to patients during the medication administration process including (but not limited to):

o Medications that have been delivered by the pharmacy to the unit.

o Medications pulled from the pharmacy dispensing system by nursing staff.

o Stored ward stock supplies (e.g. cups, syringes) transporting them to the patients.

o Work surface for preparing medication at the point of administration.

Point-of-care computing and technology-based medication administration recording system.

Printing bar-coded patient identification wristbands to scan for proper patient identification.

Howard Medical WOW carts: Serve as point-of-care computing and an efficient means of storing supplies.

Howard Medical Transfer carts: Serve the primary function of transferring medications and supples security in storage drawers matching the BCMA carts from the pharmacy and medication cabinets.

The Howard Medical Carts comply with the following required standards:

UL60601-1 – The United States adaption of the Underwriters Laboratories (UL) standard for Medical Electrical Equipment ensuring basic safety and essential performance for patient and operator protection.

IEC 60601-1 – The International Electrotechnical Commission (IEC) international standard for Medical Electrical Equipment ensuring basic safety and essential performance for patient and operator protection.

1 Collins, R (2020). “Clinician Cognitive Overload and Its Implications for Nurse Leaders.” ScienceDirect.

https://www.sciencedirect.com/science/article/pii/S1541461219303556 2 Van der Veen, et al. (2017). “Association Between Workarounds and Medication Administration Errors in Bar-Code- Assisted Medication Administration in Hospitals.” Journal of the American Meical Informatics Association. PMID:

29025037. https://pmc.ncbi.nlm.nih.gov/articles/PMC7646849/

Effective Date: 12/30/2025 Page 3 of 7

Acquisition ID#: 36C776-26-AP-1686

NFPA-99 – The National Fire Protection Association (NFPA) 99 Electrical Standards that mandates electrical safety, isolated power systems, hospital-grade receptacles, and essential electrical system design to protect patients, staff, and equipment in healthcare facilities.

The Contractor shall assemble the carts and validate they are in complete working order before deploying to the areas within each facility. The Contractor will also provide on-site training for selected VA staff.

After the delivery of carts and set up by the Contractor, VA Logistics will receive the new equipment, barcode for inclusion into their facility’s inventory management system, and then transfer PCs to OIT for imaging. OIT will image PCs with latest VA gold image within one (1) week of receipt, including all latest Windows updates;

the Barcode Administration Medication application, CPRS, and BioPoint Contingency software.

3. Statutory Authority Permitting Restricted Competition: RFO 12.201-1 Simplified Acquisition Procedures for Commercial Products and Commercial Services. The statutory authority for applying the Simplified Acquisition Procedures for Commercial Products and Commercial Services in RFO Part 12.201-1 is 41 U.S.C.

§ 1901 and is implemented by RFO 12.102 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 per 41 USC §3304(a)(1) as implemented by RFO 6.103-1;

( ) Unusual and Compelling Urgency per 41 USC §3304(a)(2) as implemented by RFO 6.103-2;

( ) Industrial Mobilization, Engineering, Developmental or Research Capability or Expert Services per 41 USC §3304(a)(3) as implemented by RFO 6.103-3;

( ) International Agreement per 41 USC §3304(a)(4) as implemented by RFO 6.103-4;

( ) Authorized or Required by Statute per 41 USC §3304(a)(5) as implemented by RFO

6.103-5;

( ) National Security per 41 USC §3304(a)(6) as implemented by RFO 6.103-6;

( ) Public Interest per 41 USC §3304(a)(7) as implemented by RFO 6.103-7;

4. Demonstration that the Contractor’s Unique Qualifications or Nature of the Acquisition Requires the Use of the Authority Cited Above (applicability of authority): The American made Howard Medical Carts and accessories are currently in use at 36 VA Medical Centers (VAMCs) within the the Department of Veterans Affairs (VA), Midwest Consortium (MidCon) and are an essential component of daily clinical operations. The purchase of Howard Medical carts is a clinician decision to standardize equipment in accordance with VHA Directive 1761 (Supply Change Management Operations) dated December 20, 2020 that addresses standardization of medical equipment across the VA. A total of 445 units require replacement to maintain continuity of care, ensure staff familiarity, and support safe and efficient nursing workflows. Standardizing on the current brand is required for several operational, clinical, and financial reasons:

