P03 - JOFOC - CBOC - Alamogordo NM - NMVAHCS - HCA Approved.pdf

Effective Date: 11/15/24 Page 1 of 5

REVISION: 01

Acquisition ID#: 36C262-26-AP-0100

DEPARTMENT OF VETERANS AFFAIRS

SOLE SOURCE JUSTIFICATION UNDER SIMPLIFIED PROCEDURES FOR

CERTAIN COMMERCIAL ITEMS IN ACCORDANCE WITH FAR 13.5

Acquisition Plan Action ID: 36C262-26-AP-0100

1. Contracting Activity: The Department of Veterans Affairs (VA), Veterans Integrated Services

Network (VISN) 22, New Mexico VA Health Care System (NMVAHCS), is the requiring activity.

This acquisition is being executed by the Network Contracting Office (NCO) 22. The Purchase

Requisition (PR) number is 501-26-1-082-0001.

2. Nature and/or Description of the Action Being Processed: This procurement is for the

Community-Based Outpatient Clinic (CBOC) services in accordance with Federal Acquisition

Regulation (FAR) 13.5 Simplified Procedures for Certain Commercial Items and specifically FAR

13.501 Special Documentation Requirements, where acquisitions conducted under Simplified

Acquisition Procedures are exempt from the requirements of FAR Part 6, but still require a justification using the format of FAR 6.303-2.

A sole source bridge contract is required to provide continued healthcare services for Veterans in

Alamogordo, New Mexico (NM). This requirement ensures continuity of critical healthcare services while the long-term contract is expected to be awarded by December 1, 2025. This action will be awarded as a new contract and the requirement type will be fixed-price (FP), indefinite delivery, indefinite quantity (IDIQ) contract.

3. Description of Supplies/Services Required to Meet the Agency’s Needs: NMVAHCS requests a contractor to provide comprehensive outpatient health care tailored to Veterans residing in rural areas.

Services include primary care, mental health care, preventive care, chronic disease management, minor procedures, and other related medical services. These services are delivered both on site and through telehealth, with additional support services such as pharmacy, laboratory, and x-ray. These services are authorized under Title 38 United States Code (USC) 8153 and VA Directive 1663.

The period of performance for this acquisition is six (6) months, with one (1) six-month option, from

10/01/2025 to 09/30/2026, for an estimated total of $4,620,011.52. The clause, FAR 52.217‐8: Option to Extend Services and FAR 52.217-9: Option to Extend the Term of the Contract are included for this requirement. The options will be evaluated, and the specified rates will be those in effect under the contract each time an option is exercised under this clause.

4. Statutory Authority Permitting Restricted Competition:

FAR 13.5 Simplified Procedures for Certain Commercial Items. The statutory authority for applying the Simplified Procedures for Commercial Items of FAR 13.5 is 41 U.S.C. § 1901 and is implemented by FAR 13.106-1(b)(2) 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

( ) Unusual and Compelling Urgency

( ) Industrial Mobilization, Engineering, Developmental or Research Capability or Expert

Services

( ) International Agreement

( ) Authorized or Required by Statute

( ) National Security

( ) Public Interest

Effective Date: 11/15/24 Page 2 of 5

5. Demonstration that the Contractor’s Unique Qualifications or Nature of the Acquisition

Requires the Use of the Authority Cited Above (applicability of authority): Primary Care

Solutions Inc., is the only responsible source capable of providing uninterrupted CBOC healthcare services to Veterans in Alamogordo without incurring unacceptable delays, service disruptions, or risks to patient care.

Establishing a new fully, functional CBOC requires significant time and resources, including facility build-out, credentialing, clinical integration, and Information Technology (IT) system setup.

However, Primary Care Solutions already has these critical components in place and is fully operational as the incumbent contractor. This continuity eliminates the need for a new build-out and accelerates delivery of services without delay.

Based on prior acquisition history and consultation with clinical operations and credentialing offices, the estimated time required for a new vendor to become fully operational is approximately 150 to 180 days. Considering the requirement is a follow-on to existing services and Primary Care Solutions is already performing, that lead time is avoided entirely.

Additionally, based on the facility’s CBOC Cost Estimating Tool, the projected cost to build-out a

CBOC is estimated at $5,503,906.69. Awarding Primary Care Solutions would result in a minimal to no additional build-out cost compared to initiating a new award.

Alamogordo is a rural area and sourcing qualified healthcare personnel in such locations often requires additional time due to limited local availability and recruitment challenges. Primary Care

Solutions already has trained and credentialed personnel, familiarity with the regional healthcare dynamics and VA-specific protocols, which uniquely enables continued service delivery without the administrative and operational delays associated with onboarding a new contractor.

In summary, Primary Care established presence, infrastructure, and trained personnel make them uniquely qualified to meet the needs of Veterans in Alamogordo without the risks or delays associated with transitioning to a new vendor.

