P08 - DETERMINATION FOR CONSOLIDATION BUNDLING EBSCO - HCA - SPE - Redacted_Redacted.pdf

ATTACHMENT VAAM M807-C and VAAM M807-D Consolidation, Bundling, and Substantial Bundling Determination and Findings

Acq Plan # 36C776-26-AP-1114 VAAM M807-C-D Page C-D-1

EBSCO – CINAHL, Medline, and PBSC

36C776-26-AP-1112

FINDINGS

I. INTRODUCTION.

The Program Contracting Activity Central (PCAC) intends to award a national, enterprise-wide, firm-fixed-price contract to EBSCO Information Services for licensed electronic access to three proprietary databases: (1) CINAHL Ultimate,

(2) Medline Complete, and (3) the Psychology & Behavioral Sciences Collection (PBSC). Market research supports that consolidation, bundling, and substantial bundling of these subscriptions into a single, sole-source award is necessary and justified to meet Veterans Health Administration (VHA) mission needs.

II. BACKGROUND.

A. This procurement action is for the purchase of a VA enterprise-wide license for electronic access to the three EBSCO products listed above, with EBSCO as a sole source vendor: the Cumulative Index to Nursing and Allied Health Literature with Full Text database (CINAHL Ultimate), Medline Complete, and the Psychology and Behavioral Sciences Collection (PBSC). The titles provided by the subscription to CINAHL are heavily relied on by VA librarians, clinicians, researchers, and educators; they provide knowledge-based information that covers journal literature in the field of nursing and allied health professions, as well as related books, dissertations, and conference proceedings. The content included in Medline Complete provides access to an extensive collection of full-text biomedical and health sciences journals that are critical to support physician clinical decision-making. In addition, this database includes full-text access to journals that are not available through other vendors, which contain important scientific knowledge needed to provide high-quality care. The Psychology & Behavioral Sciences Collection from EBSCO is a searchable database and access to full-text scientific journals centered on psychology, behavioral sciences, and related disciplines.

The current contract with EBSCO (Contract No. 36C77623P0062) provides subscription access solely to CINAHL Complete. Medline Complete and PBSC are not included under this agreement. The contract consists of a base period and two option years, with a total value of $5.5 million. Although the period of performance is currently scheduled to conclude on September 17, 2026, EBSCO and the Department of Veterans Affairs have reached an agreement to modify the contract to shorten the period of performance to May 31, 2026. This modification will include the deobligation of excess funds resulting from the reduced period of performance.

VAAM M807-C-D Page C-D-6

Regional or Agency-wide contract implications:

The proposed consolidation and bundling yields enterprise-level benefits that enhance acquisition efficiency, standardization, and oversight in accordance with Federal and VA procurement policy. The national contract replaces an estimated 70–80 decentralized local or regional procurements previously executed by individual VA medical facilities and Veterans Integrated Service Networks (VISNs). Eliminating this fragmented procurement approach reduces administrative burden, establishes uniform terms and pricing, and ensures consistent access, performance expectations, and support across all Veterans Health Administration (VHA) locations.

Centralized administration under a single contractual vehicle improves end-to-end visibility, enables effective application of economies of scale, and facilitates oversight commensurate with a nationally scoped, high-dollar sole-source requirement. This structure is aligned with regulatory expectations for appropriate internal controls and documentation. Additionally, the consolidation significantly reduces the volume of required procurement actions and associated staff hours, thereby optimizing acquisition workforce resources at both the national and field levels.

B. Procurement Strategy.

This consolidation does not adversely affect Small Business participation or set-aside opportunities. All three products—CINAHL Ultimate, Medline Complete, and PBSC—are proprietary to EBSCO Information Services and are available exclusively from the original developer. Small Business resellers cannot satisfy the required 50 percent performance requirement because they neither create nor control the licensed content and serve only as pass-through intermediaries. Their involvement adds an average fee of approximately 3 percent without altering scope, capabilities, or deliverables.

At the national level and associated contract value, introducing a Small Business intermediary would be cost-inefficient and would not provide a substantive benefit to the Government. VA will continue to engage Small Business partners on other open-market and competitive procurements where their participation is feasible, compliant, and value-added.

Additionally, PBSC has been deliberately separated from a prior bundled arrangement in which it was paired with a non-sole-source resource.

Transitioning PBSC to this sole-source EBSCO contract enables the companion product to be competed independently on the open market. This action increases competition for that product and preserves future opportunities for both Small and Large Business vendors.

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The applicable NAICS code for this requirement is 519290 (Web Search Portals and All Other Information Services).

C. Alternative Approaches.

Issue independent solicitations for each major function. Each function would be awarded to separate contractors, with the Government managing integration across contracts.

Enables specialized small businesses to compete for discrete service lines (supports small business participation consistent with FAR 7.107 bundling considerations).

Potentially sharper technical focus and niche expertise for each function.

