P03 Sole Source Justification 520-26-109 v1Redacted.pdf

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Z1DZ--520-26-109 Replace Fire Suppression Piping in Crawl Space, Biloxi (Emergency)
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36C25626C0035
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This is a Justification and Approval (J&A) document for other than full and open competition for a Department of Veterans Affairs procurement.

The Gulf Coast Veterans Health Care System (GCVHCS) in Biloxi, Mississippi requires urgent fire suppression system repairs in Building 2's crawlspace. The work includes temporary repairs to approximately 10 linear feet of damaged 6-inch piping on the west end, complete demolition of all existing 6-inch fire suppression system piping with associated fittings, valves, and hangers, and furnishing and installation of new 6-inch piping with new fittings, three check valves, one flow switch, and hangers in the original location. The new flow switch and check valves must be coordinated with the Contracting Officer Representative and tied into the facility alarm system managed by Everon (Fire and Life Safety contractor). The estimated contract value is $274,455.00 with a firm-fixed-price structure and a 30-calendar-day period of performance from issuance of the Notice to Proceed.

The procurement is justified under 41 USC §3304(a)(2) for unusual and compelling urgency, as conducting competitive procurement would add approximately 60 days, which is infeasible given ongoing damage and associated risks to patient safety. The sole source award is to Paramount Construction Group (PCG), a Service-Disabled Veteran-Owned Small Business (SDVOSB) with prior experience at GCVHCS, based on their specialized expertise, site familiarity, strict adherence to safety and infection control protocols, and ability to mobilize within one week. Market research identified 15 potential SDVOSB/VOSB firms with NAICS 236220 capabilities, but the urgency precluded competitive solicitation. The action will not be synopsized on SAM.gov per FAR 5.202(a)(2). The Contracting Officer anticipates fair and reasonable pricing based on comparison to an Independent Government Cost Estimate.

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VHAPG Part 806.3 OFOC Page 1 of 4 Revision: 04 Effective Date: 12/15/25 Acquisition ID#: 36C256-26-AP-3249

DEPARTMENT OF VETERANS AFFAIRS

Justification and Approval (J&A) For

Other Than Full and Open Competition

Acquisition Plan Action ID: 36C256-26-AP-3249

1. Contracting Activity: Department of Veterans Affairs Network Contracting Office 16 (NCO 16) 400 Veterans Avenue Biloxi, MS 39531-2410

Organizational Activity: Gulf Coast Veterans Health Care System (GCVHCS) 400 Veterans Avenue Biloxi, MS 39531-2410

2237 Number/Funding: 520-26-3-7528-0001

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

This urgent, one-time firm-fixed-price sole source requirement addresses the complete removal and replacement of all fire suppression system piping (including associated fittings, valves and hangers) located in Building 2 crawlspace.

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

To meet the needs of the GCVHCS repairs, the following supplies and services are required:

1. Replace/repair approximately 10LF section of damaged 6” piping on the west end of crawl space under Building 2. The intent to make these temporary repairs immediately upon contract award and to restore the fire suppression system to the building, which will allow VA staff to reoccupy the building.

2. Demo all existing 6” fire suppression system piping (including all associate fittings, valves, and hangers) located in crawl space of Building 2.

3. Furnish and install all new 6” piping to be replaced near original location (direct replacement). New work to include new 6” piping, fittings, (3) check valves, (1) flow switch, and hangers. Coordinate location of new flow switch and check valves with COR. The new flow switch and check valves will need to be tied and programed into the facility alarms which is managed by Everon (Fire and Life Safety contractor).

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VHAPG Part 806.3 OFOC Page 2 of 4

Acquisition ID#: 36C256-26-AP-3249

Period of Performance (POP) for this project is 30 calendar days from issuance of Notice to Proceed (NTP).

