PG Part808.405-6 Atch2 Limiting Sources Justification OVER SAT NWI signed_Redacted.pdf

VHAPG Part 808.405-6 Limiting Sources Attachment 2: Request for Limited Sources Justification Format >SAT

Effective Date: 02/01/2022 Page 1 of 3

LIMITED SOURCES JUSTIFICATION

ORDER >SAT

FAR PART 8.405-6

Acquisition Plan Action ID: 36C263-24-AP-1278

(1) Contracting Activity:

Contracting Activity Department of Veterans Affairs Network Contracting Office 23 2501 W 22nd Street, Sioux Falls SD 57105

Requesting Activity Department of Veterans Affairs, VISN 23 Nebraska Western Iowa Health Care System 4101 Woolworth Ave, Omaha NE 68105 2237 Funding Document: 636-24-2-5066-0006

(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).

Order against: FSS Contract Number: GS-03F-049GA

Name of Proposed Contractor: Iron Mountain Information Management LLC Street Address: One Federal St City, State, Zip: Boston MA 02110 Phone: 703-889-6136

(3) Description of Supplies or Services:

The estimated value of the proposed action is The intent of the contract is to procure Medical and Administrative Record storage and delivery services for the Nebraska-Western Iowa Health Care System, 4101 Woolworth Ave, Omaha, NE 68105. Period Of Performance: 3/1/2024 to 2/28/2025, plus 4 Option Periods

(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; there are roughly 9,651 cubic feet of boxes of records being stored at the Iron Mountain facility in Kansas City between Iowa City and NWI containing an estimated 123,251 patient records. This includes the boxes of records multiple departments have sent. The cost of permanent removal of cartons from the facility which includes retrieval, permanent withdraw, administrative fees, and shipping fees is per carton. It would cost an estimated which does not include any labor costs the department may incur due to the

VHAPG Part 808.405-6 Limiting Sources Attachment 2: Request for Limited Sources Justification Format >SAT

Effective Date: 02/01/2022 Page 2 of 3 removal. All patient records would need to be manually checked into Veterans Health Information Systems & Technology Architecture (VistA) which would take hundreds of employee OT hours. The other department records would also need to be checked in. Once a new location for storage was set up the employees would need to check out all the records again in VistA and create new documentation to ship the records. This would be creating hundreds of OT hours as the physical location of all patient records needs to be currently maintained in VistA. NWI would need to go through all the records before sending to another facility to ensure 100% accountability. This would take over 9,651 cubic feet of space to store these records in Omaha, while validating everything was received. The storage space would need to be NARA approved and currently NWI does not have a space that is NARA approved. During the time Iron Mountain was retrieving records and we were validating that all were received the patient records would be unavailable for request. Patient records are requested quite frequently, and this would incur a hardship to the veterans and veterans’ care. We would also have another waiting period while the “new” storage facility indexed the records, this could take anywhere from 6 months to a year total of receiving, validating, and shipping to another storage facility.

(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:

Currently the NWIHCS is only storing records at Iron Mountain, due the Department of Veterans Affairs Records Center and Vault being at full capacity. The NWIHCS frequently receive requests for information that is currently being stored at the Iron Mountain facility. Should we use more than one storage facility it would create confusion and twice as much work to locate the record for retrieval. The Privacy Officer and Records Manager conduct a site visit, when required by the VHA National Records Management Office, VHA Office of Health Informatics (105HIG), to monitor the records stored at the commercial storage space, to ensure compliance with Federal records requirements. Iron Mountain is the closest drive; if we used more than one storage space the Officers would need to make multiple inspections and travel distances greater than Kansas City as there are no other storage facilities within driving distance. This would cost the VA additional money to pay for travel and time lost traveling for the employees. There would be two or more contracts to maintain and renew. NWI is currently reducing the amount of paper records we store, there are not many records we send to storage yearly any longer, this would create unnecessary work for a few hundred additional boxes of records. Iron Mountain is well trained in identifying which records we request and delivering them within 24 hours.

(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 was conducted, and while there may be other NARA approved storage facilities for VA’s records, the cost to move the files from one facility to another would be approximately which does not include any labor costs the department may incur due to the removal. If VA were to compete the storage facility services, it would not anticipate recouping the costs to move the files.

(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: At this time, the barriers to competition cannot be overcome due to the high costs of moving the records from one facility to another. As more of VA’s records become digitized, the barriers to