redacted_J&A_W81K00-17-T-0092.pdf

Control Number: 17-RHCO-C-308

For Official Use Only (See FAR 2.101 and 3.104-4)

(25 February 2016)

Sole Source Justification and Approval Under FAR 13.501

1. Contracting Activity: Regional Health Contracting Office – Central, Carl R. Darnall Army Medical Center (CRDAMC), Fort Hood, TX 76544.

2. Description of Action: Issue a bridge contract for Non-Personal Medical Transcription Services. This action will be accomplished through the use of a firm fixed-priced contract funded with DHP Funds.

3. Description of Supplies/Services: William Beaumont Army Medical Center (WBAMC) has a requirement to continue services for Medical Transcription services (i.e. off-site medical transcription).

This service is provided 24 hours a day, 7 days a week via the Nuance Dictaphone/Transcription dictation system and Composite Health Care System (CHCS) ESSENTRIS for WBAMC. This requirement is for a one year period, Period of Performance: 1 April 2017 – 31 March 2018, plus a potential six month extension per FAR 52.217-8, “Option to Extend Services”, through 30 September 2018, with a total estimated value of $.

4. Authority Cited: 41 United States Code 1901 as implemented in Federal Acquisition Regulation 13.501(a)(1)(ii), sole source (including brand name) under the authority of the simplified procedures for certain commercial items.

5. Reason for Authority Cited: Contract W91YU0-14-P-0679 is currently in place for Medical Transcription services, which will expire on 31 March 2017; the contract included FAR Clause 52.217-8, Option to Extend Services, which has been exercised for the maximum 6 month extension. The purpose of this contract action is for the continuation of services until the MEDCOM competitive contract is awarded by the RHCO-C Contracting Office. In mid-February 2017, the Fort Hood Cell was informed that the WBAMC Medical Transcription contract will not be completed before the current contract expiration date, therefore a “bridge” is needed to ensure continued services. The time of notification that the WBAMC Medical Transcription services contract was not going to be complete before the expiration of the current contract does not allow ample time for the Government to adequately plan for the acquisition, nor sufficient time to properly execute a competitive procurement, and does not allow proper timeframe for transition to a potential new offeror. There are certain barriers that would be impossible for another source to perform the Government’s requirement by contract start date, as specified below:

a. The requirement calls for multiple Information Technology (IT) and security requirements that must be met prior to accessing the Composite Health Care System (CHCS) ESSENTRIS systems at WBAMC.

b. Contractor must submit and mail their information technology (IT) equipment to WBAMC IT security staff for equipment validation and software upload.

c. Contractor will need to submit their security background check and gain approval in order to access the WBAMC network for transcription workload.

d. The Contractor must be able to obtain and provide proof of a Certificate of Networthiness (CoN).

e. Contract employees must fully adhere with the provisions of DoD Directives, including AR 25-2, which identifies issuance of the common access card (CAC) as the authoritative source for

(Medical Transcription Services, WBAMC) account provisioning. This is accomplished by making an appointment (through the COR) with the appropriate security organization at the installation and is mandatory for these ADP Sensitive positions.

f. The Business to Business (B2B) Agreement must be completed, established and approved.

Given the nature of the services and the amount of coordination required to prevent a disconnect in service, particularly the requirement to submit and mail the Contractor’s information technology (IT) equipment to the WBAMC IT security staff for equipment validation and software upload, a transition of this service from one contract company to another is anticipated to take approximately two to three months.

A lapse in service would have an immediate negative impact, and potential mission failure in providing current health care operations and current health care services to our soldiers, civilians, and beneficiaries who rely on these services.

WBAMC does not have a sufficient workforce to absorb the negative impact that a lapse in services would effect. The incumbent contractor, Isom Enterprises, Inc., is able to provide uninterrupted services immediately following this award, which results in no disruption, delay, or harm to the Government, soldiers, civilians, and beneficiaries.

6. Efforts to Obtain Competition.

a. Effective competition: To ensure offers are solicited from as many potential sources as is practicable, the proposed follow-on action will be posted to FEDBIZOPPS. No other efforts are being made to obtain competition as only one responsible source, Isom Enterprises, Inc., is capable of meeting the minimum requirement prior to the expiration of the current contract.

b. Subcontracting competition: In accordance with FAR Subpart 19.705-2, the Contracting Officer has taken actions to determine whether the proposed contractual obligation requires a sub-contracting plan.

