P03 Lack of Competition Below SLAT JOTFOC.pdf

Lack of Competition - Memo to File

Version 11.10.22

DATE: 02/12/2026

TO: Reviewer

Lease Delegation Review Team General Services Administration (GSA)

FROM: Kevin Adkins Lease Contracting Officer

SUBJECT: LEASE # DMI 11027-001 Detroit MI, Detroit Vet Center

The anticipated annual rent for the subject lease delegation is $ 117,224.35, unserviced, and therefore meets the criteria of a Simplified Lease Acquisition Threshold (SLAT) lease. Pursuant to GSAM 570.2, a SLAT lease does not require a Justification for Other than Full and Open Competition (JOTFOC).

The below statutory authority, cost-based or mission-based rationale supports the lack of competition and documents the file per GSAM 570.203-2(b) for new and new/replacing leases; 570.402-1(a) for succeeding leases; 570.403(c)(1) for lease expansions; 570.404(b) for superseding leases; or 570.405(b) for lease extensions, based on one of the following selections:

☐ The proposed lease is for the purpose of providing health-care resources to

Veterans and the proposed lessor is an academic affiliate organization, institution, or a covered entity. 38 U.S.C. § 8103(h)(1) authorizes non-competitive lease procurements to academic affiliate organizations and institutions or covered entity organizations.

or

☒ The proposed new, new/replacing, succeeding, superseding, expansion, renewal or extension lease action will not be competed through full and open competition because the LCO has determined the space required by the agency is available from only one responsible source based on mission needs and procurement from any other source will result in substantial duplication of cost to the Government that is not expected to be recovered through competition and/or results in unacceptable delays in fulfilling the agency’s requirements. The determination that the requirement can only be met by one responsible source is supported by (select one):

☐ The proposed action is a lease extension. No further justification is required.

☒ No potentially acceptable alternative locations were identified through market research and sources sought advertisement (if required).

Market Research Conducted on the SBA DSBS site on 11/28/2025. This produced 79 Results using the NAICS code of 531120 with a setting to this NAICS

Lack of Competition - Memo to File

Version 11.10.22 being the primary NAICS code. The database does not feature tools in which specific services or other capabilities could be clearly discerned, thereby rendering the results inconclusive. There is also no supportive indication that all these parties would be interested in this requirement. None replied to the sources sought posting.

A Sources Sought Notice/Advertisement was posted on Contract Opportunities on 11/5/2025 with a response date of 11/19/2025. No responses were received to this notice. Only the incumbent lessor has indicated interest in this requirement by email on 09/18/2025. Because competition must offset the entire cost of moving to a new location a response from other vendors is highly unlikely.

Competitive solicitations were issued under RLP 36C25023R0018 and 36C25025R0005. No acceptable offers were received in response to these issuances.

The Incumbent lessor’s performance under Lease number VA215-15-L-0008, awarded for build out on 09/24/2015, has been determined to be adequate during the previous contract period. The Lease was for a five Year Firm Term, with a Five Year Soft term.

☐ Cost-based rationale The succeeding lease analysis tool was used to evaluate the expected costs of remaining in place against the costs of relocation to a new location. The analysis demonstrates that the Government could not expect to recover relocation and duplication costs through full and open competition. The expected cost savings for this action are $ which represents savings of $____/ABOA SF

☐ Mission based rationale

The agency’s mission for this location requires a unique location and cannot be satisfied through any alternative locations. The agency’s mission and justification for a unique location is summarized below:

Entering into a non-competitive lease for space or a non-competitive lease action for continued space requirements with the proposed lessor is in the best interest of the VA;

and the annual rent will be determined to be fair and reasonable.

Please do not hesitate to contact me with any questions at 317-988-1544.

Kevin Adkins Lease Contracting Officer