P03 JA _Repacker Services Bridge_HCAsigned.pdf

Attachment 1: Request for Sole Source Justification Format >SAT

Page 1 of 5 VHAPG Part 806.3 OFOC Revision: 04 Effective, Date: 12/15/25 Acquisition ID#: 36C770-26-AP-0453

DEPARTMENT OF VETERANS AFFAIRS

Justification and Approval (J&A) For

Other Than Full and Open Competition (>SAT)

Acquisition Plan Action ID: 36C770-26-AP-0453

1. Contracting Activity: Department of Veterans Affairs, NCO 15, CMOP National –All seven CMOP stations.

2. Nature and/or Description of the Action Being Approved: This acquisition is conducted under the statutory authority of 41 USC §1901 and implemented by RFO 12.102(b) Simplified Procedures for Commercial Services. The Department of Veterans Affairs intends to award a new, single Indefinite Delivery, Indefinite Quantity (IDIQ) contract vehicle to Aphena Pharma Solutions-Tennessee LLC (Aphena) for an ordering period of six months from May 1, 2026 - October 31st, 2026 to provide pharmaceutical repacking services in support of all seven CMOP facilities.

A six-month period of performance is necessary to address the exigent circumstances described in further detail below. A sole source contract with Aphena, which is the incumbent Contractor, will bridge the gap in services to avoid a critical lapse in CMOP pharmaceutical repacking services while the procurement for the long-term contract is pending completion. A task order under the new IDIQ will be issued for services.

The current IDIQ task order for these services with Aphena is due to end on April 30th, 2026. This sole-source bridge IDIQ contract to Aphena will ensure that there is no lapse of these critical services while the award of the long-term contract is completed and transitioned. The maximum value of services that the agency can order under this IDIQ will be $7,200,000.

3. Description of Supplies/Services Required to Meet the Agency’s Needs: The services required are for pharmaceutical repacking services for all seven CMOP facilities. Repacked pharmaceuticals play a vital role in the fulfillment process by improving the efficiency of CMOP operations which creates faster delivery times to Veteran patients. Based off historical data, CMOP National anticipates a need for approximately 17 million repacked bottles per year. Currently, the CMOP stations depend on this contract to fulfill the need for various quantities of pharmaceuticals that are not covered by the VA National Acquisition Center (NAC) contracts. This contract closes the gap between the NAC and CMOP by providing critical pharmaceuticals to Veterans without delays in deliveries. Failure to supply these pharmaceuticals in a timely manner would have a direct negative impact on Veteran patient health and safety.

Page 2 of 5 VHAPG Part 806.3 OFOC Revision: 04 Effective, Date: 12/15/25 Acquisition ID#: 36C770-26-AP-0453

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

(X) Only One Responsible Source per 41 USC §1901 as implemented by RFO 12.102(b)

This is a unique services requirement of National CMOP to provide Veterans with prescriptions as the Agency diligently pursues the award of its long-term contract.

Any other source would create unacceptable delays in fulfilling the agency’s requirements.

5. Demonstration that the Contractor’s Unique Qualifications or Nature of the Acquisition Requires the Use of the Authority Cited Above (applicability of authority): On December 10th, 2025, the VA issued an unrestricted solicitation on SAM.gov for 30 days to procure pharmaceutical repacking services for the National CMOP. On January 9th, 2026, a solicitation amendment was issued to extend time needed for the CMOP station to accurately answer vendor questions and to extend the solicitation due date for an additional two weeks. On January 23rd, 2026, a second solicitation amendment was issued to provide completed answers to the vendor questionnaire, provide an updated performance work statement (PWS) and pricing schedule, update the address to send bottle and cap samples to for testing, and to extend the proposal submission date an additional two weeks. At the close of the solicitation, four proposals were received, however, two proposals were deemed unsuccessful due to not submitting samples for testing by the required due date.

Source selection evaluation for the two successful proposals received occurred from February 24th to April 2nd, 2026, to include the testing of bottles and caps at the Hines CMOP as a requirement of the technical evaluation. During this evaluation period, it was determined by members of the evaluation board that the PWS and pricing schedule were missing elements they deemed critical to the successful performance of these services. Under these circumstances, the Contracting Officer has determined in good faith that an award cannot currently be made. An additional solicitation amendment will be required to be issued to provide offerors with an updated and accurate PWS and pricing schedule.

