P03 - Justification and Approval_REdI redacted.pdf

DEPARTMENT OF VETERANS AFFAIRS

Office of Procurement, Acquisition and Logistics (OPAL)

Strategic Acquisition Center (SAC) 5202 Presidents Ct, Suite 103

Frederick, MD 2170

JUSTIFICATION AND APPROVAL

FOR OTHER THAN FULL AND OPEN COMPETITION

(1) Identification of the agency and the contracting activity, and specific identification of the document as a "Justification for Other Than Full and Open Competition."

This Justification and Approval (J&A) for Other Than Full and Open Competition is executed by the Strategic Acquisition Center (SAC), on behalf of the Department of Veterans Affairs (VA), Veterans Health Administration (VHA), Office of Healthcare, Innovation and Learning (OHIL).

(2) Nature and/or description of the action being approved.

Veterans Health Administration (VHA), Office of Healthcare, Innovation and Learning (OHIL) This activity proposes to award a sole source, firm-fixed price (FFP) Indefinite Delivery Indefinite Quantity (IDIQ) contract to Resuscitation Quality Improvement (RQI) Partners, LLC, a large business, for a 12-month base period and four (4) 12-month option periods, to continue resuscitation education, products, and services under the Resuscitation Education and Innovation (REdI) program. RQI Partners, LLC is a joint venture entity of the American Heart Association (AHA) and Laerdal Medical. VHA is required to maintain compliance with applicable federal healthcare regulations and VHA directives (that mandate staff competency in resuscitation techniques). Under this authority, RQI Partners, LLC will continue to provide national program support services, standardized resuscitation training materials, standardized and interoperable equipment, and program oversight and validation necessary to support comprehensive resuscitation education programs at VA medical facilities.

(3) A description of the supplies or services required to meet the agency’s needs (including the estimated value).

The proposed action is to procure enterprise-wide resuscitation education and support services necessary to sustain VHA’s existing REdI ecosystem. Specifically, the requirement includes day-to-day operational and implementation support services; maintenance and warranty coverage for approximately 2,050 Cardiopulmonary Resuscitation (CPR) Mobile CPR Testing Stations deployed across the VHA enterprise; continued access to the RQI 1Stop digital platform; and electronic licenses for resuscitation education, instructor materials, and associated digital curriculum updates. RQI Partners, LLC 1Stop is the enterprise learning and performance platform that delivers American Heart Association– based resuscitation education, manages self-directed course completion workflows for Basic Life Support (BLS), Advanced Cardiac Life Support (ACLS), Pediatric Advanced Life Support (PALS), and Responder, provides real-time performance feedback and eCredentialing linked to Mobile CPR Testing Stations, and integrates with VHA’s existing learning management and reporting environments.

The total estimated lifecycle value of this requirement, inclusive of the 12-month base period and four (4) 12-month option periods, is $98,909,650.00. These supplies and services collectively represent the minimum requirements needed to maintain continuity of standardized resuscitation training and competency validation across VHA.

Strategic Acquisition Center (SAC) 5202 Presidents Ct, Suite 103

(4) An identification of the statutory authority permitting other than full and open competition.

The statutory authority permitting other than full and open competition is 41 U.S.C. 3304(a)(1) as implemented by the Federal Acquisition Regulation (FAR) 6.103-1 entitled, “Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.”

(5) A demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited.

a. Proprietary, integrated platform and Authority to Operate (ATO) status. RQI Partners, LLC, is a joint venture between the AHA and Laerdal Medical holds the exclusive proprietary rights to the RQI platform, the only system authorized to deliver self-directed, Low Dose, High Frequency (LDHF) resuscitation training aligned with AHA’s BLS, ACLS and PALS courses. No other vendor is licensed or otherwise authorized to deliver LDHF training for these disciplines based on current AHA standards and intellectual property.

