P03 - Sole Source Justification CLEAN_Redacted (1).pdf

Effective Date: 12/30/2025 Page 1 of 5 Revision: 02 Acquisition ID#: 36C776-26-AP-1784

DEPARTMENT OF VETERANS AFFAIRS

SOLE SOURCE JUSTIFICATION UNDER SIMPLIFIED PROCEDURES FOR CERTAIN COMMERCIAL

ITEMS IN ACCORDANCE WITH FAR 13.5

Acquisition Plan Action ID: 36C776-26-AP-1784

1. Contracting Activity: Department of Veterans Affairs,

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

This procurement is for renewal of an organizational membership and enterprise data license to the Medical Group Management Association (MGMA) DataDive� benchmarking platform and associated datasets, in support of VHA-wide practitioner productivity benchmarking requirements.

This acquisition is conducted in accordance with RFO Part 12, Acquisition of Commercial Products and Commercial Services, which exempts acquisitions conducted under Simplified Acquisition Procedures from RFO 6.104 but requires a justification using the format of RFO 6.104-2.

This action will be awarded as a new, firm-fixed-price contract for one base year with two one-year option periods. The estimated base year value is

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

The Veterans Health Administration (VHA) requires an MGMA Organizational Membership providing enterprise access to the most recent version of all MGMA DataDive� surveys and datasets. The membership provides benchmarking data and statistics in the areas of physician compensation, staffing, cost and revenue, and CPT coding, as well as educational resources and best practices supporting continuous process improvement in clinic management.

This contract enables VHA to implement the national policy mandated by 38 U.S.C. §§ 1706A and 8110(a)(3)(C) � which requires VA to monitor and assess specialty provider group practice staffing and productivity � under VHA Directive 1065. The MGMA DataDive� platform provides the productivity targets, benchmarking data, and educational resources necessary to measure provider productivity across medical facilities and benchmark performance against industry standards.

The membership directly supports VHA's Fiscal Responsibility Action Team (FRAT), and specifically FRAT Workstream 2.1 (Implement Enterprise Productivity Goals and Accountability Standards), which relies on MGMA productivity targets to enhance financial governance, optimize resource allocation, and drive cost efficiency across the organization. VHA's Governing Board has selected MGMA benchmarks as the basis for new productivity targets for VHA practitioners, established across the system via the Ready-Set-Go Campaign. VHA leadership at all levels relies on this data to evaluate clinical productivity, ensure adequate staffing, and identify improvement opportunities in administrative and management functions supporting timely, safe, high-quality Veteran care.

Specific deliverables include:

Electronic Organizational Membership access and credentials within 5 business days of contract award

Quarterly utilization reports documenting active users, datasets accessed, and any service disruptions, due within 15 calendar days following the end of each contract quarter

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Acquisition ID#: 36C776-26-AP-1784

Estimated values:

Base Year:

Option Year 1:

Option Year 2:

Total Estimated Value (Base + All Options):

Period of Performance: One base year from date of award, with two one-year option periods.

4. Statutory Authority Permitting Restricted Competition:

RFO Part 12, Acquisition of Commercial Products and Commercial Services. The statutory authority for applying the Simplified Procedures for Commercial Items of RFO Part 12 Acquisition of Commercial Products and Commercial Services and is implemented by RFO 6.103-1, Only one responsible source and no other supplies or services will satisfy agency requirements. Competition is restricted on this procurement for the reason below:

( x ) Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements

( ) Unusual and Compelling Urgency ( ) Industrial Mobilization, Engineering, Developmental or Research Capability or Expert

Services ( ) International Agreement ( ) Authorized or Required by Statute ( ) National Security ( ) Public Interest

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

The Medical Group Management Association (MGMA) is the sole provider of the MGMA DataDive� platform and its associated benchmarking datasets. MGMA DataDive� is a proprietary, brand-name product that consolidates physician compensation, staffing, cost and revenue, and CPT coding data drawn exclusively from MGMA's member survey network � a network built and maintained solely by MGMA over decades of industry engagement. Market research has confirmed that MGMA is the industry leader in providing benchmark data and is widely accepted and used across private-sector health systems. No other commercially available product or dataset replicates the scope, methodology, or industry benchmarks contained within MGMA DataDive�.

VHA's benchmarking requirements, as codified in VHA Directive 1065 and mandated by 38 U.S.C. §§ 1706A and 8110(a)(3)(C), are specifically oriented toward comparison against industry standards derived from MGMA's survey data. VHA's Governing Board has formally selected MGMA benchmarks as the basis for VHA-wide practitioner productivity targets, which are embedded in the Network Director Performance Plan and operationalized through the Ready-Set-Go Campaign and the FRAT Financial Health Initiative. MGMA benchmarks also underpin active management tools such as the Specialty Provider Productivity Standards Performance and Outlier Overview report maintained by the Office of Productivity, Efficiency, and Staffing (OPES).

