VA-26-00042103

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

1. Contracting Activity: Department of Veterans Affairs (VA) Office of Procurement Operations

Technology Acquisition Center 23 Christopher Way Eatontown, NJ 07724

2. Description of Action: The proposed sole-source action is for a firm-fixed price contract to PICIS Clinical Solutions (PICIS), Inc. 9 Centennial Drive, Suite 202 Peabody, MA 01960, for continued maintenance and technical support services for the existing perpetual licenses necessary to maintain the existing PICIS Clinical Information System/Anesthesia Record Keeping (CIS/ARK) operational capability. The software maintenance and technical support includes associated software maintenance/updates, testing, and licensing support. Additionally, VA requires optional tasks to acquire additional licenses to accommodate the possibility of expansion.

3. Description of Supplies or Services: The Veterans Health Administration (VHA), Equipment Life Cycle Management (ELCM) has a requirement to support the perpetual licenses owned by VA with continued maintenance and services of the existing PICIS system currently deployed and operational within 60 VA Medical Centers (VAMC) across 11 Veteran Integrated Service Networks (VISN). This requirement is for sustainment, maintenance, and technical support services for the existing PICIS CIS/ARK environment. Software updates, upgrades, patches, fixes, and continued licensing necessary to sustain the existing capability. The VAMCs currently own hardware supporting the PICIS CIS/ARK environment, including uninterruptible power supply units, servers, and network switches acquired under separate procurement efforts. This CIS/ARK system provides automated collection and charting of physiologic monitors, ventilators, other medical devices, monitors, real time reporting, building and configuration of specific environment, auto-triggers, database queries, real-time access to information in acute and critical care areas, emergency departments, intensive care, medical/surgical units, post anesthesia care, procedural care, progressive care, and/or telemetry areas of care. The PICIS CIS/ARK provides remote and single sign-on access, inbound and outbound Health Level Seven (HL7) interfaces to Veterans Health Information Systems and Technology Architecture (VistA), inbound data from medical devices, record upload to VistA Imaging, and data extracts. The system operates within the VA clinical environment and interfaces with VA health information systems, including VistA/Computerized Patient Record System (CPRS), using established health information exchange standards such as HL7. The PICIS CIS/ARK provides a real-time bi-directional interface with VistA and allows the creation and storage of a completed Portable Document Format file that is accessible in VistA Imaging via the CPRS and may be integrated with VHA’s Tele-Critical Care (Tele-CC) national infrastructure.

This acquisition is for the continued maintenance, support, and expansion capability of the existing VA Owned perpetual PICIS CIS/ARK licenses and does not procure a new CIS. The requirement includes continued upgrades, maintenance and technical support

Clinical Information Systems/ Anesthesia Record Keeping Systems Follow On - PICIS are properly pushed through. Additionally, this Commercial-off-the-Shelf software is highly configured/customized to interface with VistA, medical devices, Tele-CC, and analytic systems and configurations to the software are necessary to meet VA’s interoperability and standardized terminology requirements.

Additionally, no other brand name software other than PICIS can meet all of VA’s current requirements. Specifically, this requirement is to maintain the existing PICIS software which VA currently owns. However, there are optional tasks for procurement of additional licenses that must be fully integrated with the existing PICIS software. The need for additional licenses may be driven by evolving clinical and medical center needs to support the delivery of patient care. Only PICIS licenses are fully interoperable with the existing PICIS software due to the proprietary code in which these licenses communicate. Use of any other brand name software would result in that software not being able to communicate with the existing software infrastructure.

Other commercially available CIS/ARK products have VistA interface capabilities;

however, each interface must be configured to support the specific clinical workflows, data requirements, device connections, and operational needs of the individual facility.

Before that interface can be configured, the replacement CIS/ARK must first be designed, configured, and validated for the facility so the Government can determine what data must be exchanged with VistA. Accordingly, replacing the currently deployed PICIS CIS/ARK environment would require substantial site-specific system design, configuration, interface development, testing, validation, and implementation at each affected facility. Each affected facility has established and validated PICIS CIS/ARK -specific configurations, clinical workflows, data mappings, medical-device connections, logical links, security and routing constructs, VistA/CPRS and VistA Imaging integration, analytics extracts, and other site-specific operational dependencies. Implementation of a new clinical system would require these elements to be redesigned, configured, tested, clinically validated, and implemented at each affected facility to prevent disruption of clinical operations. The estimated duplication in cost of approximately $240 million is based on original procurement of a replacement solution including software and hardware licenses, as well as services which include project management, implementation, testing, training, and significant VistA interface reconfiguration. The VistA interface itself is site/instance-specific, reflecting the unique workflows, data fields, and operational processes that have been incrementally developed and refined over time within each facility’s Commercial Off-The-Shelf system. Replacing the current vendor would necessitate a full re-development of the CIS/ARK software to replicate the existing operational state, followed by a complete rebuild of the VistA interface to align with the re-developed system. This effort would entail significant new investments in hardware, software, training, and development resources. Based on historical implementation data, such a transition would require an estimated 18 to 24 months per facility to complete, during which time critical operational capabilities would be disrupted or degraded. VA will bear a higher level of risk to its patients as the time it would take to get a new system in place would require a phased approach estimated to take more than 5 years (18 months to 24 months+ per facility). This would result in major disruptions in clinical documentation and workflow affecting 60 facilities across 11

VISNs. In addition, extracts to analytics would have to be redeveloped and tested.

