P03-redacted JA 36C259-21-AP-1403- Woodland Park CNH_Redacted.pdf

OFOC SOP Revision 11 Page 2 of 6 Original Date: 03/22/11 Revision 08 Date: 02/11/2021

4. 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 FAR 6.302-2;

( ) (3) Industrial Mobilization, Engineering, Developmental or Research Capability or Expert Services per FAR 6.302-3;

( ) (4) International Agreement per FAR 6.302-4 ( ) (5) Authorized or Required by Statute FAR 6.302-5;

( ) (6) National Security per FAR 6.302-6;

( ) (7) Public Interest per FAR 6.302-7;

5. Demonstration that the Contra s Unique Qualifications or Nature of the Acquisition Requires the Use of the Authority Cited Above (applicability of authority): Veterans Affairs Salt Lake Health Care System requires a CNH with the capability of providing high flow oxygen, ventilation and tracheostomy procedures within a five-mile radius of the VAMC. The proximity of five-miles from the VAMC is ideal for the transfer of patients as they stabilize but require additional follow-up medical care from the VAMC. Currently, the nearest respiratory facility is thirty miles away and a facility minutes away from the VAMC is of the utmost importance for VA care coordination.

Woodland Park Rehabilitation Care Center Facility is one of two CNH s within the required five-mile radius of the VAMC that has a ventilation and tracheostomy unit at their facility. St. Joseph Villa is the second CNH with these capabilities. However, St.

Joseph Villa has not been vetted through the VA process as a viable candidate for contracts. Woodland Park is currently granted Veterans Care Agreements through VASLCHCS. Three years ago, the VASLCHCS conducted an oversight visit on a veteran who was admitted to the Woodland Park ventilation unit via a Veterans Care Agreement. The facility passed the Veterans Satisfaction Survey with a four out of five score. Woodland Park also passed an overall inspection done when the program was searching for a CNH with a ventilation and tracheostomy unit within five miles of the VAMC approximately a year ago. At that time St. Joseph s Villa did not express interest in doing business with the VA. Lastly, Woodland Park Rehabilitation Care Center meets the VA s Office of Geriatrics responsibility metric of a two out f overall Medicare compare score with a three out five star quality of resident care score.

6. Description of Efforts Made to ensure that offers are solicited from as many potential sources as deemed practicable: A Sources Sought Notice was published in Contract Opportunities on February 26, 2021 and closed on March 12, 2021. An advanced search for SD/VOSB businesses was done on the Vendor Information Pages website for NAICS code 623110 and zip code 84148 to determine

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Revision 08 Date: 02/11/2021 if SD/VOSB offerors existed for this requirement. CNH facilities within a ten-mile radius of the VAMC were searched on Medicare.gov and called to verify if they could meet the governments need. An SBA Dynamic Search was also conducted for zip code 84148 and NAICS Code 623110.

The Sources Sought Notice resulted in one CNH response from the Avalon Healthcare Group sharing information about their Woodland Park Rehabilitation Care Center facility. Woodland Park looks to be capable of providing the governments need and is with-in the five-mile required radius of the VAMC. The VIP search resulted in zero SD/VOSB Businesses being found for the searched NAICS and zip code. The SBA search yielded zero results as well. Out of the eight-teen CNH facilities found and called on the Medicare.gov search, twelve did not have tracheostomy or ventilation capabilities, three were unresponsive and three did seem able to meet the requirement; St. Joseph Villa, Woodland Park and South Davis Specialty Care. However, South Davis Specialty Care was outside of the part five-mile radius and St. Joseph Villa has not been vetted through the VA process as a viable candidate for contracts.

As part of the acquisition process, a CNH must provide a current state license, insurance, and a copy of the state inspection. These documents are provided to the CNH Program coordinator for review and evaluation. The CNH Coordinator will either provide a recommendation to contract or state that the CNH did not receive a recommendation to contract. A redacted J&A will be posted on Contract Opportunities.