While VHA has considered developing internal benchmarking targets as an alternative, this approach presents significant limitations: it would restrict VHA's ability to measure performance against private-sector leaders, impede the identification of underlying causes of performance issues, and

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Acquisition ID#: 36C776-26-AP-1784 require dedicated staff with specialized expertise that OPES does not currently possess. Additionally, VHA has evaluated alternative subscription structures with MGMA; however, purchasing individual licenses rather than an organizational membership would significantly limit the type of data available to VHA and result in higher aggregate costs.

The use of a brand-name description in this acquisition is essential to VHA's requirements. MGMA DataDive� is produced and licensed exclusively by MGMA, and no other product offers the equivalent datasets, benchmarking methodology, or industry-accepted standards required to satisfy VHA's statutory and operational obligations. Accordingly, MGMA is the only firm capable of providing the supplies and services described in Section 3 above without the Veterans Health Administration experiencing substantial duplication of cost that could not be expected to be recovered through competition and unacceptable delays in fulfilling its requirements.

Without continuation of this contract, VHA will no longer have the capacity to measure, monitor, or benchmark the productivity of its clinical workforce, with negative downstream impacts on quality of care and access to care for Veterans. The Ready-Set-Go Campaign, the annual productivity targets embedded in the Network Director Performance Plan, and FRAT Workstream 2.1 are all at risk of disruption if access to MGMA DataDive� is not maintained.

Provide, in narrative form, a detailed explanation supporting and clearly relating to the conditions described by the FAR for using the particular authority cited.

6. Description of Efforts Made to ensure that offers are solicited from as many potential sources as deemed practicable:

Other Actions: The Contracting Officer reviewed the acquisition history for this recurring requirement and conducted market research examining commercially available benchmarking products. No alternative product was identified that replicates the MGMA DataDive� datasets, benchmarking methodology, or industry-accepted standards required to satisfy VHA's productivity benchmarking and statutory compliance obligations. The MGMA Organizational Membership is available exclusively through MGMA and cannot be obtained through any intermediary or reseller under equivalent terms.

A Special Notice of Intent to Sole Source was posted to SAM.gov on May 27, 2026. Responses were due on June 8/2026. Zero (0) responses were received.

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

Reasonable:

The Contracting Officer determines that the anticipated cost of this procurement will be fair and reasonable. The base year is estimated at . This determination is based on a comparison of the proposed price against prior year pricing for the same MGMA Organizational Membership, an analysis of published MGMA membership pricing, and a review of applicable price escalation factors.

The Contracting Officer will obtain a price quote from MGMA and perform a price analysis comparing the quoted price to historical pricing and published catalog or market rates prior to award. Certified cost or pricing data are not anticipated to be required for this acquisition. The PM/COR will verify that the scope and level of access offered correspond to the quoted price prior to the Contracting Officer's final determination of fair and reasonable pricing.

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Acquisition ID#: 36C776-26-AP-1784

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

Market research confirmed that MGMA is the industry leader in providing physician and provider benchmarking data and that the MGMA DataDive� platform is a proprietary product available exclusively from MGMA. While other associations offer productivity data, none replicate the scope, methodology, or industry acceptance of MGMA DataDive�. No SDVOSB, VOSB, or other vendor is authorized to offer MGMA Organizational Membership or the underlying DataDive� datasets on MGMA's behalf. Accordingly, the Rule of Two cannot be satisfied for this requirement, and the non-competitive procedures authorized under VAAR 819.7007 or 819.7008 are not applicable, as the restriction on competition is driven by the proprietary nature of the product rather than the size or ownership status of the vendor.

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

The MGMA DataDive� platform and its underlying survey datasets are proprietary to MGMA. No performance work statement suitable for full and open competition has been developed because the specific benchmarking data, methodology, and industry-standard comparisons required by VHA are unique to MGMA's product and cannot be replicated through a generic or open-competition specification.

VHA's established productivity benchmarking programs, ongoing statutory compliance obligations under 38 U.S.C. §§ 1706A and 8110(a)(3)(C), and active enterprise initiatives � including the FRAT Financial Health Initiative, FRAT Workstream 2.1, and the Ready-Set-Go Campaign � are all calibrated to MGMA DataDive� outputs. Management tools such as OPES's Specialty Provider Productivity Standards Performance and Outlier Overview report are also dependent on continued access. Substitution of an alternative data source would require restructuring of established productivity evaluation methodologies, recalibration of performance targets embedded in the Network Director Performance Plan, and retraining of personnel across VHA � resulting in programmatic disruption inconsistent with VHA's mission to deliver timely, safe, high-quality Veteran care.

10. Listing of Sources that Expressed, in Writing, an Interest in the Acquisition: A Special Notice, Notice of Intent to Sole Source was posted to SAM.gov on May 27, 2026. Responses were due on June 8/2026. Zero (0) responses were received.

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 proprietary nature of the MGMA DataDive� platform represents the primary barrier to full and open competition for this requirement. VHA will continue to monitor the commercial benchmarking data marketplace to determine whether alternative products emerge that are capable of satisfying VHA's productivity benchmarking and statutory compliance requirements. Should a viable alternative be identified prior to the expiration of this contract, VHA will initiate a competitive acquisition for the follow-on requirement.