Procuring a replacement system for 60 facility sites to include new hardware, deployment, configuration, testing, training, and integration is baselined at $4 million per facility resulting in a total duplication of cost of $240 million. These estimates are based on historical acquisitions from prior, similar CIS, implementation timelines, and VistA interface development efforts undertaken by VA. In addition, these duplicated costs would not be recovered through competition. Accordingly, continuation with the incumbent vendor represents the only practicable means of maintaining system integrity, operational continuity, and compliance with established facility-specific processes.

Finally, VA is migrating to Oracle Cerner over the next 5 years with final site implementation scheduled to take place in 2031. While there is no set timeline for when facilities covered under this effort will migrate to Oracle Cerner it is anticipated that the Oracle Cerner solution/system will incorporate their own CIS/ARK system and the facilities under this contract will not be exercised via the Optional Task as they migrate to Oracle Cerner. Replacing PICIS with another CIS/ARK is estimated to take longer to fully implement than the forecasted roll out of the incoming Oracle Cerner solution.

Without continued PICIS sustainment, maintenance, and technical support, VA would be unable to ensure continued vendor support for the existing operational CIS/ARK environment, including proprietary software maintenance, updates, troubleshooting, and interface support. This creates a risk of unresolved system or interface failures, disruption to established clinical workflows, increased reliance on manual processes, and interruption or degradation of clinical information availability in acute and critical-care environments, negatively affecting timeliness and continuity of adequate Veteran care.

6. Efforts to Obtain Competition: Market research was conducted, details of which are in the market research section of this document. This effort did not yield any additional sources that are capable of meeting the Government’s requirements. The undersigned VA technical representative determined there are no resellers for support of the brand name PICIS CIS/ARK Sustainment and Support. In accordance with RFO VA Deviation Part 5.101(d) a pre-solicitation notice shall be posted to SAM.gov, combined with the solicitation. Further, in accordance with RFO VA Deviation 5.301(d), an award notice will be posted to SAM.gov within 60 days of award.

7. Actions to Increase Competition: The Government anticipates all facilities covered under this effort to be migrated into the Federal Electronic Health Record system by 2031 and thus there will be no requirement for further competition in support of this effort.

8. Market Research: The Government technical experts conducted market research efforts from November 2025 through February 2026 and focused on reviewing whether other vendors could provide similar system capabilities that would provide continued sustainment, maintenance, and technical support for the existing PICIS CIS/ARK system. Market research was conducted to assess the availability of commercial sources capable of providing continued sustainment, maintenance, and technical support for the existing PICIS CIS/ARK system currently deployed within VHA medical facilities. Market research included a review of prior contractual actions, vendor capability information, and other available commercial sources, specifically CliniComp and Pacific Monarch. These vendors are unable to provide similar solutions without substantial duplication of time and costs as described above. VA currently owns PICIS CIS/ARK specific hardware, uninterruptable power switches and switches all previously procured by the VISNs. These assets were then developed and customized to operate within VA’s environment and configuration with VistA/CPRS. Due to proprietary data/code neither vendor, CliniComp or Pacific Monarch, can provide the continued maintenance and sustainment and technical support services to maintain the existing PICIS CIS/ARK operational capability system. This includes but is not limited to all required associated software maintenance/updates, testing, and licensing support.

Additionally, the CliniComp and Pacific Monarch software was reviewed by the Governments technical experts who determined neither vendor is capable of meeting VA’s requirements for software at the optional task level as outlined in Section 5 of this justification. This effort did not identify any additional sources capable of meeting the Government’s requirement without unacceptable disruption to clinical operations, system integrity, or patient safety. Accordingly, PICIS was determined to be the only responsible source capable of fulfilling the Government’s sustainment requirements for the existing PICIS CIS/ARK system.

Additional market research was conducted by the Contract Specialist in August 2026, by utilizing the National Aeronautics and Space Administration (NASA) Solutions for Enterprise-Wide Procurement (SEWP) V Governmentwide Acquisition Contract (GWAC) Provider Look-up Tool to determine whether there are authorized resellers of PICIS CIS/ARK that hold NASA SEWP V GWACs. The Contract Specialist searched for PICIS and PICIS CIS/ARK and found that the search revealed zero sources. The Contract Specialist contacted PICIS directly in August 2026, to inquire about authorized resellers. The Senior Manager of Contracts responded on August 7, 2026, and stated, “PICIS does not have any authorized resellers”.

9. Other Facts: None.

Office of General Counsel (OGC) Review

I have reviewed this document and find it legally sufficient, based on the representations set forth in the documents and, if any, attachments. The Head of the Contracting Activity’s approval is an independently supported decision not wholly reliant on the legal sufficiency determination.

HCA Approval

In my role as Head of the Contracting Activity, based on the foregoing justification, I hereby approve the acquisition of maintenance and technical support services for the existing PICIS CIS/ARK perpetual licenses as well as optional tasks to acquire additional licenses to accommodate the possibility of expansion on an other than full and open competition basis pursuant to the authority cited in Section 4 above, subject to availability of funds, and provided that the property and services herein described have otherwise been authorized for acquisition.