P03 - JA OVER_SAT - 36C25621C0013 P000015 - Redacted.pdf
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- Solicitation number
- 36C25621C0013
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This is a Justification and Approval (J&A) document for Other Than Full and Open Competition submitted by the Department of Veterans Affairs, Network Contracting Office 16 (NCO 16) in Houston, Texas. The document justifies a sole-source contract modification with Millbrook Support Services to increase task order funding by $814,890.00 for on-site psychiatry services at Michael E. DeBakey VA Medical Center (MEDVAMC) in Houston, Texas, for the period January 18, 2026, through July 17, 2026. The contracting activity references Acquisition Plan Action ID 36C25621C0013, Requisition Number 580-26-2-039-0004, and Acquisition ID 36C256-26-AP-3212.
The justification cites "Unusual and Compelling Urgency" under 41 USC §3304(a)(2) as the statutory authority for bypassing full and open competition. The requirement involves continuation of critical on-site psychiatric services including evaluations, medication management, crisis intervention, inpatient consultations, and multidisciplinary care coordination. The contracting officer determined the anticipated cost fair and reasonable based on prior contract pricing and market research, with no price increases proposed and existing hourly rates remaining unchanged. Millbrook Support Services, located at 149 Church Street, Millbrook, NY 12545 (SAM Number E2UBKGNNGCX7), is identified as the sole source capable of providing uninterrupted services without unacceptable delays caused by credentialing and onboarding requirements that could jeopardize patient safety and regulatory compliance. The J&A requires certification from the Mental Health Care Line Administrative Deputy, Contracting Officer, and One Level Above the Contracting Officer approvals prior to award.
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| File | Type | Posted |
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| 36C25621C0013 P00015.docx | DOCX document |
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VHAPG Part 806.3 OFOC Page 1 of 4 Revision: 04 Effective Date: 12/15/25 Acquisition ID#: 36C256-26-AP-3212
DEPARTMENT OF VETERANS AFFAIRS
Justification and Approval (J&A) For
Other Than Full and Open Competition (>SAT)
Acquisition Plan Action ID: 36C25621C0013
1. Contracting Activity: Department of Veterans Affairs Network Contracting Office 16 (NCO 16) 5075 Westheimer Road, Suite 750
Houston, TX 77056
Organizational Activity: Department of Veterans Affairs, VISN 16 Michael E. DeBakey VA Medical Center (MEDVAMC) Houston, TX 77030
Requisition Number: 580-26-2-039-0004
2. Nature and/or Description of the Action Being Approved:
The MEDVAMC services under the Mental Health Care Line, Contract No. 36C25621C0013.
3. Description of Supplies/Services Required to Meet the Agency’s Needs:
seeks approval for a modification to increase the task order funding by $814,890.00 for the period of performance from January 18, 2026, through July 17, 2026. This additional funding the Mental Health Care Line and to ensure continuity of care and patient safety.
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
VHAPG Part 806.3 OFOC Page 2 of 4
Acquisition ID#: 36C256-26-AP-3212
( ) (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;
per 41 USC §3304(a)(7) as implemented by RFO 6.103-7;
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 MEDVAMC requires the continued provision of on-site psychiatry services to support the delivery of comprehensive behavioral health care to patients. These services are critical to ensuring timely psychiatric evaluations, medication management, crisis intervention, inpatient consults, and coordination with multidisciplinary care teams as well as the ongoing contract staff are already on board as well as filled with patient panels for the remainder of the current extension which ends July 17,2026. The nature of the patient population requires immediate, in-person clinical availability to maintain patient safety, continuity of care, and compliance with accreditation and regulatory standards.
Accordingly, Millbrook Support Services is the only firm capable of providing the supplies and services described in Section III above without the Veteran’s Health Administration experiencing unacceptable delays in fulfilling its requirements to provide continued on-site psychiatric services for mental health care patients.
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):
The Government intends to continue services with the incumbent contractor under the exception for only one responsible source and no other supplies or services will satisfy agency requirements (FAR 6.302-1).
The incumbent contractor possesses unique qualifications and institutional knowledge essential to the uninterrupted delivery of psychiatric services at this facility, including:
Established credentialing, privileging, and onboarding within the hospital system, allowing immediate continuation of services without delay. Demonstrated familiarity with the hospital’s patient population, clinical workflows, electronic health record systems, and standards, including response times for consults, inpatient coverage requirements, and emergency psychiatric interventions.
Transitioning to a new contractor at this time would result in unacceptable delays due to credentialing and onboarding requirements, which can take several months. Such delays would create a lapse in critical psychiatric coverage, increasing risk to patient safety, disrupting continuity of care, and potentially placing the facility out of compliance with applicable standards, including those required by accrediting bodies and oversight agencies.
VHAPG Part 806.3 OFOC Page 3 of 4
Acquisition ID#: 36C256-26-AP-3212
7. Determination by the CO that the Anticipated Cost to the Government will be Fair and Reasonable:
The anticipated cost for the continued services has been determined fair and reasonable based on prior contract pricing, market research, and comparison with similar services. The contractor is not proposing any price increases under this modification, and the existing hourly rates will remain unchanged.
8. Description of the Market Research Conducted and the Results, or a Statement of the Reasons Market Research Was Not Conducted:
A review of available market capabilities has determined that no other responsible source can necessary timeframe. Future acquisition strategies will be developed to promote competition to the maximum extent practicable.
Failure to approve this justification would result in a lapse in psychiatric services, negatively impacting patient care, increasing risk of adverse clinical outcomes, and impairing the hospital’s ability to meet mission requirements and regulatory obligations.
Based on the above, the use of other than full and open competition is justified to ensure continuity of essential on-site psychiatry services, maintain patient safety, and support the hospital’s mission.
9. Any Other Facts Supporting the Use of Other than Full and Open Competition:
See number #8 above.
10. Listing of Sources that Expressed, in Writing, an Interest in the Acquisition:
Millbrook Support Services 149 Church Street Millbrook, NY 12545
SAM Number: E2UBKGNNGCX7
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:
Compelling Urgency, to ensure uninterrupted provision of essential physicist services necessary for the delivery of urgent healthcare to Veterans. The current contract is scheduled to expire in July 2026, and a new competitive acquisition is already underway to establish
VHAPG Part 806.3 OFOC Page 4 of 4
Acquisition ID#: 36C256-26-AP-3212
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.
Date
Mental Health Care Line Administrative Deputy Michael E. Debakey VA Medical Center
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.
Date Medical Sharing
Network Contracting Office (NCO) 16
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.
Date Branch Chief, Medical Sharing Network Contracting Office (NCO) 16
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