P03_Sole Source Justification AP-4694_V2_HCA Signed.pdf

Request for SDVOSB/VOSB Sole Source Justification Format IAW VAAR 819.7008/9

VHAPG Part 819.7008/7009 Sole Source Awards to SDVOSB/VOSB Page 1 of 5 Revision: 05 Effective Date: 12/15/2025

36C241-26-AP-4694

DEPARTMENT OF VETERANS AFFAIRS

Justification and Approval (J&A) For

Other Than Full and Open Competition

Acquisition Plan Action ID: 36C241-26-AP-4694

1. Contracting Activity: Network Contracting Office 1, Regional Procurement Office East on behalf of the Department of Veterans Affairs, Veterans Integrated Service Networks (VISN 01). All VA medical centers are detailed in accordance with the table provided below on page 2. Funding has not yet been received. Funding, 402-27-1-9931-0001, 523-27-1-1020-0002, 650-27-1-108-0001, 631-27-1- 2911-0001, 689-27-1-642- 0003, 518-27-1-971-0001. 608-27-1-1026-0001, 405-27-1-923-0001, 402- 27-1-7202-0001, 523-27-1-7925-0001, 650-27-1-773-0003, 631-27-1-7922-0001, 689-27-1-654-0001, 518-27-1-7759-0001, 608-27-1-1031-0001, 405-27-1-7817-0001.

2. Nature and/or Description of the Action Being Approved: Veterans Integrated Service Network (VISN 1) currently has Contract No. 36C24126D0018 with P.D.S. CONSULTANTS, INC., a U.S.

Small Business Administration (SBA) Small Business Search (SBS) tool certified Service-Disabled Veteran-Owned Small Business (SDVOSB), for prescription eyeglass manufacturing and optician services. The current contract covers the manufacturing and delivery of both dress and safety prescription eyeglasses to include fitting services provided by a licensed optician for Veteran beneficiaries of VISN 1. The current contract expires on 09-30-2026. A short-term bridge procurement is required while the Agency is developing and awarding a long-term national consolidated solution.

The short-term bridge contract will ensure that there is no disruption in the availability of prescription eyeglasses for Veteran beneficiaries while the consolidated acquisition is being completed. Since this requirement entails direct patient care, ongoing services are required. An interruption of services is not an option as it would place Veteran patients at risk of not receiving care.

The Department of Veterans Affairs (VA) seeks approval for and anticipates the award of new indefinite delivery, indefinite quantity, firm-fixed price (FFP) contract. The period of performance will be 4 months (2-month base with 2-one month options), which will allow enough time for the long-term national solution to be awarded and will allow time for potential transition from the current contractor to a successor contractor. The estimated total value of the contract for the base period a is $4,214,643.50.

This is a repetitive sole source award to the same SDVOSB for the same or similar requirement pursuant to VAAR 819.7008. This requirement is exempt from the OSDBU review requirements in VAAM M806.304-70 Table M806.23, VHAPG 806.3 and VHAPG 819.7008 in accordance with the Memorandum for Record Exemption to the review and approval requirements of VA Acquisition Manual (VAAM) M806.304-70, Table M806.23, regarding sole-source contracts to be awarded on a repetitive basis for the provision of prescription eyeglass manufacturing and optician services to the same SDVOSBs approved by Mr. Curtis Jordan, Executive Director Procurement Operations dated 07-15- 2026.

3. Description of Supplies/Services Required to Meet the Agency’s Needs: The VA has an ongoing program to provide prescription eyeglasses (both dress and safety) to eligible veterans. The provision of corrective eyeglasses is required for eligible veterans to meet their optic and low vision medical needs. The VA eye clinic prescribes corrective lenses based upon a medical exam. The clinical judgement and assessment are used to determine medical necessity in conjunction with VHA Directive 2008-070 (Prescribing Hearing Aids and Eyeglasses) and 39 CFR 17.149 (Sensory-Neural Aids). Eyeglasses are not an emergent service and follow the administrative standard for assessment and procurement practices. The Contractor shall provide all labor and materials necessary to provide prescription eyeglasses and in-house (onsite at VA facilities) optician fitting services.

