S03 CMOP Brand Name J_A_Fully Signed_Redacted_8.26.25_.pdf

Zebra Industrial Barcode Printers VA-25-00096432

JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY

1. Contracting Activity: Department of Veterans Affairs (VA) Office of Procurement, Acquisition, and Logistics Technology Acquisition Center 23 Christopher Way Eatontown, NJ 07724

2. Description of Action: The proposed action is for the issuance of a firm-fixed price delivery order to be issued under the National Aeronautics and Space Administration (NASA) Solutions for Enterprise-Wide Procurement (SEWP) V Government-Wide Acquisition Contract (GWAC) for the procurement of various brand name Zebra industrial barcode printers.

3. Description of the Supplies or Services: The VA, Consolidated Mail Outpatient Pharmacy (CMOP) has a base requirement for 31 brand name Zebra 220Xi4 industrial barcode printers, 34 Zebra ZT 231 industrial barcode printers, and 52 Zebra ZT 411 industrial barcode printers. The seven CMOP locations function as a virtual extension of VA Medical Center pharmacies and provide approximately 80% of all outpatient prescriptions to Veterans via mail. On average, all CMOPs collectively fill approximately 130 million prescriptions annually, necessitating the use of high-speed barcode printers.

These barcode printers are utilized to print shipping labels, patient labels, and Food and Drug Administration (FDA)-mandated medication guides that address specific issues related to drugs and drug classes, containing FDA-approved information about the medications. The only known industrial barcode printers which can interoperate with CMOPs proprietary automated order processing and mail delivery system are the Zebra 220Xi4, Zebra ZT 231, and Zebra ZT 411. CMOPs are a critical resource for veteran medication requirements that have a delivery requirement of no more than 10 days, and no downtime can occur for testing new devices to determine compatibility. The Contractor shall provide the industrial barcode printers and support services as well as provide optional quantities of additional industrial barcode printers and support services, up to 100 for each of the industrial barcode printers; if the Government exercises option(s). Optional quantities may be exercised at any time, from time to time, within 24 months after receipt of award up to the not to exceed maximum quantity. The total estimated price of the proposed action, including the base requirement and optional quantities, is

4. Statutory Authority: Pursuant to Federal Acquisition Regulation (FAR) 16.505(a)(4), the following brand name requirement is being justified and approved as an exception to fair opportunity under the statutory authority of Section 41 U.S.C. 4106(c)(2) as implemented by FAR 16.505(b)(2)(i)(B), entitled “Only one awardee is capable of providing the supplies or services required at the level of quality required because the supplies or services ordered are unique or highly specialized”.

5. Rationale Supporting Use of Authority Cited Above: Based on market research, as described in Section 8 of this justification, it was determined that limited competition is available for this procurement. The proposed industrial barcode printers are the only devices tested and validated to interoperate with CMOP automated system. The CMOP automation system is used to manage and dispense a high volume of prescriptions for veterans. The proposed Zebra barcode printers are the only known devices that are interoperable with the VA CMOP proprietary automation software.

If VA were to pursue a procurement of alternative brands of industrial barcode printers, which are not currently interoperable with the VA CMOP automation software infrastructure, the cost is estimated to be a minimum of $1.125 million. These estimates are based on previous acquisitions of labor and software reconfiguration by the CMOP automation software vendor. This cost would not be recovered through competition.

More importantly, testing new industrial barcode printers would cause substantial, unnecessary delays and obstruct critical medical support to 330,000 Veterans every work day. Failure to provide the brand name Zebra industrial printers will result in an inability to print medication labels, and FDA mandated patient instructions that are required with each mail out. Procuring alternative brands of industrial barcode printers would not only incur substantial costs but also impose significant risks to the timely and efficient delivery of medical services to Veterans. The implementation of new printers necessitates extensive testing for interoperability. Testing new devices for interoperability is estimated to require a minimum of one year, which will result in unacceptable downtime and extended delay of processing Veteran medication refills.

Each CMOP and printer would require modifications and interoperability testing to determine compatibility. In order to complete the interoperability and compatibility testing the production facility would need to be taken offline leading to a drastic reduction in pharmacy orders being completed on time. Loss of production in CMOP automation will result in unacceptable delays in filling and delivering required medications to Veterans. This can also result in a net increase of cost to VA as the healthcare facilities would have to fill these prescriptions, resulting in reduced service, and increased waiting times for Veterans. This will result in longer wait times for veterans needing immediate assistance, and increased potential for human error.

Veterans will experience delays in receiving their prescribed medications, which could affect their health outcomes, and lead to deterioration in their health conditions. Without the brand name Zebra industrial barcode printers, it would result in unacceptable delays and a substantial reduction of necessary medication filling and delivery services to Veterans.

6. Efforts to Obtain Competition: Market research was conducted, details of which are in Section 8 of this justification. This effort did not yield any additional sources that can meet the Government’s requirements. However, the undersigned VA technical representative determined that limited competition is available among authorized resellers for brand name Zebra industrial printers, as well as software maintenance and support. In accordance with FAR 16.505(a)(4)(iii)(A)(1), this justification will be provided with the solicitation to all appropriate NASA SEWP V GWAC holders. Furthermore, in accordance with FAR 5.301, 16.505(b)(2)(ii)(D), and 16.505(a)(4)(iii), the award notice for this action will be synopsized on the Contract Opportunities website and this justification will be made publicly available within 14 days of award.

7. Actions to Increase Competition: The Government will continue to perform market research to determine if there are any products and/or source providers available that will enable future requirements to be competed.

8. Market Research: In July 2025, VA technical experts performed web-based market research to review similar products, including those from Honeywell International Inc (Honeywell), SC Auto ID Technology Co., Ltd. (TSC) and SATO America. After review, it was determined that hardware from other brand manufactures are incompatible with the VA CMOP automation system and specifically the proprietary software in use at the CMOPs. Any new brand name would necessitate substantial duplication of time and costs as detailed above in order to integrate within the existing VA infrastructure. This would also lead to a substantial reduction in pharmacy orders being fulfilled for Veterans.

Additional market research was conducted by utilizing the NASA SEWP V Provider Lookup Tool which identified several SDVOSB contract holders who are resellers of the required brand name Zebra products. Furthermore, the NASA SEWP V GWAC has a dynamic catalog where line items can be added based on customer requests; therefore, if the required item or service is within scope of the NASA SEWP V GWAC, items and services can be added to the catalog daily. As a result, there is reasonable expectation that limited competition exists on the NASA SEWP V GWAC for the brand name Zebra 220Xi4 industrial barcode printers, Zebra ZT 231 industrial barcode printers, and Zebra ZT 411 industrial barcode printers. VA intends to issue a Request for Quotation as an SDVOSB set-aside to all SDVOSB NASA SEWP V GWAC contract holders under Groups B, C, and D.

9. Other Facts: None

Approval In my role as procuring activity Advocate for Competition, based on the foregoing justification, I hereby approve the acquisition of various brand name Zebra industrial barcode printers, and Zebra ZT 411 industrial barcode printers on an other than fair opportunity 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.