About this file

Summary: Justification and Approval (J&A) for Sole Source Procurement

This is a Justification and Approval (J&A) document for a sole-source procurement of a commercial Radio Frequency Identification (RFID) Real-Time Location System (RTLS) to be awarded to Conexus, Inc. by the Defense Health Agency Contracting Activity (DHACA), Healthcare Contracting Division – Southeast (Germany). The 48th Medical Group at RAF Lakenheath, United Kingdom, requires an immediate procurement consisting of commercial hardware (15,000 passive RFID tags, 1,000 active Wi-Fi tags, 30 fixed RFID readers, 12 handheld scanners, and 2 mobile tracking carts), Plexus Location Engine enterprise software licenses with specialized RTLS modules, professional installation and configuration services, and 12 months of annual software maintenance. The system must be 220v, 50/60Hz compliant, integrate with UK electrical infrastructure, and possess a current Defense Health Agency Authority to Operate (ATO) with proven bi-directional interface capability to the Defense Medical Logistics Standard Support (DMLSS) system. Performance occurs across RAF Lakenheath's main hospital campus and three geographically separate OCONUS satellite clinics (RAF Alconbury, RAF Croughton, and RAF Feltwell). The contract employs simplified acquisition procedures under FAR Part 12.201-1, with an estimated total contract value spanning a 150-day implementation period plus 12 months of initial maintenance and four one-year optional renewal periods through July 2031. The estimated costs for all periods are redacted in the document.

The sole-source determination is justified under 10 U.S.C. 3204(a)(1) based on unique technical characteristics requiring complex API integration with DMLSS/LogiCole platforms, mandatory cybersecurity compliance via DHA-approved ATO certification (estimated $70,000+ cost and 12-24 months delay if unavailable), and theater-wide database standardization requirements across Defense Health Network-Europe installations. Market research, including a formal Request for Information (RFI #HT9406-26-RFI-0001) published May 15 through June 1, 2026, evaluated six vendors; only Conexus, Inc. demonstrated current DHA ATO certification (eMASS ID: 3792) with proven DMLSS interface capabilities. Five competing vendors were rejected for inability to meet mandatory cybersecurity and interoperability prerequisites. The Government will pursue future competition mitigation strategies through GSA Schedule expansion and advocacy for a DHA enterprise-wide Blanket Purchase Agreement, while acknowledging that emerging market competition from other certified DoD vendors is anticipated within 12-24 months as industry completes RMF certification processes.

View the file

On GovTribe

Work with this file

  • Download the original file
  • Contacts named in this file
  • Similar government files
  • Ask GovTribe AI about this file

Text version

Control Number:

OCT 2024

RAF Alconbury (located approximately 50 miles from the main campus), RAF Croughton (located approximately 104 miles from the main campus), and RAF Feltwell (located approximately 7 miles from the main campus).

The taxonomy for this acquisition is classified under Product Service Code (PSC) 7G21 (IT and Telecom - Network: Digital Network Products) and North American Industry Classification System (NAICS) code 334290 (Other Communications Equipment Manufacturing).

a) Detailed System Components & Security Generalities:

The contract deliverables will be procured as a complete, commercial turnkey package consisting of:

Commercial Hardware: 15,000 passive RFID tags (segregated by size to accommodate the varying dimensions of medical devices), 1,000 active Wi-Fi RTLS tags, 30 fixed RFID readers, 12 handheld scanners, and 2 mobile tracking carts. Security and access to the system are governed by Common Access Card (CAC) authentication, enforcing role-based permissions. Unlike physical weight-sensing inventory cabinets, this system utilizes wireless radio frequency (RF) readers and antennas mounted at facility chokepoints and doorways to automatically record the movement of tagged assets in real time as they pass through, with no physical "swiping" or weighing required.

Software Licenses: Plexus Location Engine enterprise software, including specialized in-field, mesh, and Wi-Fi RTLS modules.

Professional Services: Turnkey physical installation, on-site calibration, legacy data migration, user acceptance testing, a comprehensive contractor-led asset tagging phase, and initial user training. The Government will provide the necessary virtual server environment; no new physical server hardware is required from the contractor.