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The Contractor is to provide prescription eyeglasses including fitting services by a licensed optician according to contract specification for beneficiaries of the following sites of care and their entire catchment areas, within VISN 1.

4-Sight Software is used to consolidate individual locations to centralized funding source from station level.

The estimated quantities included in the short-term bridge contract will be based on the line-item usage data under the current contract.

Facility (Ordering Activity) Address

TOGUS (402)

Togus VA Medical Center 1 VA Center, Augusta, ME 04330-6796

Bangor VA Clinic 35 State Hospital Dr, Bangor, ME 04401

Lewiston VA Clinic 15 Challenger Dr, Lewiston, ME 04240-1041

Portland VA Clinic 141 West Commercial Street, Portland, ME 04102-3905

MANCHESTER (608)

Manchester VA Medical Center 718 Smyth Road, Manchester, NH 03104-7007

WHITE RIVER JUNCTION (405)

White River Junction VA Medical

Center 163 Veterans Drive, White River Junction, VT 05001-

Burlington Lakeside VA Clinic 128 Lakeside Ave Ste 260, Burlington, VT 05401

NORTHAMPTON (631)

Northampton VA Medical Center 421 N. Main Street, Leeds, MA 01053-9764

BOSTON (523)

Brockton VA Medical Center 940 Belmont Street, Brockton, MA 02301-5596 Jamaica Plain VA Medical Center 150 S. Huntington Avenue, Jamaica Plain, MA 02130-

West Roxbury VA Medical Center 1400 VFW Parkway, West Roxbury, MA 02132-4927

Causeway VA Clinic 251 Causeway Street, Boston, MA 02114-2104 Worcester VA Clinic 403 Belmont Street, 1st Floor, Worcester, MA 01604-1020

Lowell Outpatient Clinic 130 Marshall Rd, Lowell, MA 01852-5130

BEDFORD (518)

Bedford VA Medical Center 200 Springs Road Bedford, MA 01730-1114

CONNECTICUT (689)

West Haven VA Medical Center 950 Campbell Avenue, West Haven, CT 06516-2770

Newington VA Clinic 555 Willard Avenue, Newington, CT 06111-2631 John J. McGuirk VA Outpatient

Clinic 6 Shaw's Cove, Suite 104, New London, CT 06320-4969

PROVIDENCE (650)

Providence VA Medical Center 830 Chalkstone Avenue, Providence RI 02908-4734

Eagle Square VA Clinic 623 Atwells Avenue, Uncas Building, Providence, RI 02909-7403

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The period of performance will be 4 months which will allow enough time for the long-term national solution to be awarded and will allow time for potential transition from the current contractor to a successor contractor. The estimated total value of the contract for the base period is $4,214,643.50.

Period of Performance:

Base Period: 10/01/2026 – 11/30/2026 - $2,107,321.74 Option Period 1: 12/01/2026 – 12/31/2026 - $1,053,660.88 Option Period 2: 01/01/2027 – 01/31/2027 - $1,053,660.88

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

U.S. Code § 8127(c), as implemented by RFO 6.103-5 (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 certified service-disabled veteran-owned small business;

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

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

Requires the Use of the Authority Cited Above (applicability of authority): Under 38 USC 8127(c), VA has the authority to award a contract to an SDVOSB concern using procedures other than competitive procedures if three conditions are met: (1) the SDVOSB is determined to be a responsible source with respect to performance of such contract opportunity; (2) the anticipated award price of the contract, will not exceed $5,000,000; and (3) in the estimation of the Contracting Officer, the contract award can be made at a fair and reasonable price that offers best value to the U.S.

Without this short-term contract, Veteran beneficiaries of VISN 1 would not have access to prescription eyeglasses. Moreover, due to the complexities involved in a transition to another contractor who could provide the same or similar services, care would undoubtedly be disrupted and any gap in the continuity of services would have a detrimental impact on the Veterans. It is therefore necessary to provide continuous services from the incumbent contractor until national consolidated procurement is completed.

P.D.S. CONSULTANTS, INC, a verified SDVOSB concern, has been determined to be responsible in accordance with the general responsibility standards outlined in RFO Part 9. P.D.S. CONSULTANTS, INC, a prescription eyeglass manufacturer, has relevant experience providing prescription eyeglass manufacturing and optician services and is currently providing services in VISN 1 since 2019.