Proprietary Configuration and Functionality The existing carts include proprietary setup, internal layout, and workflow-specific functionality that align directly with the needs of nursing and medication management. The brand’s design supports medication safety, optimized drawer configurations, and compatibility with existing clinical processes. Switching to an alternate brand would require process redesign, retraining, and adjustments to medication handling practices, increasing operational risk and cost. In a Healthcare Business Today article titled, “Why Standardized Medical Carts Improve Accuracy and Prevent Mistakes,” standardizing medical carts can significantly reduce medical errors; incuding medical dosage errors by up to 80%.3

3 “Why Standardized Medical Carts Improve Accuracy and Prevent Mistakes.” Healthcare Business Today. January 26, 2026. https://www.healthcarebusinesstoday.com/why-standardized-medical-carts-improve-accuracy-and-prevent-mistakes/

Effective Date: 12/30/2025 Page 4 of 7

Acquisition ID#: 36C776-26-AP-1686

Product-Specific Accessories and Interoperability

Current units rely on brand-specific accessories such as locking modules, power solutions, workflow add-ons, IT mounting hardware, and medication security components. These accessories are not interchangeable with other manufacturers. Maintaining the same brand is required to continue use of existing accessories and reduces the need for new accessory procurement, resulting in cost avoidance and standardization of replacement parts.

Safe Handling of Medications

The brand is already validated for safe medication storage and is use and trusted by VA clinical staff.

Features such as controlled-access locking, medication-security workflows, and standardized drawer inserts support compliance with VA medication-handling policies. Introducing a new platform will introduce variation that can lead to errors or inconsistencies in practice that can potentially harm veteran patients.

Mobility and Durability

The current carts are designed for high-use hospital environments and have demonstrated reliable mobility, stability, and durability across multiple facilities. Staff are familiar with their handling, reducing training needs and improving daily efficiency and reduce medication-handling errors or practices that can harm veteran patients.

Staff Training and Operational Continuity

Staff across all 18+ hospitals in MidCon are trained on the Howard medical carts’ operation, maintenance, and upkeep. Selecting a different manufacturer would require widespread training, additional downtime, and temporary reductions in productivity and would introduce the potential for errors that could harm veteran patients. Retaining the same brand minimizes disruption and preserves established competencies and provides for the safe use of the equipment.

Network Compatibility and Approved IT Integration

The existing carts are already approved for network connections, physical device mounting, and IT system integration. The Howard Medical carts software Clinical Assistant (One-VA TRM v23.3), Med Display (One-VA TRM v25.3), Med Manager (One-VA TRM v25.11), Power Manager (One-VA TRM v24.10), Power System Remote Monitoring (One-VA TRM v20.4) and PowerDisplay (One-VA TRM v25.2) are all VA technologies and standards that have been assessed and can be found in the VA Technical Reference Module v26.1. They are also fully compatible with current peripherals used for medication administration, barcode scanning, and electronic health record workflows. Switching brands would require new IT assessments, cybersecurity review, and potential modifications to existing hardware.

Finally, full FITARA approval was obtained April 28, 2026 through Acquisition Identifier 2026-VHA-VISN 23-200479.

Organizational Value Through Standardization

Enterprise standardization enhances safety, consistency, and operational predictability. Using one cart model enables uniform training programs, consistent medication workflows across facilities, smoother staff float/rotation, and reduced variability in patient care environments. These benefits directly support organizational goals for safety, quality, and efficiency.

