P03 JA Nephrology Physician Services - BHHCS 1.pdf

VHAPG Part 806.3 OFOC Page 1 of 8 Revision: 04 Effective Date: 04/13/2026 Acquisition ID#: 36C263-26-AP-2373

DEPARTMENT OF VETERANS AFFAIRS

Justification and Approval (J&A) For

Other Than Full and Open Competition (>SAT)

Acquisition Plan Action ID: _36C263-26-AP-2373

1. Contracting Activity:

Department of Veterans Affairs Network Contract Office 23 (NCO23) HCT1, 2501 W.

22nd St., Sioux Falls, SD 57105, on behalf of the Black Hills Health Care System

(BHHCS).

2. Nature and/or Description of the Action Being Approved:

The Department of Veterans Affairs VISN 23 requires on-site, Board Certified Nephrology Physician Services to ensure continuity of specialized renal care for Veterans of the Black Hills Health Care System. These services are essential for providing evaluation, treatment, and management of complex nephrology conditions and must be available without interruption. In accordance with the Performance Work Statement (PWS) and Quality Assurance Surveillance Plan (QASP), the Contractor shall furnish all qualified physician labor and expertise necessary to meet or exceed community standards of care. Due to the specialized nature of nephrology services and the need for consistent clinical coverage, obtaining these services from another source at this time would result in unacceptable delays in patient care.

Therefore, a one-year sole-source procurement is required to ensure uninterrupted services while the follow-on competitive acquisition is being developed.

The current contract, 36C26321C0028, is scheduled to expire on June 30, 2026, leaving insufficient time to complete the necessary procurement actions and award a new long-term contract. This requirement is proposed for award as a Sole Source Indefinite Delivery, Indefinite Quantity (IDIQ) Bridge Contract, with an estimated total value of $377,347.20, to ensure continued support while follow-on procurement efforts are completed.

Services will be performed on-site at:

1. Black Hills Health Care System Fort Meade Campus (113 Comanche Road, Fort Meade, SD 57741)

2. Hot Springs Campus (500 N. 5th Street, Hot Springs, SD 57747)

3. Rapid City CBOC (2165 Promise Road, Rapid City, SD 57701)

Black Hills Sole Source J&A

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3. Description of Supplies/Services Required to Meet the Agency’s Needs:

The required nephrology physician services possess limiting and highly specialized characteristics that restrict availability to only one responsible source at this time.

Nephrology care for VA beneficiaries requires a provider who is already fully credentialed, familiar with the existing patient case load, integrated into VA clinical workflows, and capable of delivering complex, ongoing renal care without interruption. The incumbent provider’s established knowledge of patient histories, active treatment plans, and coordination with VA dialysis and specialty clinics represents a unique capability that cannot be immediately replicated by another source.

Transitioning to a new provider at this time would require extensive credentialing, onboarding, and clinical handoff activities, all of which demand significant coordination and lead time. These processes ensure that providers meet all federal, clinical, and facility-specific requirements before assuming patient care responsibilities. Given the limited time remaining, completing these steps is not feasible without compromising continuity of care. Attempting a transition under these constraints would introduce an unacceptable risk of delays or disruptions in patient services, particularly for high-risk individuals who rely on uninterrupted nephrology oversight and ongoing treatment management.

A competitive follow-on procurement is currently under development; however, a one-year Sole Source Indefinite Delivery, Indefinite Quantity (IDIQ) Bridge Contract, with a Period of Performance from 07/01/2026 through 06/30/2027, is required under FAR 6.302-2, Unusual and Compelling Urgency. This bridge action is necessary to ensure uninterrupted delivery of these critical services while the long-term competitive acquisition is finalized. The total estimated value of this bridge requirement is $377,347.20.

4. Statutory Authority Permitting Other than Full and Open Competition:

( ) (1) 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;

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

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

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

( ) (5) Authorized or Required by Statute per 41 USC §3304(a)(5) as implemented by RFO 6.103-5;

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

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

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Acquisition ID#: 36C263-26-AP-2373

5. Demonstration that the Contractor’s Unique Qualifications or Nature of the Acquisition Requires the Use of the Authority Cited Above (applicability of authority):

The incumbent contractor, Monument Health Rapid City Hospital, possesses the specialized qualifications, immediate readiness, and institutional knowledge required to ensure the uninterrupted delivery of nephrology physician services during this urgent bridge period. As the current provider, Monument Health has fully credentialed nephrology physicians who are already integrated into the facility’s workflows, clinical protocols, and electronic medical record systems. Their personnel maintain established relationships with the patient population, many of whom require continuous monitoring, complex medication management, and frequent adjustments to treatment plans.

Replacing the incumbent at this stage would necessitate a comprehensive credentialing and onboarding process for any new provider, along with coordinated clinical handoffs for all active patients. These activities demand significant administrative time, clinical coordination, and quality assurance steps to ensure that care standards are met. Given the limited timeline before the current contract 36C26321C0028 expires on June 30th, 2026, these steps cannot be completed without jeopardizing patient safety and continuity of care. Any lapse or disruption in service would pose substantial risks, especially for high-risk patients with chronic kidney disease, acute renal failure, or those requiring ongoing dialysis oversight.

