Redacted TAB D Limited Sources Justification (LSJ) PAD Bridge Action.pdf

CUI

Control Number: FY25-0377

Controlled by: Defense Health Agency (DHA)

Controlled by: PS-CD

CUI Category(ies): Source Selection

Limited Dissemination Control: FED Only

POC: Peichang Wang: peichang.wang.civ@health.mil

Limited Sources Justification (LSJ)

Federal Acquisition Regulation (FAR) Part 8.405-6(c)

1. Identification of the Agency and Contracting Activity: Defense Health Agency (DHA), DHA

Contracting Activity (CA), Professional Services Contracting Division, (PS-CD).

2. Nature and/or Description of Action being Approved: This is a Limited Source Justification (LSJ) for an acquisition for the DHA Patient Administration Division (PAD) pursuant to 8.405-6(a)(1)(i)(B) of the FAR. PAD is requesting approval of this Justification and Approval (J&A) for a sole source award bridge order to continue supporting the PAD Health Record Management Program for an interim period while the replacement requirement is competed, and the new service provider is on-boarded in order to complete its mission and avoid any lapse in services.

The government intends to negotiate a Firm Fixed Price Task Order with Deloitte Consulting LLP

(Deloitte) via General Services Administration (GSA) contract 47QRAA18D001P. Patient

Administration Division Joint Health Record Management Program support is under the current Task

Order, HT001124F0055, which expires on 23 September 2025; Deloitte is the incumbent contractor.

There will be no new work or change in scope from the current effort.

3. Description of Supplies or Services and Estimated Value:

The Patient Administration Division Joint Health Record Management Program support requirement will sustain the PAD Health Record Management Program under DHA and for the Department of Defense

(DoD). As a Combat Support Agency, it is imperative for DHA to provide accountability for the systematic management of health/medical/treatment records for the active-duty members and other eligible beneficiaries of the Military Health System (MHS). This requirement will provide program management and support services oversight to include Health Information Management/Medical Coding, Health Records Management, and the full gamut of functions under the purview of Patient

Administration by DoD and DHA leadership.

This requirement will provide MHS GENESIS® enterprise Patient Administration support to coordinate, collaborate, and communicate across Services and military treatment facilities (MTFs) to ensure Patient

Administration functions, policies, and workflow adoption with the new electronic health record are adhered to. Additionally, critical Composite Health Care System (CHCS) close-out activities are impacted if this award is not executed, which will negatively impact both the decommissioning of CHCS hosts as well as cost-saving to DHA.

Source Selection Information - See FAR 2.101 and 3.104-4

OCT 2024

mailto:peichang.wang.civ@health.mil

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Source Selection Information - See FAR 2.101 and 3.104-4

Period Period of

Performance or Required Delivery Date

Estimated Value Type of Funding

Base Period 9/24/2025 – 3/23/2026 Operations and Maintenance

Option Period 1 3/24/2026 – 9/23/2026 Operations and Maintenance

Total

4. Authority Cited: FAR 8.405-6(a)(1)(i)(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.

5. Rationale Justifying Use of Authority Cited:

The Acquisition Strategy (AS) for the competitive follow-on to Patient Administration Division Joint

Health Record Management Program support requirement, Patient Administration Division (PAD)

Subject Matter Expert (SME) Strategic Support, was signed off on 19 March 2025. However, a bridge action is needed due to the following reasons:

1) The requiring activity was experiencing workforce shortages that impacted the ability to prepare and adequately revise acquisition specific documents. Because of this, the acquisition lead time increased beyond what would normally be anticipated.

2) Due to budget reductions, the PAD SME requirement needed to reduce 20% of the base year estimate. This reduction in requirement scope needed additional time to adjust the requirement documents and to go through internal review and approval processes.

3) The requirement activity needed time to process the new Department of Government

Efficiency (DOGE) review and approval process for the requirements.

Due to the above causes, there isn’t sufficient time to solicit the follow-on PAD SME requirement and award it prior to the current order expiring. This justification will authorize the continued service for

DHA while the PAD SME requirement can be competed and awarded. The bridge order that will follow this approval is required to ensure the customer does not experience a break in service. The bridge order will be written with a base period of six (6) months with one (1) option period of six (6) months.

