P03 - JOFOC - 36C260-26-AP-4587 - FINAL.pdf

VHAPG Part 808.405-6 Limiting Sources Page 1 of 4 Revision: 02 Effective Date: 03/02/2026 Acquisition ID#: 36C260-26-AP-4587 – JOFOC Log Number: FY26 - NCO 20 - 2115

LIMITED SOURCES JUSTIFICATION

ORDER >SAT

FAR PART 8.405-6

Acquisition Plan Action ID: 36C260-26-AP-4587

(1) Contracting Activity: Department of Veterans Affairs, Network Contracting Office 20, located at 1601 E. Fourth Plain Blvd, Bldg 17, Suite B428, Vancouver, WA, 98661, in support of VISN 05 Puget Sound VA Health Care System at 1660 S. Columbian Way, Seattle, WA, 98108.

Purchase Request No. 663-26-4-531-0062.

(2) Description of Action: This acquisition is conducted under the authority of the Multiple- Award Schedule Program (41 U.S.C. 152(3) and 40 U.S.C. 501). This action will be awarded as a follow-on to an original Federal Supply Schedule (FSS) order number V797D-40232 36C26021A0034 36C266025N0225.

Order against: FSS Contract Number: 36F79724D0170 Name of Proposed Contractor: Ghost Rx, Inc.

Street Address: 1561 S Alafaya Trail, Suite 200 City, State, Zip: Orlando, FL 32828 Phone: (214) 682-1604

(3) Description of Supplies or Services:

The estimated value of the proposed action is $498,341.50

Locum Diagnostic Radiologic Technologists (MRI, US, CT and X-Ray) are needed at the Puget Sound VA Health Care System. The Contractor is a SDVOSB, FSS vendor.

(4) Identify the Authority and Supporting Rationale (see below and if applicable, a demonstration of the proposed contractor’s unique qualifications to provide the required service.

FAR 8.405-6(a)(1)(A): An urgent and compelling need exists and following the ordering procedures would result in unacceptable delays.

FAR 8.405-6(a)(1)(B): Only one source is capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized.

FAR 8.405-6(a)(1)(C): In the interest of economy and efficiency, the new work is a logical follow-on to an original Federal Supply Schedule order provided that the original order was placed in accordance with the applicable Federal Supply Schedule ordering procedures. The original order must not have been previously issued under sole source or limited source procedures.

https://www.acquisition.gov/far/part-8#FAR_8_405_6 http://uscode.house.gov/browse.xhtml;jsessionid=114A3287C7B3359E597506A31FC855B3 https://www.gpo.gov/fdsys/pkg/USCODE-2011-title40/pdf/USCODE-2011-title40-subtitleI-chap5-subchapI-sec501.pdf https://www.acquisition.gov/far/part-8#FAR_8_405_6 https://www.acquisition.gov/far/part-8#FAR_8_405_6

VHAPG Part 808.405-6 Limiting Sources Page 2 of 4

Acquisition ID#: 36C260-26-AP-4587 – JOFOC Log Number: FY26 - NCO 20 - 2115

The OIG Determination of Veterans Health Administration’s Severe Occupational Staffing Shortages for Fiscal Year 2025 report identifies Diagnostic Radiologic Technologist as a Severe Shortage Occupation in 48 (35%) facilities and has VA Secretary Direct-Hire Authority. While this report does not identify PSVAHCS as having this particular severe shortage they have been unable to hire new personnel and have been filling a majority of Diagnostic Radiologic Technologist position with contractor personnel since 31 Mar 25.

The original task order was awarded competitively against a multiple award BPA that was awarded against FSS contracts. All options have been exercised, and the Mission Partners need a sole source follow-on task order to avoid a lapse in service and maintain currently onboarded and credentialed personnel while a new long-term requirement is being developed and solicited.

FAR 8.405-6(b): Items peculiar to one manufacturer:

A patent, copyright or proprietary data limits competition. The proprietary data is:

These are “direct replacements” parts/components for existing equipment.

The material/service must be compatible in all aspects (form, fit and function) with existing systems presently installed/performing.

