P03 - SDVOSB Sole Source Justification-Approved.pdf

PIID: 36C263-25-AP-4283

NCO 23 Acquisition Services

VHAPG Part 819.7008/7009 Sole Source Awards to SDVOSB/VOSB Page 1 of 4

Revision: 04

Effective Date: 11/15/2024

DEPARTMENT OF VETERANS AFFAIRS

Justification and Approval (J&A)

For

Other Than Full and Open Competition (>SAT)

Acquisition Plan Action ID: 36C263-25-AP-4283

1. Contracting Activity:

The contracting activity for this requirement is the Department of Veterans Affairs, Veterans Health

Administration (VHA) Network 23 Contracting Office (NCO 23).

2. Nature and/or Description of the Action Being Processed:

This is a new firm-fixed-price requirement. The contractor shall provide program analyst, program management, and acquisition support services throughout the duration of this contract. All services provided are for NCO 23. The contractor shall deliver non-personal, non-inherently governmental advisory services to support the VA’s Contracting Officers (COs), Contract Specialists (CS), and

Contracting Officer Representatives (CORs). Under no circumstances will any contractor perform program analyst or consultant functions that are inherently governmental, as outlined in Federal

Acquisition Regulation (FAR) part 7.503(c)(12). All contractor services shall comply with applicable public laws, statutes, VA policies, and procedures.

3. Description of Supplies/Services Required to Meet the Agency’s Needs:

The contractor shall provide program analyst, program management, and acquisition support services throughout the duration of this requirement. The contractor shall deliver non-personal, non-inherently governmental advisory services to support the VA’s Contracting Officers (COs), Contract Specialists

(CS), and Contracting Officer Representatives (CORs). Under no circumstances will any contractor perform inherently governmental functions, as outlined in Federal Acquisition Regulation (FAR) part

7.503(c)(12). All contractor services shall comply with applicable public laws, statutes, VA policies, and procedures. The period of performance is one year, with an estimated start date of September 30, 2025, and an end date of September 29, 2026. The estimated cost of this work is $3,000,000 and will have a period of performance of approximately one year.

4. Statutory Authority Permitting Other than Full and Open Competition: 41 USC §3304(a)(5), 38

U.S. Code § 8127(c), as implemented by FAR 6.302-5 (Authorized or Required by Statute). COs may use the non-competitive (sole source) procedures authorized in VAAR 819.7008 (DEVIATION) or VAAR 819.7009 (DEVIATION)- up to $5,000,000. Check the specific VAAR clause used below:

(X) 819.7008 Sole source awards to a verified services disabled veteran-owned small business; or

( ) 819.7009 Sole source awards to a verified veteran-owned small business

5. Demonstration that the Contractor’s Unique Qualifications or Nature of the Acquisition

Requires the Use of the Authority Cited Above (applicability of authority):

Veterans Management Services, Inc. (VMSI) has historically and currently provided similar services across the Department of Veterans Affairs and has consistently performed those services at a level https://www.va.gov/oal/library/vaar/vaar819.asp#8197008 https://www.va.gov/oal/library/vaar/vaar819.asp#8197009

VHAPG Part 819.7008/7009 Sole Source Awards to SDVOSB/VOSB Page 1 of 4

Revision: 04

Effective Date: 11/15/2024 higher than expected, earning an overall CPARS rating of “Exceptional” on their last eight contract evaluations.

36C77625P0004 Exceptional

36C77624D0011 Satisfactory

36C24723P1352 Exceptional

1282B123F0119 Exceptional

36C79123F0001 Exceptional

36C77623D0007 Satisfactory

36C77623N1240 Exceptional

36C24723P1352 Exceptional

VSMI, although not currently providing services for NCO 23, has successfully performed two contracts for the same services over the course of a year and a half at an exceptional performance level. Not utilizing a contractor like VSMI could negatively impact patient care, as their proven track record demonstrates a capability to deliver high-quality services that are essential for maintaining optimal patient outcomes. Consistent and reliable support from experienced contractors can greatly enhance the quality of care provided to patients.

Additionally, with the expected increase in workload for fiscal year 2026, we need contractor support from a provider like VMSI to effectively manage the work and maintain high-quality services.

