JA_MMAST_ACC_ORL_15-033_Redacted.pdf
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- Q--Medical Modeling and Simulation Training (MMAST) Support Services_Justifcation and Approval Posting
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- W900KKMMASTNOTICEOFINTENT
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Control No.: ACC ORL 15-033
Simulation Training program that provides support services at 22 CONUS and OCONUS locations. The intent of this contract action is to place the required MMAST support services for the Navy MMAST program and the Air Force Aeromedical Evacuation (AE) MMAST program on contract W900KK-14-C-0007. The Period of Performance (PoP) is anticipated to begin 27 SEP 15 and be complete not later than 15 September 2018, if all options are exercised.
Subsequent to contract award, the Navy’s Program Management Office (PMO) for MMAST support services changed locations from Jacksonville, FL to Joint Base San Antonio – Randolph, TX. The Navy’s MMAST PMO personnel now sit collocated and is integrated with the Air Force’s MMAST PMO personnel. This action is a direct result of newly established Defense Health Agency (DHA), the requiring activity, absorbing the requirement for both the Navy and Air Force’s MMAST programs. The DHA was established in FY14 to support the delivery of integrated, affordable, and high quality health services to Military Health System (MHS) beneficiaries and is responsible for driving greater integration of clinical and business processes across the MHS. This is accomplished by implementing shared services with common measurement of outcomes; enabling rapid adoption of proven practices, helping reduce unwanted variation; and, exercising management responsibility for joint shared services.
a. Navy Requirement: The Navy requires 8 MMAST PWS task support at 12 locations. This action will not add any Performance Work Statement (PWS) tasks to contract W900KK-14-C-0007. It is comprised of the same PWS tasks on contract W900KK14-D-0007, in support of the same mission; develop and use advanced learning technologies and methodologies to improve medical education and training for healthcare teams and patients, for the purpose of improving healthcare outcomes. The following outlines the required PWS task and respective locations for the Navy MMAST program.
(1) Program Execution and Oversight - Program Management Office, Joint Base San Antonio- Randolph, Texas
(2) Program Analysis and Development/Execution and Oversight - Program Management Office, Joint Base San Antonio- Randolph, Texas
(3) Program Analysis and Development Management - Program Management Office, Joint Base San Antonio- Randolph, Texas
(4) Program Analysis & Development and Administration -Program Management Office, Joint Base San Antonio- Randolph, Texas
(5) Curriculum Execution and Oversight - Naval Medical Center Portsmouth
(6) Curriculum Management - Program Management Office, Joint Base San Antonio- Randolph, Texas
(7) Logistics/Resources - Program Management Office, Joint Base San Antonio- Randolph, Texas
(8) Simulation Operation
Naval Medical Center Portsmouth Naval Hospital Camp Lejeune Naval Hospital Jacksonville Naval Hospital Pensacola Naval Medical Center San Diego Navy Undersea Medicine Institute (NUMI) Groton Naval Hospital Camp Pendleton Naval Hospital Bremerton, WA Surface Warfare Medical Institute Naval Expeditionary Medical Training Institute Naval Trauma Training Center-Los Angeles
There are eight different PWS Task identified at 12 locations. However, five of the PWS tasks that provide centralized, programmatic support, outlined directly above, (2, 3, 4, 5 and 7), are currently provided on contract W900KK-14-C-0007. Since the DHA joined the requirement for the Air Force and Navy MMAST programs into one joint program/requirement, and the five PWS task referenced above are able to be filled with MMAST support services that are currently on contract W900KK-14-C-0007, there will be no additional cost to the Government for the contractor to use the current contracted solution for the five referenced PWS requirements. Therefore, the Government will realize a significant cost savings and only be required to provide additional support for three PWS tasks, rather than eight PWS tasks. In addition to reducing duplication of effort, the Air Force and Navy will be able to work towards the DHA goals of consolidating and streamlining administrative and oversight functions for medical education and training programs, initiatives, and schools; coordinate professional development and sustainment programs; and, facilitate centralized training review process to ensure medical education and training is coordinated across the MHS. As described in more detail in below paragraph 5(d)(i), the Navy is currently using contract
This contract does have one option year available from 27 September 2015 – 26 September 2016; however, it does not fully meet the requirements of DHA’s MMAST program. Therefore, the Navy has decided not to exercise the option
b. Air Force Requirement: The Air Force recently identified a training gap that AE Squadrons currently lack simulation training support. The Air Education and Training Command recognized four AE squadrons (Pope Army Air Field, Scott AFB, Kadena AB and Ramstein AB) that require simulation operation support, PWS Task 5.9, to meet critical training requirements and medical readiness. Additionally, PWS task support for curriculum execution is required for simulation scenario development for the AE community at the DHA PMO, located at Joint Base San Antonio – Randolph, TX.