(5) Describe Why You Believe the Order Represents the Best Value consistent with FAR 8.404(d) to aid the contracting officer in making this best value determination:

The order for Diagnostic Radiologic Technologists for the PSVAHCS represents the best value consistent with FAR 8.404(d) for several reasons:

a) Critical Need and Urgency: PSVAHCS is currently using contracted Diagnostic Radiologic Technologists to staff their Diagnostic Imaging department. This occupation has been identified in the OIG Determination of Veterans Health Administration’s Severe Occupational Staffing Shortages for Fiscal Year 2025 report as impacting 48 facilities and constitutes 35% of the overall identified critical healthcare needs. Filling this gap is crucial to maintaining essential medical services for Veterans. Report

b) Proven Vendor: The Contractor is a FSS SDVOSB listed on the National Acquisition Center as an authorized vendor of Diagnostic Radiologic Technologists. Utilizing a vendor with this recognized status ensures compliance with federal procurement policies.

c) Consistency and Continuity of Care: Maintaining currently onboarded and credentialed personnel through a sole-source follow-on task order ensures there is no lapse in critical medical services. This continuity is essential for the ongoing treatment and care of veterans who rely on diagnostic imaging services.

d) Cost Efficiency: By exercising all options of the initial task order, the PSVAHCS has already invested substantial time and resources to secure qualified personnel. A logical https://www.vaoig.gov/reports/national-healthcare-review/oig-determination-veterans-health-administrations-severe-1#:%7E:text=Among%20the%20most%20significant%20findings,staffing%20report%20were%20the%20following:&text=In%20fiscal%20year%20(FY)%202025,reported%202,959%20total%20shortage%20occupations.&text=Ninety-four%20percent%20of%20facilities,severe%20shortages%20for%20Nurse%20occupations.&text=Psychology%20was%20the%20most%20frequently,reporting%20it%20as%20a%20shortage.&text=Police%20was%20reported%20as%20a,frequently%20reported%20of%20all%20occupations.&text=All%20139%20VHA%20facilities%20identified,The%20OIG%20made%20no%20recommendations.

VHAPG Part 808.405-6 Limiting Sources Page 3 of 4

Acquisition ID#: 36C260-26-AP-4587 – JOFOC Log Number: FY26 - NCO 20 - 2115 follow-on task order avoids the costs and delays associated with initiating a new procurement process and onboarding new personnel, thereby ensuring cost-effective continuity of care.

e) Addressing National Shortages: The U.S. faces a significant shortage of Diagnostic Imaging Technologist driven by an aging veteran population, increased screening demands, and the retirement of current personnel. This task order would ensure that the PSVAHCS is proactive in mitigating these challenges by securing services from a reputable contractor.

Given these factors, the order represents the best value by prioritizing critical medical needs, ensuring continuity and quality of care, supporting veteran-owned businesses, and addressing national healthcare shortages in a cost-effective and efficient manner.

(6) Describe the Market Research Conducted:

Limited market research was conducted to ensure current prices are in line with industry trends.

Pricing on the expiring task order are identical to those in Ghost Rx’s GSA contract. The current task order expires on 31 August 2026. Given the limited timeframe to secure additional services and avoid a lapse in service, it is impractical for a new vendor to recruit suitable candidates, complete the necessary background investigations undergo the credentialing process, and facilitate onboarding within this period. Ghost Rx is available and ready to continue performance of these services.

(7) Any Other Facts Supporting the Justification:

Diagnostic Radiologic Technologists who have already passed the background check and credentialling are currently working on station. This is a significant advantage because the credentialling process for clinical personnel in the VA healthcare system is thorough and rigorous. Credentialling involves obtaining, verifying, and assessing a person’s qualifications to ensure they are fit to deliver care or services within the VA healthcare system. This process includes documenting evidence of licensure, education, training, experience and other relevant qualifications. By retaining these already credentialed and onboarded personnel, the PSVAHCS ensures uninterrupted, high-quality care for Veterans, avoiding the time-consuming and costly process of credentialing new personnel.

(8) A Statement of the Actions, if any, the agency may take to remove or overcome any barriers that led to the restricted consideration before any subsequent acquisition for the supplies or services is made:

A new long-term contract solicitation package is being developed and will be submitted once Mission Partner completes package requirements.

VHAPG Part 808.405-6 Limiting Sources Page 4 of 4

Acquisition ID#: 36C260-26-AP-4587 – JOFOC Log Number: FY26 - NCO 20 - 2115

(9) 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. I understand that processing of this limited sources justification restricts consideration of Federal Supply Schedule contractors to fewer than the number required by FAR Subpart 8.4.

SIGNATURE DATE

NAME TITLE SERVICE LINE/SECTION

FACILITY

(10) Approvals in accordance with the VHAPM Part 806.3 OFOC SOP:

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

SCOTT A. REED

Contracting Officer, NCO 20 Health Care Resources

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

BETHANY IRETON

Contracting Officer NCO 20 Chief, Health Care Resources https://dvagov.sharepoint.com/sites/VHAProcurement/VHAPM2/VHAPM_Part_806.3.aspx https://dvagov.sharepoint.com/sites/VHAProcurement/VHAPM2/VHAPM_Part_806.3.aspx