Annual Software Maintenance: Ongoing technical support, security patching, and remote system health monitoring.

b) Power and Facility Infrastructure Compliance:

All contractor-provided hardware requiring external power shall be 220v, 50/60Hz compliant and capable of operating on standard UK electrical power. Fixed readers will utilize Power-over-Ethernet (PoE) supplied by Government-furnished network switches. These switches are connected to the hospital�s emergency backup generator power grid, ensuring continuous, uninterrupted asset tracking and database synchronization during facility power outages.

c)Network Connection and ATO Requirements:

The software must reside on the Defense Health Agency�s secure medical community of interest (MedCOI) network. Consequently, the required system must possess a current, valid DHA-approved Authority to Operate (ATO) and a proven, bi-directional interface with the DMLSS system. This ATO is a mandatory prerequisite to enable the system to connect to the to interface with the Government's Accountable Property System of Record (APSR), the necessity of theater-wide standardization, and the severe duplication of cost associated with uncertified software.

1. Complex API Integration (DMLSS/LogiCole): The system must execute automated, bi-directional data exchange with DMLSS (and the emerging LogiCole platform).

Following a formal technical review by DHA J-6 (LRMC CIO), it was established that connecting a new software platform to these databases is not a "copy and paste" evolution. DMLSS and LogiCole utilize specific data feeds and Application Programming Interfaces (APIs). J-6 assessment confirms that introducing a vendor without proven DMLSS/LogiCole integration experience introduces considerable technical challenges and deployment hurdles. Conexus, Inc. is the sole creator of the proprietary "Plexus" software code and, in coordination with the Joint Medical Logistics Functional Development Center (JMLFDC), developed the specific interface specifications established in the DMLSS-ATS Interface Control Document (ICD) v2.0.

Conexus possesses the proven, mature API architecture required.

2. Cybersecurity Policy and Duplication of Cost (ATO): To avoid unacceptable deployment delays, the Government seeks to utilize commercial solutions that already hold a current Authority to Operate (ATO) when available, unless procuring a completely novel capability. Conexus, Inc. holds a fully accredited DHA "Assess and Incorporate" (A&I) ATO (eMASS ID: 3792). J-6 has validated that if the Government were to award to an uncertified vendor, the local MTF would be required to sponsor the software through the Risk Management Framework (RMF) process. J-6 estimates this introduces an unprogrammed, out-of-pocket duplication of cost to the Government of upwards of $70,000.00, in addition to an extended 12-24 month operational delay.

3. Theater-Wide Database Standardization: The 48th Medical Group operates within the Defense Health Network-Europe (DHN-E) and frequently transfers medical assets to and from currently utilizes the identical Conexus Plexus system (Contract W9114F23P0071). To maintain regional database integrity, ensure seamless asset visibility, and allow for the direct transfer of serialized medical equipment across the European theater, the 48th Medical Group must utilize the identical software platform. Introducing a different, non-standardized asset tracking system at RAF Lakenheath would fragment the regional database and break the logistics link with the medical hub.

(b) Unavailability of Specifications Suitable for Full and Open Competition:

The requirements include integration with existing DoD databases (e.g., DMLSS/LogiCole) and adherence to cybersecurity mandates that cannot be modified.

Procuring a commercial software platform that lacks these integrations would transform a commercial acquisition into a developmental integration project. As validated by DHA J-6, the Government cannot simply provide technical specifications for a DMLSS/LogiCole interface and expect an unproven vendor to connect instantly; the vendor must undergo significant coding, configuration, and API testing.

Furthermore, the Government does not own the technical data package for the Conexus software and therefore cannot provide it to other vendors. If the Government were to solicit uncertified vendors, the local medical treatment facility would be forced to sponsor the successful offeror through the RMF process.

Attempting to execute this requirement with a vendor other than Conexus would result in an unacceptable delay in fulfilling the agency's urgent accountability requirements and a substantial duplication of cost (estimated at >$70,000 for ATO sponsorship alone, plus unquantified API developmental costs) that is not expected to be recovered through competition. The unique qualifications of the Conexus Plexus system make it the only system capable of fulfilling the contract requirements without incurring these substantial duplications of costs and unacceptable operational delays.