In addition to the above four Simulation Operators and one AE specific Curriculum Developer, the DHA AE MMAST program require the following centralized, programmatic support services:
(1) Program Execution and Oversight
(2) Program Analysis and Development/Execution and Oversight
(3) Program Analysis and Development Management
(4) Program Analysis & Development and Administration
(5) Curriculum Management
(6) Logistics/Resources
The above mentioned requirement to provide centralized, programmatic support for six PWS tasks, required for Air Force AE MMAST portion of the DHA MMAST requirement, can be filled by the current contractor support on contract W900KK-14-C-0007. There will be no additional cost to the Government for the contractor to combine the six referenced PWS requirements. Therefore, the Government will realize a significant cost savings and only be required to provide additional support for two of the PWS task requirements that would otherwise require support for eight PWS tasks.
(1) Duplicate Requirements: As outlined in above paragraph 3(a) and (b), an inability to combine the efforts of the DHA MMAST program’s requirement will result in unnecessary duplication costs for the required centralized, programmatic support equating to an estimated amount of no less than $2,586,840.29.
Duplicate Tasks: Program Analysis and Development/Execution and Oversight;
Program Analysis and Development/Management; Program Analysis and Development/Administration; Curriculum Management; and Logistics/Resources
If the additional MMAST requirements for the Air Force and Navy, outlined within this J&A, are executed on a separate contract action, there will be duplicate requirements to provide centralized, programmatic MMAST support service that is currently on contract W900KK-14-C-0007. This would approximately cost the Government an estimated amount of $2,586,840.29 in duplicate costs. This duplicate cost will be doubled to $5,173,680.58 if the additional MMAST support services for the Navy and Air Force requirements are contracted on two separate contract vehicles, other than W900KK-14- C-0007. This estimation was derived using recent and relevant historical pricing from the current contract providing MMAST support services, W900KK-14-C-0007.
(2) Duplicate Contract Administration Costs: Award to any other source for the required MMAST support services will result in substantial duplication of cost to the Government for contract administration equating to an estimated amount of no less than $539,630.55.
DHA Deputy Director Duplicate Hours:
• ~15hrs per a week
Other DHA Support - Duplicate Hours (Director, NCOIC, SG, Finance, PCO, etc)
• ~ 10hrs per a week
PEO STRI PD (COR) Duplicate Hours:
• ~ 3hrs per a week
Other PEO STRI/ACC Support Support Duplicate Hours (PCO, CS, Finance, PM, Legal, etc)
• ~ 8hrs per a week
If the additional MMAST requirements for the Air Force and Navy, outlined within this J&A, are executed on a separate contract action, there will be duplicate requirements to provide contract administration for the new contract action and W900KK-14-C-0007.
This action will approximately cost the Government, over the proposed PoP of contract, W900KK-14-C-0007, no less than an additional 2.7 man years, equating to amount of $539,630.55. This duplicate cost will be doubled to $1,079,260.20 if the additional MMAST support services for the Navy and Air Force requirements are contracted on two separate contract vehicles, other than W900KK-14-C-0007. Duplicate tasks, divided between several Government Offices include, but are not limited to: weekly telecons, CDRL evaluations, COR reports, QASP input, Contract Discrepancy Reports resolutions, funding transactions, Program Management Reviews, processing of administration contract actions (option exercise, funding only actions), etc. This estimation was derived from coordination with DHA MMAST Program Administrator, Contracting Officer for W900KK-14-C-007, their duly authorized Contracting Officer Representative, using the average fully burdened cost of Government personnel, provided by the MMAST Program Analyst, equating to $199,863 per a man year.
(3) Duplicate Procurement Costs: Competitive award to any source for the required MMAST support services will result in substantial duplication of procurement cost to the Government, totaling 4.21 man years, for an estimated cost of $841,423.23.
This duplicate cost will be doubled to $1,682,846.46 if the additional required MMAST support services, described above, for the Navy and Air Force are competed as separate contract actions.
This estimated cost is based off the Army Contracting Command – Orlando memorandum for Procurement Administrative Lead Time, dated 13 July 2015 and signed by the Principle Assistant Responsible for Contracting, coordination with the Procuring Contracting Officer, and Contracting Officer Representative.
A competitive procurement for the MMAST support services will result unacceptable delays in fulfilling DHA MMAST requirements. Average required lead time for a new competitive action, executed by Army Contracting Command – Orlando (ACC-ORL), is 330 days. This is once the full requirements package is received from the requiring activity and accepted by the cognizant ACC-ORL Division Chief. It is reasonable to state that a duplicate competitive action for MMAST support services would take longer than a year to fulfill. Any break in service will lead to not only a degradation in training capabilities, but also risk orientation and training delays as a result of potentially hiring completely new centralized, programmatic support. Therefore, a negative impact to mission readiness would be realized, immediately.