RQI Partners, LLC’s proprietary RQI 1Stop digital platform integrates adaptive learning, automated CPR performance feedback, analytics, credential management, and real-time compliance monitoring within a closed, secure ecosystem. It is the only solution capable of providing a comprehensive LDHF resuscitation training and competency management capability in accordance with AHA guidelines and International Liaison Committee on Resuscitation (ILCOR) science. In addition, the RQI Partners, LLC platform is the only resuscitation training solution that has been assessed against applicable federal cybersecurity controls, complies with Federal Risk and Authorization Management Program (FedRAMP) standards, and possess a VA-issued Authority to Operate (ATO) (granted in March 2025 for a two-year period). This authorization uniquely authorizes the RQI platform to function within VA’s enterprise network and integrate securely with internal systems such as the VA’s Talent Management System (TMS) for compliance monitoring. No other vendor offers or is in pursuit of a comparable FedRAMP-compliant, VA-authorized LDHF solution.

b. Existing government environment and sunk infrastructure. The VHA has deployed approximately 2,050 CPR mobile testing stations nationwide, along with related backend infrastructure, all designed and configured specifically for integrating with the proprietary RQI 1Stop ecosystem. This Government-owned infrastructure, including carts, adult and infant manikins, and VA-approved, Personal Identity Verification (PIV)-enabled laptops, was purpose-built to support the self-directed learning models (biennial and LDHF) for BLS, ACLS and PALS. The deployed hardware, interfaces, and workflows are technically interoperable only with the RQI platform. The Government requires ongoing maintenance and support services to ensure the uninterrupted operation of the existing RQI equipment and related courseware licenses, including associated educational materials. Due to the proprietary nature of the current RQI ecosystem, no alternative vendor possesses the capability to provide the comprehensive program coordination and warranty support essential for keeping this system fully operational. Furthermore, the existing vendor is exclusively able to supply the necessary licenses for the continued use of the current courseware, which is integral to supporting the existing infrastructure. Transitioning to another vendor or system is

Strategic Acquisition Center (SAC) 5202 Presidents Ct, Suite 103 not feasible without risking disruption to training continuity, system reliability, and compliance with established program standards. Therefore, the continued engagement with the incumbent vendor is critical to maintaining the operational readiness and effectiveness of the RQI program, ensuring that personnel receive consistent, authorized, and high-quality training materials. Transitioning to any other vendor would render the existing infrastructure inoperable, resulting in substantial sunk costs and requiring new procurement and enterprise-wide implementation efforts. In addition to hardware replacement, an alternative solution would require a complete network security assessment, FedRAMP authorization, and VA ATO issuance, activities that would cause significant delay to mission-critical resuscitation training and compliance. The current RQI-based ecosystem is the only platform compatible with VA-approved, PIV-enabled laptops and authorized to operate on the VA network. Competing solutions, including tablet-based systems, are not capable of supporting PIV authentication and cannot be deployed on the secure VHA infrastructure due to the absence of required encryption, network controls, and approved ATO. Consequently, no other vendor can provide a technically compliant or secure means of integration with existing VA systems.

Furthermore, the incumbent RQI platform supports seamless integration with the VA’s TMS for real time training and compliance tracking. A vendor change would disrupt this interface and hinder VHA’s ability to maintain federally mandated resuscitation certification and reporting requirements under VHA Directive 1177.

c. Scale of use and continuity of clinical and regulatory compliance. The RQI 1Stop digital platform currently supports resuscitation education and competency verification for approximately 275,000 clinical and nonclinical VHA employees across roughly 170 VA medical centers, with access and performance data integrated through VA TMS in accordance with VHA Directive 1177 and related policies. The RQI-based solution delivers asynchronous, self-directed, in-situ competency verification aligned with current AHA resuscitation guidelines, thereby supporting VHA’s obligations to maintain staff proficiency and meet external accreditation and credentialing requirements (including those of The Joint Commission and other federal healthcare oversight bodies). No alternative vendor is known to provide an equivalent, FedRAMP-authorized, VA-integrated and enterprise scalable ecosystem that simultaneously integrates hardware, software, standardized content, credentialing, and compliance reporting at this scale within the VA environment. Disrupting this ecosystem to migrate to a different platform would necessarily require replacement or reconfiguration of the deployed skills testing infrastructure, re-integration with TMS, and completion of new security authorization activities, which together would create an unacceptable delay and risk to the continuity of mandated life support training and associated accreditation and credentialing requirements across the enterprise. Competing offerings, such as tablet-based or non-integrated resuscitation programs, do not currently operate within the VA’s approved technical and security architecture, are not scaled or configured for direct integration with VA’s TMS at the national level, and would therefore introduce material risk of certification lapses, data gaps, and audit findings during the transition period.

