P03 Justification _ Approval.pdf

OFOC SOP Revision 09 Page 1 of 5 Original Date: 03/22/11 Revision 09 Date: 04/17/2020

DEPARTMENT OF VETERANS AFFAIRS

Justification and Approval (J&A) For

Other Than Full and Open Competition (>SAT)

Acquisition Plan Action ID: 36C241-20-AP-2055

Contracting Activity: Department of Veterans Affairs, VA Connecticut Healthcare System, 950

Campbell Street, West Haven CT 06516

2237: 523-20-4-2765-0184

Nature and/or Description of the Action Being Processed: The VISN 1 Healthcare System requires Phlebotomy and Urine Collection Services for the following location:

Middletown CBOC, One Corporate Place (West Main Road at Northgate Road), Middletown, RI 02842

This will be a firm-fixed-price Blanket Purchase Agreement for 5-years to provide specimen collection services within a 4-mile radius of the listed location. After collection of the specimens at the contractor’s facility, they will be transported by the VA Carrier to the Providence VA Medical Center for testing.

Description of Supplies/Services Required to Meet the Agency’s Needs: Phlebotomy services as well as collection of urine specimens as needed for patients presenting with orders from the Middletown CBOC, processing of such specimens to the extent needed to preserve the specimen integrity and packaging for pick up by STAT courier (or current contracted courier) for all specimens to be transported to VA Providence for testing. See PWS for details of requirements. East Side Clinical Lab can provide this service at a nearby convenient site to the Middletown CBOC. Our requirement is to have collection services within 4 miles of the CBOC. Past practice has shown patient compliance is low if specimen collection is >4 mi from the CBOC.

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

(X) (1) Only One Responsible Source and No Other Supplies or Services Will Satisfy

Agency Requirements per 41 USC §3304(a)(1) as implemented by FAR 6.302-1;

( ) (2) Unusual and Compelling Urgency per 41 USC §3304(a)(2) as implemented by FAR 6.302-2;

( ) (3) Industrial Mobilization, Engineering, Developmental or Research Capability or Expert Services per 41 USC §3304(a)(3) as implemented by FAR 6.302-3;

( ) (4) International Agreement per 41 USC §3304(a)(4) as implemented by FAR 6.302-4 ( ) (5) Authorized or Required by Statute per 41 USC §3304(a)(5) as implemented by FAR 6.302-5;

( ) (6) National Security per 41 USC §3304(a)(6) as implemented by FAR 6.302-6;

( ) (7) Public Interest per 41 USC §3304(a)(7) as implemented by FAR 6.302-7;

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Revision 09 Date: 04/17/2020

Demonstration that the Contractor’s Unique Qualifications or Nature of the Acquisition Requires the Use of the Authority Cited Above (applicability of authority): East Side Clinical Lab has performed this function as the contracted vendor for blood draw and specimen collection since 2012. Maintaining this site as the specimen collection station provides continuity of services to the Middletown CBOC patients who have multiple medical problems/issues. It would be a hardship for them to go to a location that is in a different location from the site where these services have been rendered. We require specimen collection services to be located within 4 miles of the CBOC. Past practice has shown that there is low compliance for patients that must travel far for their blood draw and other specimen collection services. East Side Clinical Lab meets this requirement. In addition, many patients from Middletown CBOC rely on family and friends for transportation to the Middletown CBOC. A change in lab services would pose an additional obstacle for our veterans serviced by this CBOC. The Primary Care staff at Middletown CBOC find the current arrangement with East Side Clinical Lab meets their needs and the needs of their patients.

Description of Efforts Made to ensure that offers are solicited from as many potential sources as deemed practicable: Prior to last award, research was performed to find any other labs or service centers that were available in this region to provide this service. It was determined that no others were located at a convenient site to accommodate the Middletown CBOC patients ensuring a high compliance for blood draws and specimen collections after being seen at the CBOC. This convenient location has demonstrated over the term of the past agreement that both the patients and staff from the Middletown CBOC are receiving quality service from East Side Clinical Lab and traveling to a different location for this service would jeopardize patient care. Research found additional businesses in the area for consideration.

Name of Offeror Name and Address of Building East Side Clinical Laboratory Inc.

10 Risho Ave, East Providence, RI 02842

Southco st Health 672 Aquidneck Ave, Middleton, RI 02842 Ocean State Urgent Care 67 Valley Road, Middleton, RI 02842

Determination by the CO that the Anticipated Cost to the Government will be Fair and Reasonable:

This procurement of Phlebotomy and Specimen Collection Services for the location indicated in section 2 of this document is needed for veterans that would need to travel 4 miles for blood draw and specimen collections. Many of veterans are seasoned, and is problematic especially in the more rural areas. This service allows veterans to have needed specimen collection performed they’re at their convenience. Based on the market research, the centralized location is acceptable for the blood collection service and meets all VA Guidance. The previous BPA ceiling was $255,000.00 for 5-years. The expected new BPA ceiling will be $259,250.00 with an increase of less than 2% over the next 5-years. This anticipated cost to the government is fair and reasonable.

