JA-ECRI 20191022 ver2_LS FINAL_Redacted.pdf

Justification and Approval for Other than Full and Open Competition ECRI PriceGuide and Health Devices Gold Subscription Services

SOURCE SELECTION INFORMATION – SEE 2.101 AND 3.104

The ECRI Institute is a member based non-profit organization that member organizations (commercial hospitals) submit their purchase history to for aggregation and sharing among members. ECRI accumulates spend information for over 2 million unique medical/surgical items through a business model that incentivizes thousands of commercial hospitals to send their purchase price guidance to ECRI on a monthly basis.

Anonymous price and facility counts are then provided to the MedPDB build via the PriceGuide download. ECRI employs very strict rules to avoid conflicts of interest with its participating entities to ensure that recipients receive trusted guidance. No other current supplier has demonstrated conformance to rigorous standards and customer availability of comprehensive collated data pools.

Another unique and highly specialized aspect of ECRI data is that items in the ECRI data are reported as received from commercial sites and the raw name and part number references are then synchronized to federal master items that are recognizable to DoD and VA medical/surgical buyers. Commercial pricing benchmarks are also available in the MedPDB interface and include “12-month Commercial Average Price” and “12-month Commercial Low Price” for DoD and VA users browsing at the item level and Best Price analysis with links to site level cost avoidance opportunities. Benchmarks are included in monthly reports including DLA Enterprise Price Effectiveness Metrics and price comparison reports that DoD and VA contracting personnel utilize to assist in determining fair and reasonable negotiation targets. Commercial pricing benchmarks are often requested in ad hoc report requests from DoD and VA MedPDB users. The platform on which this guide is available is fully interoperable with both the DoD and VA medical IT systems. No other provider has demonstrated a solution that is interoperable across the DoD and VA systems.

While other data subscriptions may be available, none have demonstrated conformance to the rigorous standards and comprehensive collated data pools required by the DLA customer in support of this requirement. Additionally, no other provider has demonstrated the ability to successfully pair their solution with the IT system needs and demands of two independent Agency platforms (DoD and VA). Because the fields and formats of alternate data subscriptions may be substantially different from those currently in use, use of an alternate subscription would require significant analyst and developer labor costs for feasibility analysis, redesign, and recoding of current system logic and change management processes. Consequently, use of any medical/surgical product data subscription other than the highly specialized ECRI data subscriptions currently in use would result in a significant duplication of cost to the Government.

6. DESCRIPTION OF EFFORTS MADE TO ENSURE THAT OFFERS ARE

SOLICITED FROM AS MANY POTENTIAL SOURCES AS IS

PRACTICABLE, INCLUDING WHETHER A NOTICE WAS OR WILL BE

PUBLICIZED AS REQUIRED BY SUBPART 5.2 AND, IF NOT, WHICH

EXCEPTION UNDER 5.202 APPLIES.

A synopsis will be posted to beta.SAM.gov website to provide all commercial entities an opportunity to submit proposals for this requirement.

SOURCE SELECTION INFORMATION – SEE 2.101 AND 3.104

7. DETERMINATION BY THE CONTRACTING OFFICER THAT THE

ANTICIPATED COST TO THE GOVERNMENT WILL BE FAIR AND

REASONABLE.

As the Contracting Officer, I hereby determine that pricing will be fair and reasonable based on a pricing analysis in accordance with FAR 15.404-1. It is anticipated that the Government will perform a comparison of the proposed price with prices charged to the third-party contractor previously responsible for procuring the medical/surgical product pricing data feed in the Research and Development phase of the MedPDB, as well as a comparison to other raw data subscription providers, less data normalization and/or benchmarking services.

8. DESCRIPTION OF THE MARKET RESEARCH CONDUCTED (SEE PART

10) AND THE RESULTS OR A STATEMENT OF THE REASON MARKET

RESEARCH WAS NOT CONDUCTED.

The DLA Troop Support Medical Directorate conducted market research to compare service offerings of the incumbent vendor (ECRI) with alternative solutions existing in the industry. Market research techniques included a review of acquisition history for contracts used by the directorate to procure similar services and searching the FedBizOpps and GSA websites for other vendors with similar data service offerings.

Primary comparative factors used to analyze alternatives included technical service offerings, functional familiarity, and cost to the directorate.

Alternative subscription services considered included the Cardinal Health Care IQ Informatics (HCIQ) product as well and IQVIA (Formerly IMS):

Cardinal HCIQ Informatics provides some of the benchmarking data that the Government requires as well as the ability to provide comparisons and product cross-references of the limited data. It is also not know if this software is interoperable with both the DoD and VA IT frameworks. These limitations prove to be unacceptable to the continuance of the Government’s mission.

IQVIA commercial sales data is aggregated based only on average benchmark pricing, while in contrast, the ECRI PriceGuide medical cost benchmarking system provides both low and average benchmark pricing. It is also not known if this software is interoperable with both the DoD and VA IT frameworks. These limitations prove to be unacceptable to the continuance of the Government’s mission.

As a result of the market research conducted, it was determined that the current marketplace offerings do not meet the specialized and unique needs of the Government and are therefore not viable options for the current Government requirement. The DLA requiring activity determined that a continuation of the subscription services provided by the ECRI PriceGuide medical supply benchmarking system was best suited to meet the Government’s needs for a medical data feed subscription that will provide comprehensive medical/surgical sales data.

SOURCE SELECTION INFORMATION – SEE 2.101 AND 3.104

9. ANY OTHER FACTS SUPPORTING THE USE OF OTHER THAN FULL

AND OPEN COMPETITION.

In addition to the highly specialized and unique solution provided by ECRI, the original programming cost for MedPDB to include the ECRI benchmarking data was $6.3M in 2008-2009. Following the Government investment in the MedPDB, subsequent feasibility analysis demonstrated that if an alternate feed is found viable, the subsequent redesign and recoding costs would exceed $7.8M. Therefore, development of a new solution that provides all customer demands and interoperability across two independent agency platforms would be a duplicative cost effort.

There have not been significant market emergences since the initial feasibility study which would indicate a greater cost savings to the Government. The Government’s initial MedPDB investment in 2008-2009 has far exceeded standard IT software/subscription program lifecycles at great cost savings to the Government.

Exploratory investment in new software would result in a significant duplication of cost and negative impact on customer mission critical goals.

10. LISTING OF THE SOURCES, IF ANY, THAT EXPRESSED, IN WRITING,

AN INTEREST IN THE ACQUISITION.

ECRI Institute.

11. 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.

At this time, the ECRI solutions to this Government requirement are the only services that will support DLA’s requirements and meet the Government’s needs. However, DLA has exercised, and continues to exercise, competition as often as possible and is required to conduct ongoing reviews to keep abreast of new technology, both in industry and the Government. As a continuing effort, DLA utilizes a variety of vendors, manufacturers, and contracts to fulfill its requirements and will continue the practice of surveying the market to ensure full and open competition to the maximum extent practicable.

SOURCE SELECTION INFORMATION – SEE 2.101 AND 3.104

12. CONTRACTING OFFICER CERTIFICATION THAT THE JUSTIFICATION

IS ACCURATE AND COMPLETE TO THE BEST OF THE CONTRACTING

OFFICER’S KNOWLEDGE AND BELIEF.

Technical and Requirements Certification

I hereby certify that the supporting data provided for which I am responsible and which form a basis for this justification are complete and accurate:

Date

I hereby certify that the information contained in this justification is accurate and complete to the best of my knowledge and belief.

Date

Contracting Officer