Moreover, VAAR 819.7008 authority authorizes sole source awards to SDVOSB/VOSB based on 38

U.S.C. 8127(c), provided that the SDVOSB/VOSB concern has been deemed a responsible source regarding performance.

6. Description of Efforts Made to ensure that offers are solicited from as many potential sources as deemed practicable, including whether a notice was or will be publicized as required by FAR

Subpart 5.2 and, if not, which exception under FAR 5.202 applies:

A determination that only one SDVOSB can meet the requirement is not required in accordance with

VAAR 819.7008. No effort was made to solicit multiple sources as the circumstances surrounding the need date for award of the requirement didn’t allow for the time to do so. VSMI a highly qualified contractor, was immediately solicited upon receipt of the requirements. A notice of intent to sole source was posted to Sam.gov on 9/17/2025. but was subsequently cancelled on 9/25/2025 as such notice is not required. Synopsizing of this requirement is exempt under FAR 5.202(a)(4) – The proposed contract action is expressly authorized or required by a statute to be made through another

Government agency, including acquisitions from the Small Business Administration (SBA) using the authority of section 8(a) of the Small Business Act (but see 5.205(f)), or from a specific source such as a workshop for the blind under the rules of the Committee for Purchase from People Who Are

Blind or Severely Disabled").

7. Determination by the CO that the Anticipated Cost to the Government will be Fair and

Reasonable:

VMSI has been awarded multiple contracts for these types of services indicating they have an extensive record of providing fair and reasonable prices to receive awards. Their ratings within the

Contractor Performance Assessment Reporting System (CPARS) for cost control also provide a snapshot of fiscal responsibility as the majority of the ratings provided range from satisfactory to exceptional. The CO anticipates the prices received will be fair and reasonable and the rates will be compared to similar services from previous acquisitions and the General Services Administration

(GSA) schedule for acquisition services.

VHAPG Part 819.7008/7009 Sole Source Awards to SDVOSB/VOSB Page 1 of 4

Revision: 04

Effective Date: 11/15/2024

8. Description of the Market Research Conducted and the Results, or a Statement of the Reasons

Market Research Was Not Conducted:

Due to the need date and sole source authority for this requirement, market research was limited verifying that there were no mandatory sources capable of providing these services. VMSI met the eligibility criteria outlined in VAAR 819.7003 (DEVIATION) as they are a SBA verified SDVOSB, the requirement is under $5M, they are responsible and qualified, and it is anticipated that an award can be made at a fair and reasonable price.

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

None.

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

None.

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:

NCO 23 will solicit future projects for the same or similar types of requirements through competitive channels, as appropriate.

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

______JOHNSON ____________10:30 :35 -05'00' ___________

Travis A. Johnson Division Chief – Division 1 Network 23 Contracting Office

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

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

Date

______MILROY ________10:35:29 ______-05'00' __________

John Milroy

Contracting Officer

Network 23 Contracting Office

TRAVIS

Digitally signed by

TRAVIS JOHNSON

Date: 2025.09.25 9/25/25

JOHN

Digitally signed by JOHN

MILROY

Date: 2025.09.25 9/25/25 https://dvagov.sharepoint.com/sites/VHAProcurement/VHAPM/VHAPM_Part_806.3.aspx

VHAPG Part 819.7008/7009 Sole Source Awards to SDVOSB/VOSB Page 1 of 4

Revision: 04

Effective Date: 11/15/2024

b. One Level Above the Contracting Officer (Required over SAT but not exceeding $750K):

I certify the justification meets requirements for other than full and open competition

c. Director of Contracting (Required with HCA Approval): I certify the justification meets requirements for other than full and open competition.

d. 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.

Date

______LAROSE ________10:40:33 ______-05'00' __________

Curt LaRose Branch Chief Network 23 Contracting Office

CURT

Digitally signed by CURT

LAROSE

Date: 2025.09.25 9/25/25

Scott J. Petrin

Date

Director of Contracting

Network 23 Contracting Office

SCOTT

PETRIN

Digitally signed by

SCOTT PETRIN

Date: 2025.09.25 10:44:33 -05'00' 9/25/25

__9/25/25 _____________________

Date

Daryl A. Berg

Executive Director, RPO Central

Head of Contracting Activity

DARYL

BERG

Digitally signed by DARYL BERG Date:

2025.09.25 12:50:35 -05'00'