Sole Source Justification - LifeGift.pdf
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- Solicitation number
- 36C25626Q0631
About this file
This is a Request for Sole Source Justification under FAR 12.102(b) for a firm-fixed-price Indefinite Delivery Indefinite Quantity (IDIQ) contract. The Department of Veterans Affairs, through Network Contracting Office 16 (NCO 16) in Houston, Texas, is seeking to procure Organ Procurement Organization (OPO) acquisition fees for the Michael E. DeBakey VA Medical Center (MEDVAMC). The requirement covers organ recovery services for liver, kidney, and heart transplants performed at MEDVAMC for its veteran patient population. The contract is a single-award IDIQ with a five-year ordering period beginning June 1, 2026.
LifeGift Organ Donation Center, located at 2510 Westridge Street, Houston, Texas 77054, is designated as the sole OPO for Southeast Texas and the only responsible source capable of providing this requirement under federal regulations (42 USC 273 and 42 CFR Part 486, Subpart G). The justification establishes that LifeGift is the Medicare-certified OPO for MEDVAMC's geographic catchment area and no other entity in the Houston region may legally provide organ procurement and recovery services. Fair and reasonable pricing will be determined in accordance with FAR 12.204(a) based on Medicare-established Standard Acquisition Charges (SACs), which are benchmarked to Medicare reimbursement policies. The acquisition ID is 36C256-26-AP-3089, with requisition number 580-26-3-200-0357, and the justification was approved for procurement value between $900,000 and $90 million.
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| File | Type | Posted |
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| 36C25626D0063.docx | DOCX document |
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Effective Date: 12/30/2025 Page 1 of 5 Revision: 02 Acquisition ID#: 36C256-26-AP-3089
Request for Sole Source Justification
DEPARTMENT OF VETERANS AFFAIRS
SOLE SOURCE JUSTIFICATION UNDER SIMPLIFIED PROCEDURES FOR CERTAIN
COMMERCIAL ITEMS IN ACCORDANCE WITH FAR
Acquisition Plan Action ID: 36C256-26-AP-3089 – Organ Procurement Organization (OPO)
1. Contracting Activity: Department of Veterans Affairs Network Contracting Office 16 (NCO 16) 5075 Westheimer Road, Suite 750 Houston, TX 77056
Organizational Activity: Department of Veterans Affairs, VISN 16 Michael E. DeBakey VA Medical Center (MEDVAMC) Houston, TX 77030
Requisition Number: 580-26-3-200-0357
Nature and/or Description of the Action Being Processed:
The Michael E. DeBakey VA Medical Center (MEDVAMC) at 2002 Holcombe Boulevard, Houston, TX 77030 is in need of a firm-fixed-price Indefinite Delivery Indefinite Quantity (IDIQ) contract for the OPO acquisition fees associated with the recovery of organs (Liver, Kidney, and Heart) for transplant operations. This organ acquisition fee requirement is essential for patients at MEDVAMC that are scheduled or waiting for an organ transplant procedure. This proposed single award IDIQ contract will be for the OPO fees associated with the recovery of organs through a sole source acquisition to be designed for OPO LifeGift Organ Donation Center (LifeGift).
This procurement is for source OPO acquisition fees in accordance with
Description of Supplies/Services Required to Meet the Agency’s Needs:
MEDVAMC in Houston, TX has (Liver, Kidney, and Heart) transplant program available to its Veteran patient population. In order to perform a transplant operation, the organ itself must be procured.
Effective Date: 12/30/2025 Page 3 of 5
Acquisition ID#: 36C256-26-AP-3089 delay patients' treatment plans, deter the patients' safety, and increase the potential risk of expirations of patients.
Description of Efforts Made to ensure that offers are solicited from as many potential sources as deemed practicable:
Due to federal regulations, Full and Open Competition is not needed when only one source can provide the requirement. LifeGift is the sole OPO for the MEDVAMC, as obligated by federal regulations and no other entity in the Houston, TX region may provide this requirement. An Intent Notice to sole-source this acquisition will be posted to the SAM.gov website.
Determination by the CO that the Anticipated Cost to the Government will be Fair and Reasonable:
LifeGift is the sole OPO for the MEDVAMC, as obligated by federal regulations under The donation and recovery of organs and tissues requires OPO to comply with both state and federal regulations. Fair and reasonable pricing will be determined in accordance with FAR . Pricing will be evaluated to be fair and reasonable based on Medicare rates. Medicare program has established policies which support organ transplantation by providing an equitable means of payment for the variety of organ acquisition services required to support quality transplant programs. Therefore, Standard Acquisition Charges (SACs) would be consider reasonable and necessary costs associated with acquiring the organ (i.e., organ acquisition costs). Medicare reimbursement policies—such as SACs—guide the pricing used by OPOs. Since LifeGift’s fees are benchmarked to Medicare-established rates, these prices are considered reasonable and necessary under government reimbursement policies.
Description of the Market Research Conducted and the Results, or a Statement of the Reasons Market Research Was Not Conducted:
Market research was conducted and it was determined that LifeGift is the sole OPO for MEDVAMC catchment area of Southwest Texas, as obligated by federal regulations for the Houston, TX region.
Therefore, LifeGift is the one responsible source that may provide this requirement.
Any Other Facts Supporting the Use of Other than Full and Open Competition:
LifeGift is the only designated OPO for MEDVAMC geographic location.
Listing of Sources that Expressed, in Writing, an Interest in the Acquisition:
Lifegift Organ Donation Center 2510 Westridge Street Houston, TX 77054
Effective Date: 12/30/2025 Page 5 of 5
Acquisition ID#: 36C256-26-AP-3089
c. Director of Contracting: I certify the justification meets the requirements for other than full and open competition.
Network Contracting Office 16 (NCO 16)
d. VHA Advocate for Competition and RPO HCA Review and Approval: I have reviewed the foregoing justification and find it to be complete and accurate to the best of my knowledge and belief and approve $900K to $90 million for other than full and open competition.
Executive Director, Regional Procurement Office Central Head of Contracting Activity (HCA)
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