Because Monument Health Rapid City Hospital is the only provider with the current capability, staff readiness, and institutional awareness to sustain these vital services without interruption, they are uniquely qualified to fulfill the Government’s immediate needs. As such, the nature of this requirement combined with the unusual and compelling urgency to avoid service gaps supports use of the authority under FAR 6.302-2.

6. Description of Efforts Made to ensure that offers are solicited from as many potential sources as possible (including whether a notice was or will be publicized as required by RFO Part 5 and, if not, which exception under RFO Part 5 applies):

Market research and outreach efforts were conducted to identify any additional sources capable of providing uninterrupted nephrology physician services within the required timeframe. Preliminary inquiries confirmed that transitioning to a new source would require extensive credentialing, onboarding, and clinical handoff processes that could not be completed before the current contract expires. Due to these constraints, no additional vendors were identified who could assume responsibilities without risking a disruption in patient care.

Under FAR Part 5, the Government is generally required to publicize contract actions to allow for full and open competition. However, in this instance, the

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Acquisition ID#: 36C263-26-AP-2373 circumstances meet the exception under FAR 5.202(a)(2), which applies when the agency’s need for services is of such unusual and compelling urgency that the Government would be seriously injured if the notice were delayed. Publication of a notice would not allow sufficient time for additional sources to respond, nor would it permit appropriate credentialing or onboarding of new clinicians prior to the required start date.

Although a competitive follow-on procurement is underway and will be publicized in accordance with FAR Part 5 requirements, the immediate need for continuity of these specialty medical services prevents the Government from soliciting offers from additional sources for the bridge period. To the maximum extent practicable, all actions taken support competition for the long-term requirement, even though the urgent need can only be met by the incumbent provider.

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

The Contracting Officer has determined that the anticipated cost for this requirement is fair and reasonable. This determination is based on a review of the incumbent contractor’s current pricing, historical costs for similar services, and an assessment of the level of effort and specialized clinical expertise required to perform nephrology physician services. The proposed price of $377,347.20 is consistent with the existing contract rates, which were previously evaluated and determined fair and reasonable through competitive procedures and market analysis. The current proposal reflects an increase of approximately $34,821.36, primarily attributable to higher costs associated with CLIN 00001. Recent market research indicates industry-wide cost escalation for this requirement due to rising material and labor pricing. The observed increase is aligned with current market trends, and therefore the adjusted pricing is still considered fair and reasonable.

Additionally, the price has been analyzed for consistency with prevailing medical service rates within the region and for comparable nephrology physician support contracts. The urgent requirement for uninterrupted clinical services and the limited performance period were also considered in assessing the reasonableness of the proposed pricing.

To ensure the final contract price remains fair and reasonable, the Government will conduct a detailed cost and price analysis prior to award, review labor categories and hours to verify appropriate application of rates and confirm that no unallowable or unsupported costs are included. Any necessary negotiations will be conducted to ensure that pricing reflects the Government’s best interest. The CO will document all analyses and findings to support the final determination of price fairness and reasonableness.

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Acquisition ID#: 36C263-26-AP-2373

8. Description of the Market Research Conducted and the Results, or a Statement of the Reasons Market Research Was Not Conducted:

Market Research was conducted using multiple Government supported tools and databases to assess the capability and capacity of potential sources to Provide Nephrology Physician Services (PSC Q531) (NAICS 621111) for a Place of Performance in South Dakota.

A Co-Pilot Vendor Search using NAICS (621111) and State of South Dakota (SD) returned 38 Vendors. There is no functionality available to filter the Vendor Search using PSC Code (Q531), and there is currently no means to verify whether nephrology physician services are available within the State of South Dakota. A Co- Pilot Contract Vehicle Search of NAICS (621111), PSC Code (Q531) and Managing Department “VA” yielded One (1) Contract Vehicles. There is no functionality to filter the Contract Vehicle Search using State South Dakota (SD) and the is no means to verify whether nephrology physician services are available within the State of South Dakota.

A GSA Advantage search using the keyword “Nephrology” and Managing Department “VA” resulted in 15 Catalogs however GSA Advantage is not a primary vehicle for Physician Staffing, and results could not be used to validate small-business of veteran-owned availability.

A SBA search using NAICS (621111) and State South Dakota (SD) returned 28 results. There is no functionality to filter by PSC Code (Q531) and there is no means to verify availability of Nephrology Physician Services in the State of South Dakota.

A secondary search on SBA of NAICS (621111) and Keyword Term “Nephrology” returned 39 results. A DSBS search using NAICS (621111), State South Dakota (SD), and Keyword Term “Nephrology” resulted in zero (0) results returned. It is unlikely that nephrology physician services utilizing a small business are within the state of South Dakota (SD). A VetCert search of NAICS (621111), State South Dakota (SD), and SBA Certifications resulted in 5 results. Due to search constraints, it is unknown if Small Business Certified can perform services under PSC Code (Q531).