Strategic Acquisition Center (SAC) 5202 Presidents Ct, Suite 103

d. Retraining burden and risk of unacceptable delay. Transitioning to a new resuscitation education vendor would require retraining approximately 2,500 instructors and 275,000 learners on a different platform, equipment set, and curriculum delivery model, in addition to associated changes in workflows and local implementation procedures. This retraining, together with system cutover, data migration, re-integration with VA TMS, and re-validation of course content and competencies, would significantly disrupt ongoing life support certification and recertification cycles across VHA facilities. Given that VHA Directive 1177 requires timely and continuous BLS and ACLS certification for clinically active staff, such disruption would likely delay care readiness and compliance with mandatory resuscitation training requirements at a national scale. This level of delay, affecting a nationwide clinical workforce and potentially interrupting required BLS and ACLS certifications, constitutes an “unacceptable delay in fulfilling the agency’s requirements” within the meaning of FAR 6.103-1(a)(2)(iii)(B).This risk includes potential lapses in certification tracking and reporting, which could directly impact patient safety, undermine VHA’s ability to comply with its own directives, and impair VA’s capacity to demonstrate compliance during external audits and accreditation reviews.

e. Duplication of cost and waste of existing investment. Transitioning to a different vendor would also require replacement of more than $25 million in existing infrastructure, including the deployed CPR mobile testing stations and associated backend platform integration, as well as new implementation, configuration, and validation services. These costs would be in addition to the cost of retraining the national instructor and learner population and would not be recoverable through competition for this requirement.

Accordingly, award to any source other than RQI Partners, LLC would result in substantial duplication of cost to the Government that is not expected to be recovered through competition, and in unacceptable delay in fulfilling VHA’s minimum resuscitation training and competency requirements, thereby satisfying the conditions for use of FAR 6.103-1. Beyond the direct financial impact, abandoning the current infrastructure would waste years of investment in system optimization, data integration (including FedRAMP and ATO authorization packages, TMS integration), and workflow standardization, forcing VHA to repeat extensive configuration, validation, and accreditation-related efforts that have already been completed. These efforts include development and validation of program administrative documents, large-scale instructor training, site visit support, and the implementation of reporting and analytics necessary to monitor compliance and clinical competence across the enterprise. This would not only squander taxpayer resources but also disrupt established processes that underpin compliance and operational efficiency across VHA, increasing the risk of lapses in required resuscitation training and competency.

(6) A description of efforts made to ensure that offers are solicited from as many potential sources as is practicable, including whether a notice was or will be publicized as required by subpart 5.2 and, if not, which exception under 5.202 applies.

Prior to proceeding under the authority of FAR 6.103-1, VHA conducted market research to identify other potential sources capable of providing an enterprise-wide, FedRAMP compliant, LDHF resuscitation training ecosystem that is technically interoperable with the existing REdI

Strategic Acquisition Center (SAC) 5202 Presidents Ct, Suite 103 infrastructure and can support approximately 275,000 users across 170 VA medical centers.

Market research activities included review of available GSA/FSS schedules and other Government-wide contract vehicles, open-source industry and literature searches, and engagement with vendors at relevant professional conferences. At the International Cardiac Arrest Survival Summit in December 2025, the VA technical representatives specifically sought out and evaluated alternative products and solutions, including those offered by the American Red Cross, to determine whether they could meet VHA’s minimum requirements. Based on demonstrations and discussions with vendor representatives, these alternative solutions were determined not to be sufficiently mature or capable at the required scale and level of integration within the VA environment and, therefore, could not meet the Government’s requirements.

In addition, a brand-name only Notice of Intent to Sole Source (Notice 36C10X26R0012) for the existing solution was posted on February 26, 2026, inviting capability statements from any responsible source by March 13, 2026. One capability statement was received from HealthStream, Inc. asserting that its standalone resuscitation platform could perform the requirement. Government review determined that this proposed solution does not meet VA’s minimum needs for this follow-on requirement because it would require deployment of a new tablet-based, standalone environment and replacement of the approximately 2,050 Mobile CPR Testing Stations and Laerdal QCPR manikins currently in use; it lacks a FedRAMP authorization and VA ATO, which are already in place for the incumbent enterprise CPR ecosystem; and it does not demonstrate that all required self-directed courseware (BLS, ACLS/ALS, PALS, and related content) is available at the time of award. Transitioning to this alternative would necessitate new equipment procurement, interface development, security authorization, and large-scale re-training of approximately 275,000 VHA staff and 2,500 instructors, resulting in substantial duplication of cost and an unacceptable risk of delay or disruption to mandatory resuscitation training.

