SAM.gov Posting JA FAR Part 6 Four Points Technology_Redacted.pdf

DEPARTMENT OF VETERANS AFFAIRS (VA)

Office of Procurement, Acquisition and Logistics (OPAL)

Strategic Acquisition Center (SAC) 5202 Presidents Ct, Suite 103

Frederick, MD 21703

JUSTIFICATION AND APPROVAL

FOR OTHER THAN FULL AND OPEN COMPETITION

(1) Identification of the agency and the contracting activity, and specific identification of the document as a "Justification for Other Than Full and Open Competition."

This Justification and Approval (J&A) for Other Than Full and Open Competition is executed by the Strategic Acquisition Center in Frederick, Maryland on behalf of the Department of Veterans Affairs (VA) Veterans Health Administration (VHA)’s Office of Health Informatics (OHI), Electronic Health Record Modernization (EHRM).

(2) Nature and/or description of the action being approved.

This activity proposes to negotiate a non-competitive award (sole-source) to Four Points Technology, LLC, a Service-Disabled Veteran-Owned Small Business (SDVOSB), for the procurement of site planning services in support of Operational Readiness Assessment (ORA) activities at VA Medical Centers under the auspices of Veterans Health Administration (VHA) Office Of Health Informatics (OHI) Electronic Health Record Modernization (EHRM) activities.

Led by OHI, this specific collaboration between EHRM Integration Office (IO) and VHA will identify and communicate specific unmet needs in clinical processes necessary for successful go-live of new Electronic Health Record (EHR) at one or more VA Medical Centers (VAMC).

(3) A description of the supplies or services required to meet the agency’s needs (including the estimated value).

The estimated value for this acquisition is $ , which is under the $5 million threshold for the use of Public Law 109-461: “Veterans Benefits, Health Care, and Information Technology Act of 2006” specifically, the “Veterans First Contracting Program” outlined in 38 USC §8127(c) which permits a contracting officer to award a contract to a verified SDVOSB in a sole source manner when other criteria are met.

Four Points Technology, LLC will provide specific site planning and communication services to carry out duties and responsibilities as part of OHI EHRM’s overall ORA support services to ensure the successful implementation of the EHR, Oracle Health Millennium. The range of services required include subject matter expertise from project managers, management analysts and systems analysts with skill sets and experience that comply with and respond to requirements including current, updated program plans and documentation for conducting and communicating operational readiness assessments.

A Teamlet group consisting of an assessor (government employee), scribe, and coordinator (who will arrange and schedule the interviews) will conduct a maximum of seven (7) interviews in a workday. These interviews will be conducted with VHA personnel in an effort to provide guidance in operational readiness preparedness and support of the EHRM program. The purpose of the Teamlet’s interviews is to take an active role in defining, evaluating, and

Strategic Acquisition Center (SAC) preparing their facilities in go-live readiness. The contractor, Four Points Technology, LLC, will conduct data analysis and management and shall conduct qualitative analysis and prepare results for presentation and upload into the EHRM-IO dashboard. Four Points Technology, LLC will engage and assess stakeholder communities during site assessment tasks, processes, and plans needed for successful adoption of Oracle Health Millennium EHR using and enhancing the existing VHA Operational Readiness Assessment tool.

(4) An identification of the statutory authority permitting other than full and open competition.

The statutory authority permitting other than full and open competition for this procurement is 41 U.S.C.§ 253(c)(5) as implemented by the Federal Acquisition Regulation (FAR) Subpart 6.302-5 entitled, “Authorized or required by statute”. The applicable statute is Public Law 109-461:

“Veterans Benefits, Health Care, and Information Technology Act of 2006” specifically, the “Veterans First Contracting Program” outlined in 38 USC §8127(c).

38 U.S.C. 8127(c) permits a contracting officer to award a contract to a verified SDVOSB using procedures other than competition if:

(1) such concern is determined to be a responsible source with respect to performance of such contract opportunity;

(2) the anticipated award price of the contract (including options) will exceed the simplified acquisition threshold (as defined in section 134 of title 41) but will not exceed $5,000,000.00; and

(3) in the estimation of the contracting officer, the task order award can be made at a fair and reasonable price that offers best value to the United States.

The proposed action meets all three (3) of the requirements of 38 U.S.C. 8127(c).

Four Points Technology, LLC is also registered and verified in VetCert. As such, Four Points Technology, LLC is determined to be a responsible source with respect to performance of this requirement. Specifically, Four Points Technology, LLC has experience supporting VA and providing qualified personnel capable of meeting the data analysis essential to the successful performance of this requirement.

The anticipated total estimated award price of the task order, including options, is $ , which is within the statutory $5,000,000.00 threshold.

(5) A demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited.

The proposed source for this acquisition is, Four Points Technology, LLC, which has been certified by VetCert as an SDVOSB. Four Points Technology, LLC offers the types of support

Strategic Acquisition Center (SAC) accordance with Public Law 109-461, Section 502(c) meets the requirements of this statute to allow a sole source to a SDVOSB.

In addition, the Federal Awardee Performance, and Integrity Information System (FAPIIS) was reviewed and FAPIIS shows no reports for Four Points Technology that would indicate defective pricing, instances of contractor fault or recipient not- qualified, terminations for cause, default, material failure to comply, or non-responsibility of the contractor.

(9) Any other facts supporting the use of other than full and open competition.

The Procuring Contracting Officer has determined that this proposed action meets all the requirements of 38 U.S.C. 8127(c). This acquisition is below the $5,000,000.00 threshold, Four Points Technology, LLC is a responsible SDVOSB for performance of the services described herein, and the proposed task order can be awarded at a fair and reasonable price.

(10) A listing of the sources, if any, that expressed, in writing, an interest in the acquisition.

Although an Intent to Sole Source was posted to sam.gov with an active period of 01/18/2024 through 01/29/2024, no responses were received expressing an interest in this procurement action.

(11) A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition for the supplies or services required.

All future requirements will be handled on a case-by-case basis. Toward the expiration of this task order, consideration will be given as to whether the future acquisition should be competitive.

Strategic Acquisition Center (SAC)

(12) Certifications/Signatures

Technical Representative Certification:

I certify that the foregoing justification is complete and accurate to the best of my knowledge and belief.

Serge Yee Date Health System Specialist, VHA

Pursuant to FAR 6.303-2(a)(12), I certify that this justification is accurate and complete to the best of my knowledge and belief.

Signature: _________________________________ Date: ____________ Caitlin Ruc Contracting Officer, Strategic Acquisition Center - Frederick

Approval

In my role as Contracting Activity Competition Advocate, based on the foregoing justification, I hereby approve this acquisition on an “other than full and open competition” basis pursuant to the statutory authority cited in paragraph four above, subject to availability of funds, and provided that the property and services herein described have otherwise been authorized for acquisition. As this action does not exceed $15M, the certification below required by FAR 6.304 serves as approval.

Signature: _________________________________ Date: ____________ Mr. Efrain J. Fernandez Director of Contracting and Competition Advocate Strategic Acquisition Center—Frederick Tracking Number: 24F-0067a

SERGE YEE Digitally signed by SERGE YEE Date: 2024.02.20 17:18:25 -05'00'

CAITLIN RUC Digitally signed by CAITLIN RUC Date: 2024.02.21 08:32:12 -05'00'

EFRAIN FERNANDEZ Digitally signed by EFRAIN FERNANDEZ Date: 2024.02.21 10:08:23 -05'00'