6. Description of Efforts Made to ensure that offers are solicited from as many potential sources as deemed practicable: Although market research for the long-term requirement has been completed and a competitive award is anticipated, soliciting offers for this short-term requirement is not deemed practicable due to the limited duration, the complexity of the requirement, and the risk of service interruption. Issuing competitive solicitation for CBOC services would not be cost-effective or feasible for a short-term contract. Therefore, no additional offers were solicited for this requirement, as no other source could satisfy the agency’s immediate needs without significant risk to Veteran’s care.

However, during the market research for the long-term contract, efforts were made to ensure that offers are solicited from as many potential sources as practicable. A Source Sought Notice (SSN):

36C26224Q1390 for the long-term requirement was posted on June 25, 2024, to July 2, 2024, on

SAM.gov. Nine (9) vendors responded: six (6) SDVOSBs, two (2) large businesses, and one (1)

Veteran Own Small Business (VOSB). Of the six (6) SDVOSB respondents, two (2) vendors were confirmed capable of meeting the CBOC requirement.

Subsequently, this action will be synopsized on SAM.gov in accordance with FAR 13.501(a)(1)(iii) and will be made publicly available within 14 days after the contract is awarded.

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

Reasonable: In accordance with FAR 13.106-3(a), the Contracting Officer (CO) will determine that the anticipated cost for this requirement will be fair and reasonable. Determination will be based on the incumbent proposed rates, historical pricing for similar services, the independent government cost

Effective Date: 11/15/24 Page 3 of 5 estimates (IGCE), and prevailing market rates for equivalent healthcare services. Additionally, the

CO will assess whether the proposed rates are aligned with competitive benchmarks and confirm that no excessive cost increases are present.

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 in accordance with FAR

Part 10 to identify vendors potentially capable of providing CBOC services. The contract specialist conducted searches through several government databases and reviewed vendor performance data, contract history, and other available resources to assess viable sources capable of meeting the requirement. Market research for this requirement was conducted between June and July 2025.

A search through General Services Administration (GSA) portal, (https://www.gsaelibrary.gsa.gov), using the keyword “CBOC” returned no relevant results. A secondary search using “primary care” produced one (1) multiple award schedule for Office Management, which was limited to office supplies and media products.

A search through the U.S. Small Business Administration (SBA), Dynamic Small Business search tool (https://search.certifications.sba.gov), using the North American Industry Classification System

(NAICS) code: 621498 (All Other Outpatient Care Centers) resulted in two (2) SDVOSB vendors who currently provide CBOC services, including the incumbent vendor.

A search in SAM.gov, (https://sam.gov), using the same NAICS code, Product and Service Code

(PSC): Q201 (Medical-General Health Care) identified 19 recent awards within the last year. Of the identified, 14 were awarded as interim CBOC contracts, four (4) were awarded long-term CBOC contracts, and one (1) was for ancillary services. These awards were distributed among six (6) large businesses, two (2) SDVOSBs (including the incumbent), and two (2) small businesses.

The Medical Sharing / Affiliate Nation Program Office (MSO) database confirms that there are currently 17 vendors nationally capable of performing CBOC services, including the incumbent vendor.

Market research confirmed that although multiple vendors are capable of performing the work under a new long-term contract, only the incumbent vendor is positioned to continue services immediately without a lapse in care. Any transition to a new vendor for the short-term period would result in unacceptable delays or disruption to Veteran care.

9. Any Other Facts Supporting the Use of Other than Full and Open Competition: The VA is actively working to competitively award a long-term contract. This requirement is a temporary solution to maintain care until that award is finalized. Initiating a new competition for a short-term requirement would be inefficient, duplicative, and waste taxpayer resources.

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

Name: Primary Care Solutions Inc.

Address: 10300 N Central Expressway Ste. 460, Dallas, TX 75231

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:

This sole source requirement is to prevent a lapse in care. No additional actions are needed at this time, as future services will be acquired competitively under the pending long-term contract.

Effective Date: 11/15/24 Page 4 of 5

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.

Cynthia Heins, M.D

Ambulatory Care Service, NMVAHCS

Chief of Service

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

a. Contract Specialist: I certify that the foregoing justification is accurate and complete to the best of my knowledge and belief.

Ramonalisa Aviles

Network Contracting Office 22

Contract Specialist

b. Contracting Officer: I certify that the foregoing justification is accurate and complete to the best of my knowledge and belief.

Danielle Trudeau

Contracting Officer

c. One Level Above the Contracting Officer (Required over SAT but not exceeding $750K): I certify the justification meets requirements for other than full and open competition.

Jarrod Washington

Contracting Officer, Division Chief, HCR

d. Director of Contracting Review and Approval: I approve the justification for other than full and open competition for HCA review and approval.

Sabrina J. Smith

Network Contracting Office - 22

Director of Contracting https://dvagov.sharepoint.com/sites/VHAProcurement/VHAPM/VHAPM_Part_806.3.aspx

Effective Date: 11/15/24 Page 5 of 5

e. 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 approve ($750K to $7.5 million (or $15.0 million for acquisitions described in FAR 13.500(c)) for other than full and open competition.

Curtis M. Jordan

Executive Director, Regional Procurement Office West

Head of Contracting Activity (HCA)