In summary, this follow-on market research, including updated outreach to industry stakeholders, review of newly published product capabilities, direct engagement with vendors, and public notice inviting capability statements, did not identify any alternative that can satisfy the combined requirements for FedRAMP authorization, VA ATO readiness, LDHF delivery model, and full interoperability with the existing REdI infrastructure at enterprise scale without incurring substantial duplication of cost and unacceptable delay. As a result, VHA determined that RQI Partners, LLC, is the only responsible source capable of providing the required proprietary RQI platform, associated licenses, hardware support, and integration services necessary to meet VHA’s minimum needs.

As a result of this market research, VHA determined that RQI Partners, LLC is the only known source capable of providing the required proprietary RQI Partners, LLC platform, associated licenses, hardware support, and integration services necessary to meet VHA’s minimum needs.

No other companies are authorized to provide the RQI Partners, LLC solutions required for this effort. In accordance with, FAR 6.104, 6.103(b)(2) and FAR Subpart 5.201, this justification will be posted with the solicitation on the Government-wide Contracting Opportunities portal, providing notice of the Government’s action and an opportunity for any other interested parties to respond in future acquisitions. Any responses or proposals received will be reviewed and evaluated to determine whether they demonstrate the ability to meet the Government’s requirements.

Strategic Acquisition Center (SAC) 5202 Presidents Ct, Suite 103

(7) A determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable.

Based on the technical and market research information set forth in paragraph 5 and paragraph 6, full and open competition for this acquisition is not presently feasible because RQI Partners, LLC, is the only known source capable of meeting VHA’s minimum requirements without substantial duplication of cost and unacceptable delay. Nevertheless, the Government will continue to conduct periodic market research and monitor developments in resuscitation education technology, including attendance at relevant professional conferences and review of emerging platforms, to determine whether future requirements may be competed.

The current pricing being paid to the contractor has already been verified to be fair and reasonable by a warranted Contracting Officer. The Contracting Officer for this action will review the pricing offered and will use the pricing from the current contract and pricing received in conjunction with this action to verify those prices offered to be fair and reasonable. Should discussions be necessary, the Contracting Officer will conduct those with the information gained from that review.

(8) A description of the market research conducted (see part 10) and the results or a statement of the reason market research was not conducted.

Market research was conducted from November 2024 to the present to determine whether other vendors could meet VHA’s minimum requirements for an enterprise wide, LDHF resuscitation education ecosystem and to identify any sources with proprietary rights or authorized capability to deliver and support the RQI 1Stop digital platform. The RQI 1Stop digital platform is a centralized, software-as-a-service (SaaS) learning and analytics environment that delivers AHA resuscitation curricula in a self-directed and LDHF modality that manages learner enrollment and credentialing and provides real-time reporting on compliance and competence across the enterprise. The platform integrates with the VA’s existing learning and human resources systems, supports single sign-on access, and includes embedded analytics to track individual and aggregate performance and course completion. No other vendor was identified with proprietary rights to deliver or support the RQI 1Stop platform, nor any vendor capable of integrating an alternative solution into the current VHA deployment without extensive retraining, infrastructure overhaul, and significant operational disruption. Additional outreach included review of updated GSA/FSS schedules, engagement with vendors through industry demonstrations, and evaluation of new product releases announced during this period. Despite these efforts, no solution was found that meets the combined requirements for FedRAMP authorization, VA ATO readiness, self-directed or LDHF delivery model for ACLS or PALS, and seamless interoperability with existing REdI infrastructure at enterprise scale. Transitioning to any alternative would require duplicative investment exceeding $25 million and introduce delays that jeopardize compliance with VHA Directive 1177 and other applicable accreditation standards.

a. Consultation with knowledgeable Government and industry personnel. The Government contacted knowledgeable individuals in Government and industry regarding market capabilities of potential vendors, including personnel from other federal agencies and the Military Training Network. Based on live product demonstrations, review of vendor

Strategic Acquisition Center (SAC) 5202 Presidents Ct, Suite 103 marketing materials, and discussions with these stakeholders, the Government identified one potential source capable of meeting all requirements: RQI Partners, LLC, a joint venture between the AHA and Laerdal Medical.

b. Request for Information (RFI). The Government issued RFI 36C10X25Q0024 on November 21, 2024, with a response date of December 23, 2024. The RFI resulted in two responses. Evaluation criteria were developed using the case-study questions included in the RFI to assess each respondent’s ability to meet the enterprise-wide technical, operational, and cybersecurity requirements. Based on this evaluation, the only respondent determined to be capable of meeting all identified requirements was RQI Partners, LLC.