Description of the Market Research Conducted and the Results, or a Statement of the Reasons Market Research Was Not Conducted: An internet search was conducted for specimen collection services located within a 4 mile radius of the Middletown CBOC. That search revealed 2 vendors, East Side Clinical Laboratory and Southcoast Health . Of the two, only East Side Clinical Lab was willing to provide these services. East Side Clinical Lab has been providing this service from its current location since 2012. This has been ideal to serve the veterans from the Middletown CBOC.

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Revision 09 Date: 04/17/2020

Past practice has shown that there is low compliance for patients that have to travel far to unknown locations for their blood draw and other specimen collection services. East Side Clinical Lab is within 4 miles of Middletown CBOC. Additional market research was conducted by this office. A search was conducted on the Vendor Information Page (VIP). 52 contractors were found, all were sent a request for information. The following contractors responded; Millbrook (SDVOSB), EGA Associates LLC.

They both indicated the inability to provide the service. A search of the General Service Administration (GSA) website found Medical & Healthcare Staffing and Testing & Analysis Testing Services under Schedule 621 I & II but were not specific to the area and need. Search was conducted on the National Acquisition Center website, Phlebotomy and Urine Collection Services were not offered. Reached out via e-mail to the following companies in the area; East Side Clinical Laboratories, Southcost Laboratories, Lifespan Urgent Care, Roger Williams Medical Center, and Quest Diagnostics Inc.

• East Side Clinical Laboratories (Small Business) – Responded they could provide the service

• Southcoast Laboratories – Responded they would not participate

• Lifespan – Did not respond, not registered in SAMs

• Prospect Chartercare RWMC LLC (DBA: Roger Williams Medical Center) – Did not respond, not registered in SAMs

• Quest Diagnostics Inc (Large Business), Responded, declined to participate in providing the service

A Sources Sought Notice was posted (36C24120Q0387). Received two response; Firm Healthcare Systems LLC (SDVOSB), and Legacy Group & Associates Inc. Firm Healthcare Systems LLC wanted to participate but did not provide specifics of how they would meet the requirement in accordance to the Performance Work Statement. Their proposal was to send staff to area facility locations within the 4-mile radius to collect the specimens. A FedDataCheck was completed using their DUNS number. They do have a contract with a VA (36C26320P0521) for Personal Protection Equipment for 620K, but no contracting experience or history in Phlebotomy & Urine Collection Services. They were asked to provide a list of locations within the coverage area but declined to submit that information until a contract was awarded. Legacy Group & Associates Incorporated indicated that they would work with Sequential Medical & Information Solutions to provide the service. Legacy was requested to provide a site location. They provided 67 Valley Road, Middletown RI 02842.

Ocean State Urgent Care was listed. According to the company, they only offered urgent care services, not outpatient specimen collection service. The VA is looking to provide this service at the time of the current expiration o, there is no lapse in patient care.

8. Any Other Facts Supporting the Use of Other than Full and Open Competition: East Side Clinical can provide the service within a 4-mile radius for veterans that would need to travel further if they had the service at a VA Site. This will alleviate long drives for veterans that may have difficulties

, and their caretakers. There were no other companies willing to work with the VA in the area that met all the requirements necessary to attend to our veterans. As indicated in section 7, several of the businesses declined to participate, not SAMs registered, or did not provide additional information requested to confirm their capability. Base on the independent government cost

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Revision 09 Date: 04/17/2020 estimate, there is only a 2% increase from the previous Blanket Purchase Agreement, which is acceptable to the government.

9. Listing of Sources that Expressed, in Writing, an Interest in the Acquisition: The following businesses expressed interest; East Side Clinical Laboratories (Small Business) and Firm Healthcare Systems LLC. (SDVOSB).

10. 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 VA will continue to reach out as indicated in section 7 of this document. Companies were found in the area but chose not to participate at this time. Prior to the expiration of the new Blanket Purchase Agreement, the VA will consider that there are other businesses on the market. At that time the same methods will be taken to seek out competition.

11. 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

Approvals in accordance with the VHAPM Part 806.3 OFOC SOP:

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.

Date

Julie A. Lemire 149432 Digitally signed by Julie A. Lemire 149432 Date: 2020.07.28 12:29:10 -04'00'

Janet L. Lane 150483

Digitally signed by Janet L.

Lane 150483 Date: 2020.07.28 19:50:28 -04'00'

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Revision 09 Date: 04/17/2020

b. One Level Above the Contracting Officer (Required over SAT but not exceeding $700K): I certify the justification meets requirements for other than full and open competition.

Date

Linda Ward Branch Chief NCO 1, Supply Team South

Manchester

Linda J. Ward 155235 Digitally signed by Linda J. Ward 155235 Date: 2020.07.28 22:21:11 -04'00'