Attachment 2: Request for Limited Sources Justification Format >SAT

VHAPG Part 808.405-6 Limiting Sources Page 1 of 5 Revision: 02 Effective Date: 03/02/2026 Acquisition ID#: 36C263-26-AP-3176

LIMITED SOURCES JUSTIFICATION

ORDER >SAT

FAR PART 8.405-6

Acquisition Plan Action ID: 36C263-26-AP-3176

1. (1) Contracting Activity: Department of Veterans Affairs, Network/Program Contracting Office 23, located at 1303 5TH STREET, SUITE 300 CORALVILLE IA 52241, in support of VISN 23 VA Health Care System at 2805 DODD ROAD SUITE 250 EAGAN MN 55121.

a. 2237- 499-26-4-6765-0097

(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 Department of Veterans Affairs, Veterans Integrated Service Network (VISN) 23, requires comprehensive Omnicell interface and software configuration, testing, and cutover support to transition multiple medical centers to the Oracle Health Federal (Cerner) Electronic Health Record (EHR). This transition requires modifications to medication dispensing workflows, system interfaces, data exchange processes, integration logic, and operational configurations across all Omnicell environments used within VISN 23.

Order against: FSS Contract Number: 36F79723D0073

Name of Proposed Contractor: Omnicell INC

Street Address: 590 CRANBERRY WOODS DRIVE

City, State, Zip: CRANBERRY TOWNSHIP, PA 16066

Phone: 650-251-6100

(3) Description of Supplies or Services:

The estimated value of the proposed action is $432,047.10

The Department of Veterans Affairs, Veterans Integrated Service Network (VISN) 23, requires comprehensive Omnicell interface and software configuration, testing, and cutover support to transition multiple medical centers to the Oracle Health Federal (Cerner) Electronic Health Record (EHR). This transition requires modifications to medication dispensing workflows, system interfaces, data exchange processes, integration logic, and operational configurations across all Omnicell environments used within VISN 23.

https://www.acquisition.gov/far/part-8#FAR_8_405_6 http://uscode.house.gov/browse.xhtml;jsessionid=114A3287C7B3359E597506A31FC855B3 https://www.gpo.gov/fdsys/pkg/USCODE-2011-title40/pdf/USCODE-2011-title40-subtitleI-chap5-subchapI-sec501.pdf

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(4) Identify the Authority and Supporting Rationale (see below and if applicable, a demonstration of the proposed contractor’s unique qualifications to provide the required supply or service.

FAR 8.405-6(a)(1)(B): Only one source is capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized;

FAR 8.405-6(b): Items peculiar to one manufacturer:

A patent, copyright or proprietary data limits competition. The proprietary data is:

Omnicell Inc. is the original equipment manufacturer (OEM) of all Omnicell hardware, software, firmware, and associated proprietary components required for this upgrade.

These products cannot be manufactured, configured, licensed, installed, or serviced by any third party.

All required components for this procurement are proprietary items controlled solely by Omnicell. Manufacturer requirements and warranties expressly restrict installation and configuration to Omnicell certified technicians, as these activities involve:

• Proprietary firmware deployment

• Activation of software licenses (Profile Option, Scheduled Meds)

• Validated hardware/software testing https://www.acquisition.gov/far/part-8#FAR_8_405_6 https://www.acquisition.gov/far/part-8#FAR_8_405_6

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• Secure configuration to meet VA cybersecurity requirements (FIPS, TRM, MDS2, VA 6550)

Procurement from any party other than Omnicell would result in:

• Voided warranties and loss of lifecycle support

• Inability to activate required licensing features

• Technical incompatibility with existing VISN 23 Omnicell infrastructure

• Noncompliance with VA cybersecurity and medical device security requirements

• Unsupported and unsafe system configurations

Because this procurement requires OEM exclusive components, installation, activation, and service, only Omnicell, Inc. is capable of meeting the Government’s full requirement.

The material/service must be compatible in all aspects (form, fit and function) with existing systems presently installed/performing.

(5) Describe Why You Believe the Order Represents the Best Value consistent with FAR 8.404(d) to aid the contracting officer in making this best value determination:

This procurement requires OEM exclusive components, installation, activation, and service, only Omnicell Inc. is capable of meeting the Government’s full requirement. Omnicell, Inc FSS contract 36F79723D0073 contains all required items.

Ordering from a GSA Federal Supply Schedule (FSS) provides several major advantages for federal buyers, contracting specialists, and program offices. GSA has already determined that Schedule pricing is fair and reasonable. This means you do not need to conduct your own cost/price analysis at the contract level, reducing workload and procurement lead time. FSS purchases fall under FAR 8.4, which is significantly simpler than FAR Part 13, 14, or 15 procedures. This results in faster award timelines, reduced documentation requirements and lower administrative burden. All Schedule contractors have already been assessed for financial responsibility, past performance and compliance with federal laws and regs. This reduces procurement risk and protects the government.

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

Vet’s 1st determination:

No SDVOSBs or VOSBs were found through the SBA Small Business Search Tool. Omnicell INC the OEM stated they have 1 authorized SDVOSB (TrillaMed LLC) partner capable of performing this requirement. Market research confirms only 1 SDVOSB can potentially perform this requirement. The result of this market research fails the Rule of Two. A total SDVOSB/VOSB set aside will not be sought.

An SDVOSB sole source to TrillaMed LLC was contemplated but due to the

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NMR applying to SDVOSB sole sources this strategy is not possible due to TrillaMed LLC is not similarly situated to Omnicell INC, a large business.

TrillaMed LLC will need to subcontract 100% of the work to Omnicell, serving only as a pass through.

SB determination:

Similar to the above determination, only 1 authorized SB partner (TrillaMed LLC) is capable of performing this requirement. The result of this market research fails the SBA Rule of Two. A total SB set aside will not be sought.

NRM determination:

Based on the NMR Decision Tree issuing an unrestricted solicitation or ordering against an existing IDV is the recommended strategy.

BAA/TAA determination:

The OEM Omnicell INC confirmed all required items are manufactured in the USA. The recommended strategy will be to use Omnicell’s FSS contract 36F79723D0073 for an order.

(7) Any Other Facts Supporting the Justification:

None

(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:

NCO 23 contracting will continue to monitor the market for changes and new products. New market research will be performed in accordance with RFO FAR 10 & VAAR 810 for any subsequent acquisitions.

(10) Approvals in accordance with the VHAPM Part 806.3 OFOC SOP:

https://dvagov.sharepoint.com/sites/VHAProcurement/VHAPM2/VHAPM_Part_806.3.aspx https://dvagov.sharepoint.com/sites/VHAProcurement/VHAPM2/VHAPM_Part_806.3.aspx

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

Joshua Imdacha NCO 23 Contracting Officer

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.

Michael Casper Services Branch Chief, Network Contracting Office (NCO 23)