Estimated Value: $274,455.00

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

( ) (1) Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements per 41 USC §3304(a)(1) as implemented by

RFO 6.103-1;

(X) (2) Unusual and Compelling Urgency per 41 USC §3304(a)(2) as implemented by RFO 6.103-2;

( ) (3) Industrial Mobilization, Engineering, Developmental or Research Capability or Expert Services per 41 USC §3304(a)(3) as implemented by RFO 6.103-3;

( ) (4) International Agreement per 41 USC §3304(a)(4) as implemented by RFO 6.103-4

( ) (5) Authorized or Required by Statute per 41 USC §3304(a)(5) as implemented by RFO 6.103-5;

( ) (6) National Security per 41 USC §3304(a)(6) as implemented by RFO 6.103-6;

( ) (7) Public Interest per 41 USC §3304(a)(7) as implemented by RFO 6.103-7;

5. Demonstration that the Contractor’s Unique Qualifications or Nature of the Acquisition Requires the Use of the Authority Cited Above (applicability of authority):

This requirement is justified for other than full and open competition under FAR 6.302-2 due to the unusual and compelling urgency arising from piping damage in the west-end crawl space under Building 2 at the GCVHCS. Conducting a competitive procurement would add an estimated 60 days, which is not feasible given the ongoing damage and associated risks. Paramount Construction Group (PCG), a verified SDVOSB with prior experience at GCVHCS, is the most suitable contractor because they possess the specialized expertise needed for complete removal and replacement of all fire suppression system piping, adhere to strict safety and infection control protocols, and can mobilize within one week. Their unique qualifications, familiarity with the site, and ability to meet the project’s technical and safety requirements support the use of the cited authority for a sole-source emergency award.

Due to the facts outlined above, if this emergency work under unusual and compelling urgency is not awarded to PCG it will harm hospital operations which in turn will affect patient safety.

6. Description of Efforts Made to ensure that offers are solicited from as many potential sources as possible (including whether a notice was or will be publicized as required by RFO Part 5 and, if not, which exception under RFO Part 5 applies):

https://www.acquisition.gov/far-overhaul/far-part-deviation-guide/far-overhaul-part-5 https://www.acquisition.gov/far-overhaul/far-part-deviation-guide/far-overhaul-part-5 https://www.acquisition.gov/far-overhaul/far-part-deviation-guide/far-overhaul-part-5 VHABILTynesT Sticky Note Accepted set by VHABILTynesT

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VHAPG Part 806.3 OFOC Page 3 of 4

Acquisition ID#: 36C256-26-AP-3249

Market research conducted with Small Business Administration Dynamic Small Business Search (SBA DSBS) demonstrates that 15 SDVOSB/VOSB certified with NAICS 236220 with potential capabilities to perform this work. However, due to the unusual and compelling urgency regarding this requirement, this will be sole sourced to PCG, as to not affect patient safety.

Per FAR 5.202, the Contracting Officer need not submit the notice required by 5.201 when (FAR 5.202(a)(2), The proposed contract action is made under the conditions described in 6.302-2 and the Government would be seriously injured if the agency complies with the time periods specified in 5.203. Due to the unusual and compelling urgency of this action, the action will not be synopsized.

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

Based on historical data, there is reasonable expectation that a fair and reasonable cost can be negotiated. In addition, the Contracting Officer anticipates cost will be considered fair and reasonable based on comparing finalized cost to the Independent Government Cost Estimate (IGCE).

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

Limited market research was performed using SBA DSBS for SDVOSB using NAICS 236220, and with FPDS. The recommended sole source award source, PCG, an SBA certified SDVOSB, was able to immediately diagnose and provide market research pricing for the work. There are no known Buy American Act exceptions to this requirement.

The contract incorporates FAR 52.225-9 and confirmation of the materials will be made upon submittal review by the Gulf Coast Engineering group. If there are concerns that materials do not meet the Buy American Act, the appropriate measures will be taken by the Engineers and/or the Contracting Team to mitigate the use of improper materials.

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

None at this time.

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

Paramount Construction Group 2301 US 51 Building 100 Madison, MS 39110 POC: Jonathan McDaniel, President or Adam Fowler, Vice President Email: jonathan@pcgcontracting.com or Adam@pcgcontracting.com

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VHAPG Part 806.3 OFOC Page 4 of 4

Acquisition ID#: 36C256-26-AP-3249

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:

Any future requirements, including regular maintenance and inspection of the roof to provide a permanent solution to the deterioration issue, will be procured competitively based on the mission needs.

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.

Brandon O’Neal Date Contracting Officer Representative (COR) General Engineer / Healthcare Engineer

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.

Jennings (JB) Herbst Date Senior Contracting Officer

NCO 16

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2026-04-27T14:41:36-0500
JENNINGS HERBST
2026-04-27T14:50:34-0500
BRANDON O'NEAL

File details come from the government source that posted it. Updated .