7. Determination by the Contracting Officer (CO) that the Anticipated Cost to the Government will be Fair and Reasonable: The Medicaid rates are used as the basis for pricing the CNH contracts. The Medicaid rates are established by each state based on national average. The VA Geriatrics and Extended Care Office through the VHA PM and VA pulse publishes an annual maximum allowable percentage that are applied to each RUGS IV category. The RUGS IV category identify the different levels of treatment. The add-on percentages are added to the basic Medicaid rate then applied to each RUGS IV category. The Medicaid rate and the VA add-on percentage make up the per diem rate paid for each Veteran. The line item structure will illustrate the different RUGS IV category and the add-on percentage and the total per diem rate for each level of care. After conducting research on the current Medicaid and RUGS IV rates, the CO has determined that the results are determined to be fair and reasonable when the add-on percentage agreed upon by both parties is at or under the maximum allowable percentage established by VA. The add-on percentages do not change through the life of the contract.

8. Description of the Market Research Conducted and the Results, or a Statement of the Reasons Market Research Was Not Conducted:

As previously described in Section six above, A Sources Sought Notice was issued on Beta.Sam on February 26, 2021 and closed on March 12, 2021. An advanced

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Revision 08 Date: 02/11/2021 search for SD/VOSB businesses was done on the Vendor Information Pages for NAICS code 623110 and zip code 84148. CNH facilities within a ten-mile radius of the VAMC were searched on Medicare.gov and called to verify if they could meet the governments need. An SBA Dynamic Search was also conducted for zip code 84148 and NAICS Code 623110.

The Sources Sought Notice resulted in one CNH response from the Avalon Healthcare Group sharing information about their Woodland Park Rehabilitation Care Center facility. Woodland Park looks to be capable of providing the governments need and is with-in the five-mile required radius of the VAMC. The VIP search resulted in zero SD/VOSB Businesses being found for the searched NAICS and zip code. The SBA search yielded zero results as well. Out of the eight-teen CNH facilities found and called on the Medicare.gov search, twelve did not have tracheostomy or ventilation capabilities, three were unresponsive and three did seem able to meet the requirement; St. Joseph Villa, Woodland Park and South Davis Specialty Care. However, South Davis Specialty Care was outside of the part five-mile radius and St. Joseph Villa has not been vetted through the VA process as a viable candidate for contracts.

Lastly, CNH's are not competed. Based on the CNH program requirements, the Veterans preference is taken into consideration when selecting a CNH. The CNH selection is based on the Veteran needs, proximity to home/residence and family.

The CNH Program Coordinator is required to conduct a clinical and life safety inspection to ensure the CNH has the resources availa needs. The CNH Program Coordinator is responsible for conducting market research and required inspections to increase the number of available and qualified CNH's that can pass the Government's inspections before a contract can be established. However, in the current COVID environment, Government inspections are not being conducted and Medicare Compare Scores are being utilized in their place

9. Any Other Facts Supporting the Use of Other than Full and Open Competition:

While one other CNH, St. Joseph Villa, has been identified in the area of the proposed CNH, it has not been vetted by the CNH Coordinators to determine if they have the required services via clinical and life safety inspection. An Inspection of Woodland Park s facility was conducted prior to COVID and before the Medicare Compare Scores took precedent. At that time and currently Woodland Park has and is treating multiple Veterans under VCA s. Although St. Joseph Villa s Medicare Compare Score of five of five stars is better than Woodland Parks two of five stars, St. Joseph Villa has stated that they currently are not admitting new patients. Based on the CNH program requirements, the Veterans preference is taken into consideration when selecting a CNH. The CNH selection is based on the Veteran s needs, proximity to home/residence and family. Pre-Covid, the CNH Program Coordinator was required to conduct a clinical and life safety inspection to ensure the CNH has the resources available to meet the pat However, Medicare Compare Scores have now taken precedent until inspections resume.

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Revision 08 Date: 02/11/2021

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

Only Woodland Park Rehabilitation Care Center Facility responded to the sources sought notice published on 26 February 2021.

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: There is currently only one facility capable of providing the specialty of care and medical needs the VASLCHCS requires, which is for the CNH to have a tracheostemy and ventilation unit. Also, based on the CNH program requirements, the Veterans preference is taken into consideration when selecting a CNH based on the Veteran s needs, proximity to home/residence and family. The CNH Program attempts to inspect a sample of CNH's in a given area to provide the Veterans with several choices. However, the selection of the CNH is determined on whether the CNH has the resources available to meet each Veteran's needs. The CNH Program Coordinator is responsible for conducting market research and required inspections to increase the number of available and qualified CNH's that can pass the Government's inspections. However, in the current COVID environment, Government inspections are not being conducted and Medicare Compare Scores are being utilized in their place. The contracting office and CNH Program office will continue to canvas the market for new CNH entrants capable of meeting program requirements.

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