6. Market Research:

Market research was conducted from 01 August 2024 to 14 December 2024, by performing reviews of previous or similar acquisitions within the small business platform. Searches in Ability One did not identify any sources. A SBA market search identified three (3) potential sources, and SBA Quick Market

Search identified three (3) potential sources. The research highlighted the special items numbers as well as the North American Industry Classification System codes (541611) related to professional services.

There are currently no contract vehicles that support the requirement needed for continuation of this work; however, market research on GSA Advantage identified multiple contractors that offer the same

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Source Selection Information - See FAR 2.101 and 3.104-4 labor categories required by this requirement. These labor categories are offered by multiple Small

Business contractors on GSA Advantage; in addition, this requirement is not technically complex or unique. Adequate competition can be achieved by offering this requirement to Small Business contractors on GSA; therefore, this requirement can be met if it is set aside for Small Businesses on GSA Advantage.

From 11 August 2025 to 15 August 2025, follow-up market research was conducted, and market conditions have not changed. In order to ensure: 1) continuity of existing services; and 2) sufficient time is available to compete the follow-on requirement, conduct source selection, complete award, and on-board the new awardee; awarding a bridge action to the incumbent contractor, Deloitte, at this time is the most advantageous method of fulfilling the Government’s need, with regards to price, efficiency, past performance, and experience. In addition, a notice was posted on SAM.Gov on 22 August 2025 to inform the industry that the Government intends to issue a sole source bridge to extend current Patient

Administration Division Joint Health Record Management Program support in preparation for the competitive follow-on solicitation. Numerous contractors expressed interest in the PAD recompete, and

Contracting informed all of them that the PAD recompete will be posted on GSA Advantage as a 100%

Small Business Set Aside.

7. Other Facts:

a. Procurement history.

(1) Is this a new requirement? No.

(2) If 7.a.(1) is No, was the action just prior to this one competed? No.

(3) If 7.a.(2) is Yes, what has changed where this action cannot be competed? N/A.

b. Additional Information. N/A.

8. Actions to Remove or Overcome any Barrier to Competition:

The follow-on to Patient Administration Division Joint Health Record Management Program support requirement, PAD SME Strategic Support, has a signed Acquisition Strategy. The requirement owner is currently finalizing input on the solicitation package. The PAD SME requirement will be competed on

GSA Advantage as a 100% Small Business Set Aside.

9. Technical Certification:

I certify the supporting data under my cognizance, which are included in the justification, are accurate and complete to the best of my knowledge and belief.

Contracting Officer Representative (COR) Health

Information Management Patient Administration Division

10. Requirements Certification:

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Source Selection Information - See FAR 2.101 and 3.104-4

I certify the supporting data under my cognizance, which are included in the justification, are accurate and complete to the best of my knowledge and belief.

Contracting Officer Representative (COR) Health

Information Management Patient Administration Division

11. Best Value Determination:

Consistent with FAR 8.404(d) Pricing and supplemental Department of Defense requirements, I hereby determine the action described herein represents the best value to the Government.

Basis for Determination: The Contracting Officer will determine that the anticipated cost to the

Government will be fair and reasonable through a comparison and analysis of proposed prices with historical prices paid, the Contractor’s list prices, the Independent Government Cost Estimate, and prices for same or similar services on GSA Advantage.

Contracting Officer Professional Services – Contract Division (PS-CD)

12. Legal Review:

I have reviewed this justification and have found it to be legally sufficient.

Associate General Counsel

Office of General Counsel

Defense Health Agency

13. Contracting Officer Certification:

I certify this justification pursuant to the authority of FAR 8.405-6(a)(1)(i)(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” is accurate and complete to the best of my knowledge and belief.

Contracting Officer

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Source Selection Information - See FAR 2.101 and 3.104-4

Review

I have reviewed this justification and find it adequate to support limited sources.

Concurrence

Chief, Contracting Office

Approval

Based on the foregoing justification, I hereby approve limiting sources in the acquisition of Patient

Administration Division Joint Health Record Management Program support in the estimated amount of pursuant to the authority of FAR 8.405-6(a)(1)(i)(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”, subject to availability of funds, and provided that the services and property herein described have otherwise been authorized for acquisition.

Competition Advocate

Defense Health Agency Contracting Activity (DHACA)