The CMOP requires these services to continue to provide Veterans with prescriptions as the Agency diligently conducts the acquisition for its long-term requirement. No other Contractor would be able to start providing services under the current time restraints based upon the current Contractor’s validated procedures, required facility licenses and certifications and specialized equipment required to perform compliant pharmaceutical repacking. The urgent nature of this short-term requirement to ensure continuity of services precludes the ability to conduct full market research. However, market research was conducted for the solicitation currently issued to fulfill the long-term requirement and the Agency fully intends to make award pursuant to the solicitation.

While the long-term solicitation effort has demonstrated that other firms are interested and capable of providing these services, Aphena is the only Contractor currently providing these services, as such, they are the only responsible source

Page 3 of 5 VHAPG Part 806.3 OFOC Revision: 04 Effective, Date: 12/15/25 Acquisition ID#: 36C770-26-AP-0453 able to meet this short-term need. Any other Contractor would need to spend a significant portion of the envisioned period of performance transitioning during which time services would be disrupted.

As discussed above, the VA is actively soliciting for the long-term requirement. The current task order with Aphena ends on April 30, 2026, at which time CMOP National will need a new bridge contract and task order to avoid a lapse in repacker services. Accordingly, the VA has a short term need to continue these services while the long-term requirement is awarded.

The repacker services provided are critical to the provision of Veteran care because the CMOP relies on these services to fill Veteran prescriptions. As noted above, given the nature of prescriptions supplied, failure to timely supply would have a direct negative impact on Veteran health and safety. Any delay in providing services will have a significant impact on VA’s ability to carry out its mission. Therefore, the sole-source IDIQ bridge contract with Aphena is necessary to ensure continued services as the remaining acquisition to establish a long-term contract for National CMOP is completed.

6. Description of Efforts Made to ensure that offers are solicited from as many potential sources as possible: This justification relates solely to the need to provide repacking services for the CMOP stations for the ordering period from May 1st, 2026 - October 31st, 2026, or through transition of the long-term solution, whichever comes first. The Contracting Officer is establishing a long-term solution, which will allow other potential sources to participate in the acquisition.

7. Determination by the CO that the Anticipated Cost to the Government will be Fair and Reasonable: The Contracting Officer used historical pricing from other contracts, the IGCE, and competitive pricing for the long-term solution which confirmed and deemed the cost fair and reasonable.

8. Description of the Market Research Conducted and the Results, or a Statement of the Reasons Market Research Was Not Conducted: CMOP National requires these services to continue providing Veterans with prescriptions as the Agency diligently pursues the award of its long-term contract. Once the bridge contract is awarded, Aphena will be able to continue providing services on May 1st, 2026, avoiding a lapse in coverage. As noted above, the VA has already conducted market research and is actively competing the long-term procurement.

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

N/A

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

N/A

Page 4 of 5 VHAPG Part 806.3 OFOC Revision: 04 Effective, Date: 12/15/25 Acquisition ID#: 36C770-26-AP-0453

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 anticipates sufficient competition under this solicitation to address the long-term requirement, thereby successfully overcoming the need for an additional sole-source bridge IDIQ with Aphena.

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.

Russell A. Wright Date Supply System Analyst National CMOP

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.

Renee M. Kreutzer Date Contracting Officer Network Contracting Office 15 – CMOP Division

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.

Andrew J. Raiber Date Director of Contracting

Network Contracting Office 15

Page 5 of 5 VHAPG Part 806.3 OFOC Revision: 04 Effective, Date: 12/15/25 Acquisition ID#: 36C770-26-AP-0453

c. VHA RPO HCA Review and Approval: I have reviewed the foregoing justification and find it to be complete and accurate to the best of my knowledge and belief and recommend approval (if over $90 million) or approve ($900K to $90 million) for other than full and open competition.

Daryl A. Berg Date Executive Director Regional Procurement Officer Central (RPO-C) VHA Head of Contracting Activity (HCA)

VHAMINBergD2 Typewritten Text 04/29/2026