P03_ Justification AP-3100 FULLY_Redacted.pdf

Request for SDVOSB/VOSB Sole Source Justification Format IAW VAAR 819.7008/9

VHAPG Part 819.7008/7009 Sole Source Awards to SDVOSB/VOSB Page 1 of 5 Revision: 04 Effective Date: 11/15/2024

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DEPARTMENT OF VETERANS AFFAIRS

Justification and Approval (J&A) For

Other Than Full and Open Competition

Acquisition Plan Action ID: 36C241 25 AP 3100

Contracting Activity: Network Contracting Office 1, Regional Procurement Office East on behalf of the Department of Veterans Affairs, VISN 01, All VA Medical Centers in New England.

Nature and/or Description of the Action Being Approved: VISN 1 currently has Contract No.

36C24125D0011 with P.D.S. CONSULTANTS, INC, a U.S. Small Business Administration (SBA) Dynamic Small Business Search (DSBS) tool certified Service Disabled Veteran Owned Small Business (SDVOSB), for prescription eyeglass manufacturing and optician services. The current contract covers the manufacturing and delivery of both dress and safety prescription eyeglasses to include fitting services provided by a licensed optician for Veteran beneficiaries of VISN 1. The current contract expires on 05/27/2025. A short term bridge procurement is required while the Agency is developing a long term national consolidated solution. The short term bridge contract will ensure that there is no disruption in the availability of prescription eyeglasses for Veteran beneficiaries while the consolidated acquisition is being completed. Since this requirement entails direct patient care, ongoing services are required. An interruption of services is not an option as it would place Veteran patients at risk of not receiving care.

VA anticipates the award of new multiple, firm fixed price, IDIQ contracts resulting from national consolidated acquisition. VA further anticipates that the national consolidated acquisition should be completed by October 31, 2025. The period of performance will include a 4 month base period while the long term national solution is being worked. The estimated total value of the contract for the base period is

Description of Supplies/Services Required to Meet the Agency’s Needs: The Department of Veterans Affairs (VA) has an ongoing program to provide prescription eyeglasses (both dress and safety) to eligible veterans. The provision of corrective eyeglasses is required for eligible veterans to meet their optic and low vision medical needs. The VA eye clinic prescribes corrective lenses based upon a medical exam. The clinical judgement and assessment are used to determine medical necessity in conjunction with VHA Directive 2008 070 (Prescribing Hearing Aids and Eyeglasses) and 39 CFR 17.149 (Sensory Neural Aids). Eyeglasses are not an emergent service and follow the administrative standard for assessment and procurement practices. The Contractor shall provide all labor and materials necessary to provide prescription eyeglasses and in house (onsite at VA facilities) optician fitting services. The Contractor is to provide prescription eyeglasses including fitting services by a licensed optician according to contract specification for beneficiaries of the following sites of care and their entire catchment areas, within VISN 1.

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Facility (Ordering Activity) Address

Togus VA Medical Center 1 VA Center, Augusta, ME 04330 6796

Manchester VA Medical Center 718 Smyth Road, Manchester, NH 03104 7007

White River Junction VA Medical Center 163 Veterans Drive, White River Junction, VT 05001 0001

Northampton VA Medical Center 421 N. Main Street, Leeds, MA 01053 9764

Providence VA Medical Center 830 Chalkstone Avenue, Providence RI 02908 4734

West Haven VA Medical Center 950 Campbell Avenue, West Haven, CT 06516 2770

Brockton VA Medical Center 940 Belmont Street, Brockton, MA 02301 5596

Jamaica Plain VA Medical Center 150 S. Huntington Avenue, Jamaica Plain, MA 02130 4817

West Roxbury VA Medical Center 1400 VFW Parkway, West Roxbury, MA 02132 4927

Bedford VA Medical Center 200 Springs Road Bedford, MA 01730 1114

Causeway VA Clinic 251 Causeway Street, Boston, MA 02114 2104

Worcester VA Clinic 403 Belmont Street, 1st Floor, Worcester, MA 01604 1020

Lowell Outpatient Clinic 130 Marshall Rd, Lowell, MA 01852 5130

Newington VA Clinic 555 Willard Avenue, Newington, CT 06111 2631

Eagle Square VA Clinic 623 Atwells Avenue, Uncas Building, Providence, RI 02909 7403

John J. McGuirk Department of Veterans Affairs Outpatient Clinic

6 Shaw's Cove, Suite 104, New London, CT 06320 4969

Bangor VA Clinic 35 State Hospital Dr, Bangor, ME 04401

Lewiston VA Clinic 15 Challenger Dr, Lewiston, ME 04240 1041

Portland VA Clinic 141 West Commercial Street, Portland, ME 04102 3905

Burlington Lakeside VA Clinic 128 Lakeside Ave Ste 260, Burlington, VT 05401

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The estimated quantities included in the short term bridge contract will be based on the line item usage data under the current contract.

Period of Performance:

Base Period: 05/28/2025 – 09/30/2025 – Estimated Valu

4. Statutory Authority Permitting Other than Full and Open Competition: 41 USC §3304(a)(5), as implemented by FAR 6.302 5 (Authorized or Required by Statute), and 38 U.S. Code § 8127(c), as implemented by VAAR 819.7008 (DEVIATION).

5. Demonstration that the Contractor’s Unique Qualifications and/or Nature of the Acquisition Requires the Use of the Authority Cited Above (applicability of authority): Under 38 USC 8127(c), VA has the authority to award a contract to an SDVOSB concern using procedures other than competitive procedures if three conditions aremet: (1) the SDVOSB is determined to be a responsible source with respect to performance of such contract opportunity; (2) the anticipated award price of the contract, including options, will not exceed $5,000,000; and (3) in the estimation of the Contracting Officer, the contract award can be made at a fair and reasonable price that offers best value to the U.S.