6. Efforts to Obtain Competition: In accordance with RFO 6.104 and DFARS PGI Class Deviation 2026-O0017, Rev. 1, 206.104-71, the Contracting Office made extensive efforts to solicit offers from as many potential sources as practicable and to formally validate the market conditions supporting this sole-source determination.

(a) Request for Information (RFI) / Sources Sought Synopsis:

To ensure maximum transparency and to actively seek potential competition, the Contracting Officer posted a formal Request for Information (RFI #HT9406-26-RFI-0001) under NAICS code 334290 to the Government-wide Point of Entry (SAM.gov) on 15 May 2026. The RFI remained open until 01 June 2026.

The RFI explicitly outlined the Government�s essential performance requirements. The RFI stated that to be considered capable, a vendor must demonstrate:

"An existing, proven, bi-directional data exchange interface with the Defense Medical Logistics Standard Support (DMLSS) system... "

"A current, valid Authority to Operate (ATO) on the Defense Health Agency (DHA) Information Network, verifiable via an active eMASS record."

Results of the RFI:

CUI

Six (6) vendors submitted capability statements in response to the RFI. The Contracting Officer, in coordination with technical subject matter experts (including the Chief of Healthcare Technology Management, Medical Logistics Flight Chiefs, and the IMD Cybersecurity team), evaluated all submissions against the mandatory requirements.

Five (5) of the responding sources were excluded from capability consideration based on their inability to meet the mandatory cybersecurity and interoperability requirements:

Conexus, Inc. was the only source capable of providing verifiable evidence (eMASS ID: 3792 and a list of 19 active DHA installations) demonstrating compliance with all mandatory requirements.

Technical claims regarding network cybersecurity requirements (ATO) and the mandatory DMLSS data-exchange interface have been coordinated with and validated by the Information Management Department (IMD) / J-6.

(b) Notice of Intent to Sole Source (Pre-Solicitation Notice):

In accordance with RFO 5.101, a Notice of Intent to Award a Sole Source contract will be published on SAM.gov. The notice will identify Conexus, Inc. as the intended sole-source awardee and will cite the authority of RFO 6.103-1. The notice will be posted concurrently with the issuance of the Request for Quote (RFQ) and will remain open for 15 days. Capability statements, proposals, or quotations received in response to the Notice of Intent prior to the closing date will be considered by the agency prior to contract award.

7. Actions to Increase Competition/Remove or Overcome any Barriers to Competition:

(a) Availability of Technical Data:

The primary technical barrier to competition is not a restriction on Government-owned data.

The DMLSS-ATS Interface Specification, Version 2.0 Interface Control Document (ICD) is Government-owned and is available to any commercial source. The barrier is a market-driven business decision; commercial software providers have historically chosen not to invest the private capital required to write software compliant with the DoD�s proprietary DMLSS ICD, nor have they funded the rigorous Risk Management Framework (RMF) certification process required to obtain a DHA Authority to Operate (ATO). Because the software required is commercial, the Government cannot compel other vendors to develop these capabilities.

(b) Emerging Market Competition (RFI Findings):

While Conexus is the only source currently capable of meeting the requirement today, the market research conducted for this acquisition indicates that the competitive landscape is actively shifting. Responses to the RFI (HT9406-26-RFI-0001) from capable DoD IT vendors, , revealed that they are actively investing in RMF development. noted their system is currently entering the ATO process at , and is seeking DHA reciprocity for an existing

. This demonstrates that industry is actively working to overcome these specific technical barriers, and viable competition is anticipated in the near future.

While it is not possible to compete the current acquisition due to the time-sensitive, need for a pre-certified, "turnkey" system, the DHA Contracting Activity will take the following steps to increase the potential for future competition on subsequent acquisition(s) of these supplies or services:

1. Encouraging GSA Schedule Expansion: Conexus, Inc. currently holds a GSA MAS Contract (47QTCA24D005P) that only covers IT labor categories. The Contracting Officer will formally communicate with Conexus, Inc. and encourage them to submit a Modification package to GSA to add their proprietary Plexus software licenses and RFID hardware to their active schedule. If the vendor successfully adds these commercial products to their GSA Schedule, future acquisitions at RAF Lakenheath and other DoD MTFs can be executed under the streamlined, pre-competed procedures of FAR Subpart

8.4 (Federal Supply Schedules) rather than requiring open-market, sole-source J&As.