Furthermore, P.D.S. CONSULTANTS, INC can meet the requirements of this acquisition immediately upon award of the short-term contract.

P.D.S. CONSULTANTS, INC has certified that it will comply with the requirements of the Buy American Statute and the applicable Limitations on Subcontracting. P.D.S. CONSULTANTS, INC has certified it is a small manufacturer under applicable NAICS code 339115. P.D.S. CONSULTANTS, INC is a certified SDVOSB within the SBA SBS as confirmed by the Contracting Officer on 08-21-2026.

The Contracting Officer has determined that award will be made to P.D.S. CONSULTANTS, INC at a fair and reasonable price. The Contracting Officer utilized the pricing under the current contract as well as other procurements of prescription eyeglass manufacturing and optician services where prices were previously determined to be fair and reasonable to assist in the determination that the pricing for this short-term contract is fair and reasonable.

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 RFO 6.301 and, if not, which exemption under RFO 5.101(b)(1) applies: The Contracting Officer’s determination to award a short-term contract on a sole source basis is a business decision https://www.va.gov/oal/library/vaar/vaar819.asp#8197008 https://www.va.gov/oal/library/vaar/vaar819.asp#8197009 https://www.acquisition.gov/far-overhaul/far-part-deviation-guide/far-overhaul-part-6#FAR_6_301 https://www.acquisition.gov/far-overhaul/far-part-deviation-guide/far-overhaul-part-5#FAR_5_101

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wholly within the discretion of the Contracting Officer. Procuring the short-term requirement on a competitive basis is not feasible. VA has statutory authority to procure this requirement from a verified SDVOSB concern on a sole source basis IAW 38 USC § 8127(c). It is in the Government’s best interest to solicit from one contractor, P.D.S. CONSULTANTS, INC, the incumbent for the short-term contract to ensure there is no interruption of services while the national consolidated acquisition is going through the procurement process.

7. Determination by the CO that the Anticipated Cost to the Government will be Fair and Reasonable: The Contracting Officer has determined the offered pricing for the short-term bridge contract is fair and reasonable based on a comparison to historical pricing data for these same services in VISN 1. The unit prices in the short-term bridge contract will remain the same as the unit prices included in the current contract. The existing prices under the current contract were determined fair and reasonable prior to award.

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

Market Research Was Not Conducted: Market research indicates that the incumbent P.D.S.

CONSULTANTS, INC is an SBA verified SDVOSB and available to begin performance under the short-term contract on 08-21-2026. Further market research has not been performed for this requirement.

9. Any Other Facts Supporting the Use of Other than Full and Open Competition: None. VA has statutory authority to procure this requirement from a verified SDVOSB concern on a sole source basis in accordance with 38 USC 8127(c).

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

SDVOSB sources include P.D.S CONSULTANTS, INC.

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:

The Department of Veterans Affairs (VA) anticipates the award of new multiple, firm-fixed-price with economic price adjustment, indefinite delivery, indefinite quantity (IDIQ) contracts resulting from national consolidated acquisition for the nation. Details regarding this requirement can be located at Acquisition Plan ID 36C241-26-AP-0017. VA further anticipates that the national consolidated acquisition should be completed by October 31, 2026, and implementation of the national contract is anticipated throughout 2026 and the beginning of 2027.

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.

Alexander Dowgiallo Date VISN 1 Prosthetics Health Specialist VISN 1 VA New England Healthcare System

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

a. 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.

Gail Grundy Date Contracting Officer

NCO 1/ RPO EAST

https://dvagov.sharepoint.com/sites/vhapromanual/SitePages/VHAPM-Part-806.3.aspx

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b. One Level Above the Contracting Officer (Required over the SAT but not exceeding $900K): I certify the justification meets requirements for other than full and open competition.

Cory Dionne Date Contracting Officer

NCO 1/ RPO EAST

c. 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 $90 million) or approve ($900K to $90 million) for other than full and open competition.

Brent Goe Date Acting Executive Director Regional Procurement Office East VHA Head of Contracting Activity (HCA) Contracting Activity Advocate for Competition