c. Database searches. The Government conducted queries of multiple databases, including SAM.gov, FPDSNG, GSA eLibrary, and the Veteran Small Business Certification database, under the applicable NAICS code 611710 and related keywords. These searches produced a broad range of vendors; however, the vast majority were determined to be unable to meet the VA’s specialized requirements for an integrated, enterprise-wide resuscitation education ecosystem, including FedRAMP compliant digital delivery, hardware integration, and support for self-directed and LDHF training at the VHA scale.

d. Review of catalogs, open-source information, and ongoing independent research. The Government reviewed catalogs and other publicly available product literature from manufacturers, distributors, and dealers, as well as information available online and on contractor websites. This review, together with ongoing independent market research focused on compatibility and feasibility within VA given the size and complexity of its training requirements, identified only one source capable of meeting all requirements:

RQI Partners, LLC. RQI Partners, LLC is the only known vendor capable of providing resuscitation education for BLS, ACLS, PALS, and Responder in a self-directed and LDHF modality that is independent of an onsite instructor and technically compatible with the existing VA deployed ecosystem. RQI Partners, LLC is a joint venture between the AHA and Laerdal Medical; AHA is the proprietary owner and national leader of the certified, nationally recognized resuscitation training programs used throughout the United States. This outreach included direct engagement with vendors at the International Cardiac Arrest Survival Summit in December 2025, where alternative products were evaluated and determined not to meet VHA’s minimum

(9) Any other facts supporting the use of other than full and open competition.

The AHA serves as the United States member organization and voting representative to ILCOR, the international body that coordinates evidence evaluation and issues Consensus on Science with Treatment Recommendations (CoSTR) for CPR and emergency cardiovascular care worldwide. As the U.S. voting member, AHA plays a leading role in shaping the resuscitation science that underpins many nationally recognized training programs in the United States. AHA guidelines and course content are widely used and accepted as evidence-based resuscitation education, and AHA-based courses are commonly accepted by major accrediting and

Strategic Acquisition Center (SAC) 5202 Presidents Ct, Suite 103 credentialing bodies as meeting current standards of care.

AHA owns the exclusive accredited content rights to its competency-based resuscitation training programs, and Laerdal Medical serves as the original equipment manufacturer (OEM) for the associated hardware. In accordance with FAR 11.105(a), “Items Peculiar to One Manufacturer,” the specific brand name content, equipment, and integrated platform features provided through the AHA/Laerdal solution are essential to the Government’s requirements, and market research has shown that other companies’ similar products lack these critical features, do not meet, or cannot be modified to meet VHA’s minimum needs. RQI Partners, LLC, a joint venture between AHA and Laerdal Medical, is therefore the only known provider capable of delivering the required integrated solution combining AHA accredited content, Laerdal OEM hardware, and the RQI 1Stop digital platform necessary to satisfy all requirements described in this justification. In addition, the proprietary integration between AHA courseware and Laerdal simulation technology enables real-time performance feedback and automated credentialing through the RQI Partners, LLC 1Stop platform, capabilities that are not available in any competing solution.

These features are essential for maintaining continuous competency validation and reducing skill decay, which directly supports VHA’s LDHF training model and patient safety objectives.

(10) A Listing of sources, if any, that expressed, in writing, an interest in the acquisition.

HealthStream, Inc. submitted a capability statement in response to Notice 36C10X26R0012; as discussed in paragraph 5, their proposed solution does not meet the Government’s minimum requirements. No other sources expressed interest or demonstrated the ability to meet all

(11) A statement of the actions, if any, the agency may take to remove or overcome any barriers that led to the exception to fair opportunity before any subsequent acquisition for the supplies or services is made.

The agency conducted a formal market research via an RFI/Sources Sought notice to identify capable vendors for the American Heart Association resuscitation courseware requirement.

Despite outreach to multiple vendors, only one vendor demonstrated full capability to meet all minimum requirements due to their exclusive control over the proprietary courseware, digital platform, and certificate issuance. Because no other vendors could meet these essential needs, and subcontracting is not feasible or valuable, the agency justifies an exception to fair opportunity. However, before any future acquisition of similar supplies or services, the agency may seek to remove or address barriers, such as proprietary control or limited vendor qualifications, that prevent competition and enable more vendors to compete fairly and reduce sole-source dependency. This supports better competition and risk mitigation in subsequent acquisitions.