Based on the demonstrated reliability, proprietary compatibility, existing training investments, and significant cost and operational efficiencies achieved through standardization, continued procurement of the current medical cart brand through Minburn Technology, LLC (Howard Industries sole authorized dealer for Howard medical carts) is essential for supporting safe patient care and operational effectiveness across the organization. Additionally, purchasing and fully replacing the current Howard Medical carts in use at VA medical centers would significantly increase the price and administrative burden on the Government. Award to another source would result in a substantial duplication of costs to the Government that is not expected to

Effective Date: 12/30/2025 Page 5 of 7

Acquisition ID#: 36C776-26-AP-1686 be recovered through competition. Market research was conducted for this requirement and the previous purchase orders awarded for the same supplies and services described in Section 2 above. This market research confirmed that Minburn Technology Group, LLC is the sole authorized dealer for Howard medical carts.

5. Description of Efforts Made to ensure that offers are solicited from as many potential sources as deemed practicable:

A Special Notice/Notice of Intent to Sole Source was posted to Contract Opportunities via sam.gov on June 8, 2026. Responses were requested no later than June 15, 2026. In accordance with VA Acquisition Regulation (VAAR) 810.001-70, the SBA’s Small Business Search (SBS) was queried on June 8, 2026 in an effort to find SDVOSB and VOSBs with NAICS 339113 who are capable of performing the required services. A total of 116 vendors were found. An email was sent to all 116 SDVOSB and VOSB vendors on June 8, 2026 informing the vendors of the posting of the Special Notice/Notice of Intent to Sole Source. Vendors were informed this notice was not a request for competitive quotes; however, any responsible source who believes it is capable of meeting the requirements may submit a capability statement, proposal, or quotation which may be considered by the agency. Vendors were also informed that responses would be evaluated; however, a determination by the Government not to compete the proposed procurement based upon responses received to the notice is solely within the discretion of the Government. Three (3) responses were received from Brightstar Innovations Group, LLC; Mayday Aid, LLC; and Vigour Media, LLC. None of the vendors are capable of providing Howard medical carts as Minburn Technology, LLC is the only authorized distributor for the OEM Howard Industries.

Additionally, an email was sent to Joshua Taylor of Howard Industries, inquiring about authorized distributors on June 8, 2026. He confirmed that Minburn Technology Group, LLC is the only authorized distributor of Howard Medical Carts and accessories to the VA and that Howard Industries will not sell directly to the VA.

The program conducted initial market research in March and April 2026. The market research conducted, including reviewing the acquisition history, reviewing the market research conducted by VISN 10 for the same required equipment, speaking with the VISN 10 procurement lead and representatives from Minburn Technology, LLC, and online market research for medical carts determined that only Howard medical carts can fulfill MidCon’s requirements for medical carts and that Minburn Technology, LLC is the only OEM authorized distributor for Howard Medical carts for the VA.

6. Determination by the CO that the Anticipated Cost to the Government will be Fair and Reasonable: The

Program has developed an Independent Government Cost Estimate (IGCE) for this requirement. The IGCE was developed by pulling 5-Year SEPG data on MidCon VAMCs projected needs. Once the needs were established, the VA calculated an estimated cost per fiscal year using VISN 10s current contract pricing that was established in December of 2025. Finally, the sole source vendor’s quote will be evaluated to determine whether the price is fair and reasonable prior to award.

7. Description of the Market Research Conducted and the Results, or a Statement of the Reasons Market Research Was Not Conducted: As stated in Section 6 above, market research was conducted pursuant to RFO Part 10, VAAR Part 810 and PPM 2016-05 (REVISED AUG 2019). Per PPM 2016-05, Implementation of the Veterans First Contracting Program as a Result of the U.S. Supreme Court Decision: §8127 is mandatory, not discretionary and its text requires the Department to apply the Rule of Two to all contracting determinations. A query of the Small Business Administration (SBA)’s Small Business Search (SBS) for SDVOSB and VOSB concerns with NAICS 339113 was conducted on June 8, 2026. A total of 116 vendors were found. An email was sent to all 116 SDVOSB and VOSB vendors on June 8, 2026 informing the vendors of the posting of the Special Notice/Notice of Intent to Sole Source. Three (3) responses were received from Brightstar Innovations Group, Mayday Aid, and Vigour Medica. None of the vendors were determined capable of providing the required supplies and services as Minburn Technology, LLC is the only authorized distributor for the OEM Howard Medical.