According to System for Award Management (SAM), the incumbent contractor is a Woman Owned Small Business (WOSB) and a sub-contracting plan does not apply.

7. Actions to Increase Competition: It is not possible to compete the proposed acquisition in time for services to commence on 01 April 2017.

8. Market Research: Market Research was conducted by posting a Sources Sought Notice on FedBizOpps from 22 February 2017 to 27 February 2017 for a total of five days. A total of seven vendors responded to the notice, however, in this instance, award to any other vendor rather than the incumbent, would be detrimental to healthcare services at WBAMC, the DoD, and all beneficiaries, resulting in unacceptable delays and service disruption.

9. Interested Sources: Seven vendors responded to the Sources Sought: Isom Enterprises Incorporated (Incumbent), Perry Johnson & Associates, Inc., Genesis Government Solutions, Inc., Goodwill Industries of San Antonio, Alpha Transcription, Shivan Technologies Inc., and AlgorithmsPlus, LLC. All vendors’ capabilities were reviewed and fully considered. Also, each vendor was contacted via email to see if they were able to meet the IT and Security requirements. The vendor’s responded they could meet the IT and Security requirements, however, due to the mandatory requirements to submit and mail their information technology (IT) equipment to WBAMC IT security staff for equipment validation and software upload;

obtain and provide proof of a Certificate of Networthiness (CoN) prior to commencement of services, there is not sufficient time for the contractors to perform with a 1 April 2017 start date.

10. Other Facts

a. Procurement history. This procurement is to provide non-personal Medical Transcription services (i.e. off-site transcription services). This service is provided 24 hours a day, 7 days a week via the Nuance Dictaphone/Transcription dictation system and Composite Health Care System (CHCS) ESSENTRIS for William Beaumont Army Medical Center (WBAMC) by a Certified Medical Transcriptionist (CMT). Current contract W91YU0-14-P-0679 was competed and awarded on 30 September 2014 with a period of performance of 1 October 2014 to 30 September 2016 and was extended for six months through 31 March 2017 per FAR 52.217-8, “Option to Extend Services”. The current vendor is a WOSB.

(1) Contract number and date of current award. W91YU0-14-P-0679, 1 October 2014 – 31 March 2017, $673,312.50.

(2) The competitive status of these actions. Competed 100% Small Business Set-Aside

(3) Authority previously cited if less than full and open competition was used. N/A

(4) If a justification was prepared to support the procurement made before this one, a summary of the contents of paragraph 7 of the justification for that procurement and an explanation of the results. N/A

(5) If any prior contract for this requirement was accomplished using full and open competition, include a detailed explanation of the changed circumstances causing this action to now limit the sources.

Given the nature of the services and the amount of coordination required to prevent a disconnect in service, i.e., Information Technology (IT) (the mandatory requirements to submit and mail their information technology (IT) equipment to WBAMC IT security staff for equipment validation and software upload); obtain and provide proof of a Certificate of Networthiness (CoN) prior to commencement of services, the transition of this service from one contract company to another is anticipated to take approximately two to three months.

(6) An explanation of any unusual patterns that may be revealed by the history, e.g., several consecutive, urgent buys. N/A

(7) If a justification was prepared to support the procurement made before this one, briefly describe the circumstances justifying the procurement and whether there have been any significant changes. N/A

b. Other facts. The performance work statement (PWS) for this contract is the same as the PWS for the current contract and may include changes to points of contact, and those required by law or regulation.

11. Technical Certification:

I certify that 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 that the supporting data under my cognizance, which are included in the justification are accurate and complete to the best of my knowledge and belief.

13. Fair and Reasonable Cost Determination:

I hereby determine that the anticipated cost to the Government for this contract action will be fair and reasonable. Fair and reasonable pricing will be determined by using price analysis and the Independent Government Estimate. As part of the basis, certified cost or pricing data is not required per FAR 15.403- 1(b)(3).

14. Contracting Officer Certification: I certify that this justification is accurate and complete to the best of my knowledge and belief.