A VetCert search using NAICS (621111), State South Dakota (SD), and Keyword Term “Nephrology” resulted in zero (0) results returned. This indicates there are no VetCert-listed SDVOSB/VOSB firms headquartered in South Dakota that advertise nephrology physician services.

A SAM.gov search using NAICS (621111) and PSC (Q531) returned 45 results.

However, applying a South Dakota place-of-performance filter resulted in one (1) finding. This aligns with SBA, DSBS, & VetCert results and indicates a lack of historical or currently registered vendors offering these specialty physician services in the state under this NAICS (621111) /PSC (Q531) combination.

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Acquisition ID#: 36C263-26-AP-2373

Market research was conducted across multiple Government databases and tools to identify SDVOSB/VOSB firms capable of providing Nephrology Physician Services (PSC Q531, NAICS 621111) in South Dakota. Searches across Co-Pilot, SBA, DSBS, VetCert, GSA Advantage, and SAM.gov consistently showed no verified vendors in South Dakota that advertise or demonstrate capability to provide these services. Most tools lacked PSC-specific filtering or the ability to confirm service availability, and several searches returned zero nephrology-related results. Due to this lack of available sources and the immediate need to maintain uninterrupted nephrology coverage for VA patients, the requirement meets the criteria under FAR 6.302-2, Unusual and Compelling Urgency, necessitating immediate action while a long-term competitive solution is developed.

9. Any Other Facts Supporting the Use of Other than Full and Open Competition:

The follow-on competitive acquisition is currently underway and will contain a fully developed Performance Work Statement (PWS) / Quality Assurance Surveillance Plan (QASP) and all requisite documentation to support full and open competition.

However, these materials are still in draft and require further refinement, coordination, and technical review before release to industry.

Because the current contract is approaching expiration, and because transitioning such a specialized medical service requires extensive credentialing, onboarding, and clinical handoff processes, the Government cannot delay the requirement long enough to complete the competitive documentation or allow sufficient time for new vendors to prepare and submit proposals. As such, the conditions outlined under FAR 6.103-2 apply, as the immediate need for continuity of patient care outweighs the ability to fully develop and compete the bridge requirement.

The complexity and clinical risk associated with these services further limit the Government’s ability to adapt existing specifications for temporary use. Nephrology physician support involves individualized treatment plans, high-risk patient monitoring, and direct clinical decision-making that must be maintained without interruption. Any attempt to rapidly create or modify detailed specifications for bridge competition would result in documentation that does not adequately account for the unique clinical, credentialing, and operational requirements of the service.

These circumstances provide further justification for utilizing other than full and open competition during the bridge performance period, while the Government continues to pursue a fully competitive long-term solution.

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

No sources other than the incumbent, Monument Health Rapid City Hospital, expressed interest in this acquisition. Due to the urgent nature of the requirement

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Acquisition ID#: 36C263-26-AP-2373 and the limited time available to complete credentialing and onboarding for new providers, no additional vendors submitted written correspondence indicating their ability to meet the Government’s immediate need for uninterrupted nephrology physician services during the bridge period.

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:

The agency is actively taking steps to foster full and open competition for future acquisitions of nephrology physician services and to remove the barriers that necessitated this urgent sole source action. A competitive follow-on procurement is already in development, and the program office is finalizing a comprehensive Performance Work Statement (PWS), updated market research, and an Independent Government Cost Estimate (IGCE) to support a fully competitive solicitation. These documents will establish clear, complete, and competition-ready requirements for industry participation.

To overcome the primary barrier to competition, namely, insufficient time for credentialing, onboarding, and clinical handoffs the agency will begin the competitive acquisition process well in advance of the bridge contract’s expiration. This approach will provide prospective offerors adequate time to prepare proposals, complete necessary provider credentialing, and plan for a seamless transition, if applicable. The competitive solicitation will be posted to SAM.gov in accordance with FAR Part 5 to ensure maximum visibility and industry participation.

In addition, the Government will conduct expanded market research to identify all qualified nephrology service providers capable of meeting future requirements. This may include industry outreach, Requests for Information (RFIs), or engagement with professional medical networks to broaden the potential offeror pool.

Through these actions, the agency will ensure that future procurements are conducted under full and open competition, eliminating the urgency-related barriers that necessitated this bridge sole source bridge contract.

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.

Tina Bernad Contract Specialist Network Contracting Office 23

TINA BERNAD Digitally signed by TINA BERNAD Date: 2026.04.29 09:11:37 -06'00'

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Acquisition ID#: 36C263-26-AP-2373

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

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

Matthew Rose Contracting Officer Network Contracting Office 23

b. One Level Above the Contracting Officer (Required over SAT but not exceeding $900K): I certify the justification meets requirements for other than full and open competition.

Chara Collins Division Chief Network Contracting Office 23