2. Advocacy for a DHA Enterprise-Wide Solution: Since the Plexus system is already deployed at Landstuhl and 18 other DHA facilities, the local contracting activity will formally coordinate with DHA Category Management and J-8 (Resource Management) to advocate for the establishment of a DHA-wide enterprise Blanket Purchase Agreement (BPA) or IDIQ contract for Conexus software and hardware. Establishing a centralized, agency-wide enterprise vehicle would leverage the DHA's collective buying power, achieve substantial economies of scale, standardize technical support across all MTFs, and eliminate redundant, facility-level sole-source procurements.

8. Market Research: In accordance with RFO FAR Part 10 and DFARS Class Deviation 2026-O0017, Rev. 1 210.001, comprehensive and meaningful market research was conducted from 01 November 2025 through 06 June 2026 to identify qualified sources, assess commerciality, and determine the appropriate acquisition strategy. The full scope, methodology, and results of this effort are formally documented in the Contracting Market Research Report dated 06 June 2026, which is included in the contract file.

The extent of the market research included:

Mandatory Sources: A review confirmed that AbilityOne and UNICOR do not provide cybersecurity-certified RFID medical asset tracking systems, Database and Contract Vehicle(s) Review: Searches of SAM.gov, FPDS-NG, and

USAspending.gov were conducted to review historical DoD acquisitions of similar systems. GSA Multiple Award Schedule (MAS) Contract 47QTCA24D005P was evaluated but determined unsuitable as it does not include the required hardware or perpetual software licenses. The Air Force PMI-ATS enterprise contract (FA445224F0059) was evaluated and ruled out due to a programmatic mission mismatch between global casualty movement and localized facility tracking.

Industry Engagement (RFI): A formal Request for Information (RFI) was published on

SAM.gov from 15 May to 01 June 2026. This effort actively tested the market against the Government�s minimum mandatory requirements (a pre-existing DMLSS interface and a current DHA ATO).

Market Research Results:

The market research established that the required hardware, software, and services meet the definition of commercial products and commercial services under FAR 2.101. While the general market for commercial RFID tracking technology is highly competitive, the specific military requirements for immediate interoperability with proprietary DoD databases (DMLSS) and compliance with the Risk Management Framework (RMF) create a restrictive technical barrier.

As detailed in Section 6, the evaluation of the six (6) responses to the RFI confirmed that Conexus, Inc. is the only commercial vendor that currently possesses the required DHA network certifications and proven integration capabilities. Therefore, market research conclusively supports a sole-source acquisition strategy.

9. Other Facts:

a. Procurement History:

(1) Is this a new requirement? Yes. This requirement for a single, comprehensive tracking system for the entire MTF is a new, initial request for the implementation of an automated Real-Time Location System (RTLS) at the 48th Medical Group.

(2) If 9.a.(1) is No, was the action just prior to this one competed? Not applicable

(3) If 9.a.(2) is Yes, what has changed where this action cannot be competed? Not applicable.

b. Additional Information:

Strategic OCONUS Mission Support: RAF Lakenheath operates United States military hospital in the United Kingdom. The 48th Medical Group must provide uninterrupted support to units across the USAFE-AFAFRICA Area of Responsibility,

10. Interested Sources: In response to the Request for Information / Sources Sought Synopsis (Notice ID: HT9406-26-RFI-0001) published on SAM.gov from 15 May to 01 June 2026, the following six (6) sources submitted written capability statements expressing interest in the acquisition:

Rationale for Exclusion of Sources:

As the authority cited is RFO 6.103-1 (Only one responsible source), the capability statements from all sources other than Conexus, Inc. were evaluated and rejected because they could not meet the Government's minimum mandatory requirements for an existing, proven DMLSS interface and a current DHA Authority to Operate (ATO). The sources were rejected for the following specific reasons:

Additional sources that express interest in response to the forthcoming Notice of Intent to Award a Sole Source contract will be reviewed prior to any resultant contract award.

11. 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.

12. Requirements 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.

File details come from the government source that posted it. Updated .