Rationale for Not Selecting:

Loss of Economies of Scale: Market research indicated volume pricing and cross-functional staffing efficiencies would be reduced, with a high probability of increasing the contract price(s) over the consolidated baseline.

Integration & Interoperability Risk: Multiple contractors would complicate coordination of clinical operations, device uptime, and change management, resulting in higher schedule risk.

Increased Administrative Burden: Government would assume system integration responsibility across multiple contracts, increasing COR oversight, monitoring, and invoice reconciliation workload.

Continuity of Care Impacts: Fragmentation of services could delay incident response, creating potential mission risk to patient care.

Proprietary Source: EBSCO is the exclusive provider of enterprise-level contracts for these database subscriptions. Access is delivered through EBSCOhost, EBSCO’s proprietary flagship search platform, which is not available to resellers.

D. Negative impact.

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Although the consolidated, sole-source approach does limit the number of potential small business prime contracting opportunities, these impacts do not outweigh the agency’s need to award to the proprietary source that is uniquely capable of meeting the full requirement. Market research confirms that the essential components, technical data, and interoperability necessary for successful performance are proprietary to the identified source, and no small business possesses the rights or capabilities required to perform the work independently. As a result, separating the requirement into smaller acquisitions would introduce significant performance, compatibility, and cost risks without creating meaningful opportunities for small business participation. To the extent practicable, the agency will require small business subcontracting, participation goals, and related measures to ensure that small firms are still meaningfully engaged. In balance, the proprietary nature of the requirement, the operational risks associated with fragmentation, and the sole-source justification collectively outweigh the limited negative impacts on small business contracting.

E. Inclusion of small business concerns.

Because the requirement is proprietary and can only be fulfilled by a single responsible source, there are no meaningful subcontracting opportunities available for small business participation. The Government will engage the VA Small Business Specialists and OSDBU to ensure full visibility of the requirement and to verify that no SDVOSB or VOSB could meet the proprietary technical needs.

IV. SUBSTANTIAL BUNDLING.

A. Specific benefits anticipated from substantial bundling.

This consolidation provides agency-wide benefits by improving acquisition efficiency, consistency, and oversight. The national contract replaces approximately 70 to 80 separate local and regional purchases previously executed by individual VA medical facilities and Veterans Integrated Service Networks (VISNs). Eliminating this fragmented approach reduces administrative burden, standardizes terms and pricing, and ensures uniform access and support for all VHA facilities.

B. Assessment of impediments to small business participation resulting from substantial bundling.

This consolidation does not create barriers for Small Business participation nor eliminate any viable set-aside opportunities. All three required products— CINAHL Ultimate, Medline Complete, and the Psychology & Behavioral Science Collection (PBSC) - are proprietary to EBSCO Information Services and can only be obtained directly from the original publisher. Small Business resellers cannot meet

VAAM M807-C-D Page C-D-9 the required 50 percent performance standard because they do not produce or control the licensed content; they function solely as pass-through intermediaries, typically adding an average 3 percent fee without providing additional value or altering the scope of work. As a result, substantial bundling does not reduce competition among Small Businesses, as no Small Business entities are capable of performing the requirement.

C. Actions designed to maximize small business participation as contractors, including provisions that encourage small business teaming.

To maximize opportunities for Small Business participation, the VA conducted outreach through a Sources Sought/Request for Information posted on SAM.gov and distributed an additional RFI directly to verified SDVOSB/VOSB vendors under NAICS 519290. These actions were intended to identify any Small Business entities capable of providing the required subscription services or participating as part of a teaming arrangement. However, because all required products are proprietary to EBSCO Information Services and can only be obtained from the original publisher, there is no viable opportunity for Small Business prime contractors or teams to perform the requirement. Small Business resellers do not produce or control the licensed content and therefore cannot meet performance requirements under a set-aside or teaming structure. As a result, while the VA took meaningful steps to assess Small Business capability, no feasible Small Business contracting or teaming opportunities exist for this requirement.

D. Actions designed to maximize small business participation as , or order, that may be awarded to meet the requirements.

Opportunities for small business participation as subcontractors were evaluated;

however, none exist due to the proprietary nature of the required products.

CINAHL Ultimate, Medline Complete, and the Psychology & Behavioral Science Collection (PBSC) are exclusively produced, licensed, and distributed by EBSCO Information Services. As the sole owner and publisher of the content, EBSCO does not utilize subcontractors or third-party suppliers for any portion of this subscription service. There are no ancillary service components (installation, configuration, maintenance, or support) that could be subcontracted to small businesses. Because the performance requirements consist solely of delivering licensed digital content controlled by a single source, no viable subcontracting or supplier roles are available for small business participation at any tier.

E. Determination that the anticipated benefits of the proposed bundled contract or order justify its use.

Centralized management under a single contract provides better contract visibility and leverages economies of scale, while also ensuring appropriate scrutiny