The proposed contract is a short term bridge contract with total performance period of 4 months, while the long term national solution is being worked. This proposed short term bridge contract will allow for continued services. Interruption of services is not an option. The incumbent contractor, P.D.S. CONSULTANTS, INC, is an SBA verified SDVOSB vendor who has been providing prescription eyeglass manufacturing and optician services to VISN 1 since 2015. As such, the incumbent would not require a transition period for this proposed short term bridge contract.

Award of a follow on short term bridge contract to P.D.S. CONSULTANTS, INC will allow for continued services while the national consolidated procurement is being completed. Without this short term bridge contract, Veteran beneficiaries of VISN 1 would not have access to prescription eyeglasses.

Moreover, due to the complexities involved in a transition to another contractor who could provide the same or similar services, care would undoubtedly be disrupted and any gap in the continuity of services would have a detrimental impact on the Veterans. It is therefore necessary to provide continuous services from the incumbent contractor until national consolidated procurement is completed.

P.D.S. CONSULTANTS, INC, a verified SDVOSB concern, has been determined to be responsible in accordance with the general responsibility standards outlined in FAR 9. P.D.S. CONSULTANTS, INC, a prescription eyeglass manufacturer, has relevant experience providing prescription eyeglass manufacturing and optician services and is currently doing so in VISN 1 since 2015. Furthermore, P.D.S. CONSULTANTS, INC can meet the requirement in its entirety immediately upon award of the short term bridge contract.

P.D.S. CONSULTANTS, INC has certified that it will comply with the requirements of the Buy American Statute and the applicable Limitations on Subcontracting. P.D.S. CONSULTANTS, INC has certified it is a small manufacturer under applicable NAICS code 339115, P.D.S. CONSULTANTS, INC is a certified SDVOSB within the SBA DSBS as confirmed by the Contracting Officer on 04/29/2025.

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36C241 25 AP 3100

Request for SDVOSB/VOSB Sole Source Justification Format IAW VAAR 819.7008/9

The estimated dollar value is for the base period. The anticipated award price of the short term bridge contract will not exceed the $5 million dollar threshold.

The Contracting Officer has determined that award will be made to P.D.S. CONSULTANTS, INC at a fair and reasonable price. The Contracting Officer utilized the pricing under the current contract as well as other procurements of prescription eyeglass manufacturing and optician services where prices were previously determined to be fair and reasonable to assist in the determination that the pricing for this short term bridge contract is fair and reasonable.

6. Description of Efforts Made to ensure that offers are solicited from as many potential sources as deemed practicable: The Contracting Officer’s determination to award a short term bridge contract on a sole source basis is a business decision wholly within the discretion of the Contracting Officer. Procuring the short term requirement on a competitive basis is not feasible. VA has statutory authority to procure this requirement from a verified SDVOSB concern on a sole source basis IAW 38 USC § 8127(c). It is in the Government’s best interest to solicit from one contractor (the incumbent P.D.S. CONSULTANTS, INC for the short term bridge contract to ensure there is no interruption of services while the national consolidated acquisition is going through the procurement process.

7. Determination by the CO that the Anticipated Cost to the Government will be Fair and Reasonable: The Contracting Officer has determined the offered pricing for the short term bridge contract is fair and reasonable based on a comparison to historical pricing data for these same services in VISN 1. The unit prices in the short term bridge contract will remain the same as the unit prices included in the current contract. The existing prices under the current contract were determined fair and reasonable prior to award.

8. Description of the Market Research Conducted and the Results, or a Statement of the Reasons Market Research Was Not Conducted:Market research indicates that the incumbent P.D.S.

CONSULTANTS, INC is an SBA verified SDVOSB and available to begin performance under the short term bridge contract on 05/28/2025 Separate market research has been performed as part of the national consolidated acquisition.

9. Any Other Facts Supporting the Use of Other than Full and Open Competition: None. VA has statutory authority to procure this requirement from a verified SDVOSB concern on a sole source basis in accordance with 38 USC 8127(c).

10. Listing of Sources that Expressed, in Writing, an Interest in the Acquisition: P.D.S. CONSULTANTS, INC., has confirmed their interest in the interim contract in writing through email correspondence on Monday, 3/31/2025 at 11:10 AM via email correspondence from the President, CEO of P.D.S.

CONSULTANTS, INC., Sean M. Loosen.

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: VA intends that the national consolidated acquisition will result in the award of IDIQ contracts to multiple SDVOSB vendors on a competitive basis.

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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

Alexander Dowgiall VISN 1 Prosthetics Health Specialist VISN 1 VA New England Healthcare System

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

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

Gail Grundy Date Contracting Officer

NCO 1/ RPO EAST

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

Cory Dionne Date Contracting Officer

NCO 1/ RPO EAST

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 $75 million) or approve ($750K to $75 million) for other than full and open competition.

Gerald F. Jacobs Date Executive Director, Regional Procurement Office East VHA Head of Contracting Activity (HCA)

May 2, 2025

ALEXANDER

DOWGIALLO

Digitally signed by

ALEXANDER DOWGIALLO

Date: 2025.05.02 08:30:20 -04'00'

GAIL

GRUNDY

Digitally signed by

GAIL GRUNDY

Date: 2025.05.02 09:25:58 -04'00'

CORY DIONNE Digitally signed by CORY DIONNE Date: 2025.05.05 06:34:21 -04'00'

GERALD

JACOBS

Digitally signed by

GERALD JACOBS

Date: 2025.05.21 10:14:29 -04'00'