P03 - Sole Source RFO 8 over SAT Executed.pdf

DEPARTMENT OF VETERANS AFFAIRS

RFO 8.401(b) & GSAR 538.7104-3 / 538.7104-4 – Sole Source Justification >SAT

Acquisition Plan Action ID: 36C10D-26-AP-0177

(1) Agency and Contracting Activity:

Department of Veterans Affairs Office of Procurement Operations, Supporting VBA Office of Acquisition, Logistics and Construction (OALC)

(2) Description of Action: This acquisition is conducted under the authority of the Multiple- Award Schedule Program (41 U.S.C. 152(3) and 40 U.S.C. 501).

The Office of Business Integration (OBI), Benefits Delivery Protection & Remediation, intends to pursue a sole-source bridge Task Order for continued Fraud Prevention Services (FPS) operations. This requirement represents a follow-on effort to Federal Supply Schedule (FSS) Number GS-00F-008DA, Veterans Benefits Administration (VBA) Task Order 36C10D21F0017.

Name of Proposed Contractor: Booz Allen Hamilton Inc.

FSS Contract Number: GS-00F-008DA Address: 8283 Greensboro Dr.

City, State, Zip: Mclean, VA 22102 Phone/Email: Susie Cohen, Contract Manager, 240-547-1588, cohen_susie@bah.com

(3) Description of Supplies or Services:

This Task Order supports VBA’s counter-Fraud, Waste, and Abuse (FWA) Directorate within OBI.

To aggressively respond to FWA risks, VBA requires a robust capability to analyze business processes through VA data, detect anomalies and patterns of FWA, and flag incidents and schemes for mitigation. The Task Order provides predictive advanced analytics, artificial intelligence (AI) and machine learning (ML) modeling, access to data scientists and engineers, and operational capabilities for direct counter-fraud support to Veterans and enables VBA to aggressively respond to fraud, waste, and abuse within its business processes. This success provides VBA with a ready-made platform for protecting the total benefit pool and close the gap (risk exposure) in the protection of the total $200B+ annual benefits pool.

The VBA is requesting a six-month base period of performance, from September 26, 2026, through March 25, 2027, with the ability to extend services under Revolution Far Overhaul (RFO) Clause 52.217-8, Option to Extend Services. The total estimated value of this six-month task order to include all RFO Clause 52.217-7 Option for Increased Quantity – Separately Priced Line Items is $4,046,614.00.

(4) Identify the Authority/Statutory Exception and Supporting Rationale.

GSAR 538.7104-3(b)(1)(i): The need is of such unusual urgency that following the procedures would result in unacceptable delays in fulfilling that need.

GSAR 538.7104-3(b)(1)(ii): Only one source is capable of providing the products, services, or solution required at the level of quality required because the products, services, or solutions are unique or highly specialized.

GSAR 538.7104-3(b)(1)(iii): The order should be issued on a sole source basis in the interest of economy and efficiency because it is a logical follow-on to an FSS order already issued on a competitive basis.

Task Order 36C10D21F0017 was competitively solicited under FSS SIN 541611. As such this short-term bridge Task Order may be issued on a sole source basis in the interest of economy and efficiency because it is a logical follow-on to an FSS order already issued on a competitive basis. Due to budgetary constraints the new work to be performed under this bridge Task Order represents the minimum services required to keep the FPS Services program operational until the long-term requirement is awarded.

GSAR 538.7104-3(b)(1)(iv): It is necessary to place the order with a particular FSS contractor to satisfy a minimum guarantee established in the FSS BPA.

GSAR 538.7104-3(b)(1)(v): A law expressly authorizes or requires that the purchase be made from a specified source.

(5) Items peculiar to one manufacturer: This section is not applicable.

GSAR 538.7104-4. Items peculiar to one manufacturer. This acquisition involves a particular brand name, product, or feature of a product, peculiar to one manufacturer. A brand name item, whether available on one or more schedule contracts, is an item peculiar to one manufacturer.

How will this requirement be fulfilled? Check one:

Competitively. The brand name item will be competed among FSS contractors/distributors offering this item. The basis for restricting consideration is documented immediately above.

(Per GSAR 538.7104-4(b)(2)(i)).

Sole source. A justification must be executed in accordance with GSAR 538.7104-3.

Complete Section 4 above. (Per 538.7104-4(b)(2)(ii)).

(6) Describe the Market Research Conducted among schedule holders and the results or a statement of the reason market research was not conducted.

Market research for this bridge Task Order was not conducted. VBA has performed extensive market research for the forthcoming long-term requirement, which will be solicited competitively under the GSA Alliant 2 contract vehicle. The purpose of this bridge Task Order is solely to maintain continuity of critical Fraud Prevention Services while the competitive long-term procurement is finalized.

(7) Any Other Facts Supporting the Justification:

Multiple unforeseen circumstances significantly affected VBA’s ability to execute the long-term competitive requirement as originally scheduled. During the acquisition planning period, VBA experienced an extended Government shutdown, substantial retirements and staffing reductions, internal division reorganizations, and uncertainty surrounding resource allocations.

Each of these events contributed to unanticipated delays in developing and finalizing the acquisition strategy required for competition under GSA Alliant 2.

Further complicating the timeline, Fraud Prevention Services performed under Task Order Number 36C10D21F0017 were temporarily terminated by DOGE and later reinstated, which required VBA to exercise a one-month extension under FAR 52.217-8 to maintain operational continuity. These disruptions, paired with delays in securing the resources necessary to procure new services, created conditions in which this short-term bridge Task Order became the only viable method to prevent a lapse in mission-critical fraud-prevention support while the long-term competitive requirement is completed.

(8) A Statement of the Actions, if any, the agency may take to remove or overcome any barriers that led to the restricted consideration before any subsequent acquisition for the supplies or services is made:

The long-term requirement for these services remains in active development, and the restricted consideration associated with this short-term bridge action resulted primarily from unforeseen circumstances, including an extended Government shutdown, increased retirements and staffing reductions, delays in resource availability, and organizational realignments—that disrupted normal acquisition planning timelines. These events collectively postponed progress toward executing competitive procedures under GSA Alliant 2.

To remove or overcome such barriers in future acquisitions, the agency will coordinate closely with the program office to ensure that advanced acquisition planning is conducted well ahead of anticipated contract expiration dates. This will include building contingencies for potential disruptions, stabilizing resource allocations earlier in the planning cycle, and initiating acquisition actions sufficiently in advance to avoid gaps in service delivery. These measures will help prevent recurrence of restricted consideration and support timely completion of competitive procurements.

(9) 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.

Ronnie Bell Date Senior Program Analyst

(10) Approvals:

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

Bridget Bartolomei Date Contracting Officer

b. Supervisory Contract Specialist (required for actions valued over SAT-$900K): I certify that the foregoing justification is accurate and complete to the best of my knowledge and belief and approve.

Heather Hampton Date Supervisory Contract Specialist HIGHER LEVEL APPROVAL (required for actions over $900K):

c. Designated Contracting Activity Advocate for Competition or Head of Contracting Activity (HCA) (over $900K to $90M): I have reviewed the foregoing justification and find it to be complete and accurate to the best of my knowledge and belief and approve.

Alyssa M. Dark Date Competition Advocate and Head of Contracting Activity Office of Procurement Operations, Supporting VBA Office of Acquisition, Logistics and Construction (OALC)

RONNIE BELL

Digitally signed by RONNIE

BELL

Date: 2026.08.11 11:47:10 -04'00'

BRIDGET BARTOLOMEI Digitally signed by BRIDGET BARTOLOMEI Date: 2026.08.11 11:59:56 -04'00'