c. Impact: The aforementioned duplicate costs are significant and provide ample justification to proceed with a J&A. However, the most substantial cost to the Government not proceeding with a J&A will be the detrimental impact it has on the DHA’s MMAST program. If the Government executed a separate contract action, it would not only directly provide duplicate costs to the DHA MMAST program, but also adversely impact the DHA’s MMAST program ability to meet their mission and objectives. The objective of Jointness, Standardization, Efficiency, Innovation, and Readiness is directly compromised by essentially separating the components, Air Force and Navy, of the DHA MMAST program that comprise a single requirement to develop and use advanced learning technologies and methodologies to improve medical education and training for healthcare teams and patients. It is highly unlikely that the Air Force and Navy will be able to efficiently and effectively implement shared services providing for mutual lessons learned and the adoption of innovative, standardized medical procedures. Also, there will not be an opportunity to consolidate and streamline administrative and oversight functions for the DHA’s MMAST medical education and training program, initiatives, and schools; or, coordinate professional development and sustainment programs. Additionally, the ability to facilitate centralized training review process to ensure DHA MMAST medical education and training is coordinated across the program is at least greatly hindered, if not completely dissolved. The objective of Cost Savings will undoubtedly not be met, as the substantial duplicate costs are clearly delineated in the above paragraph 5(b). The Military Health System is a complex system that intricately weaves the separate components together that relies on joint, standardized, and effective medical education shared between components. Failure to meet the DHA’s MMAST objectives will negatively affect the DHA MMAST critical mission of providing joint medical readiness training requirements in support of US National Security Objectives.
d. Alternatives:
(1) Exercise the remaining option on contract : This is the current contract vehicle that the Navy MMAST services are procured on. There is one, priced option year (27 SEP 15 – 26 SEP 16) available for Navy MMAST services, at a cost of , that provides MMAST services. Although this route is less than the proposed contract action with ECS, it is not a viable option as it does not fully meet requirements. As a result, the Navy has determined not to exercise the option.
As described in the above paragraph 3, there are eight different PWS task identified at eleven locations. However, five of the PWS tasks provide centralized, programmatic support and the Navy’s contract, , does not meet this requirement.
Specifically, the DHA joint requirement to provide centralized, programmatic support for standardization and efficiency includes task support for: Program Analysis, &
6. Efforts to Obtain Competition: Based on the information in paragraph 5, above, competition for this immediate action is not feasible. As previously stated, it would result in substantial duplication of costs. Furthermore, if there was a competition for the additional MMAST requirements, the Government wholeheartedly anticipates that ECS would win the award. Not only does ECS have a major competitive advantage with the required centralized, programmatic support currently on contract, but they would also be the only contractor that can fully support the abovementioned DHA MMAST objectives and mission by keeping the requirement for the DHA MMAST program within one contract/contractor. Contract W900KK-14-C-0007 was competed in FY14, as total small business set-aside, with ten offerors. ECS’s proposed solution was far above the other offerors and undoubtedly represented the overall best-value to the Government.
Because of the nature and the scope of the contract remains unchanged, it is reasonable to state that if the additional requirements outlined paragraph 3, above, were included in the initial RFP, ECS would remain the overall best value to the Government.
A synopsis of the additional DHA MMAST requirements was posted to FBO.gov on 13 August 2015. One response was received by and as required by FAR 6.302-1(d), it was considered by the Government. The proposal outlined a base year cost of and a proposal cost of . This proposal does not provide clear and convincing evidence that competition of this action would not result in substantial duplication of cost to the Government for the start-up, hiring, training, execution and administration of the above described support services over the PoP for contract W900KK-14-C-0007. The contractor does not have an understanding of the requirement and their cost proposal does not address the requirements in their entirety. Furthermore, the subcontractor cost for the base year comprises of the total base year cost, . This equates to a 58% subcontractor cost, which does not comply with Federal Regulation, as outlined in FAR clause 52.219-14, Limitations on Subcontracting. proposal fails to meet the DHA’s MMAST program’s objectives of Jointness, Standardization, Efficiency, Innovation, and Readiness; or, the DHA’s mission to implement shared services with common measurement of outcomes; enable rapid adoption of proven practices, helping reduce unwanted variation; and, exercise management responsibility for joint shared services. Additionally, the proposed effort adds substantial duplication of cost to the Government that is not expected to be recovered through competition, as outlined in above paragraph 5(b). Based on the information above, it is not feasible to award the additional requirements to notification also claims that the Government awarding the MMAST requirements to their company would avoid substantial duplication of cost to the Government for the start-up, hiring, training, execution and administration of the required support services. However, there is no cost to the
Government for “start-up” or transition of effort. Furthermore, ECS intends on preserving the initial continuity of the program by providing each incumbent employee the right of first refusal for employment.
Contract W900KK-14-C-0007 was awarded as a total small business set-aside. The contractor uses a team of subcontractors to assist in the filling the requirements, however, ensures to complete over 50% of the work. Because the contract was recently awarded as a total small business set-aside and the contractor showed adequate use of subs at time of award, the Government is not requiring further assurance of competition in subcontracting.
7. Actions to Increase Competition: Army Contracting Command – Orlando, in conjunction with the requiring activities, are currently preparing specifications, inclusive of the requirements of the DHA MMAST program, for competition. Market Research is being performed for the follow-on requirement to identify all potential sources. This RFP is anticipated to be released in FY 16 and awarded in FY 17. The overlap will provide the Government the ability to establish unambiguous requirements and execute a seamless transition between contract vehicles.
The current contract for the AFMMAST program, W900KK-14-C-0007 was competitively awarded to ECS after evaluations deemed the company as the best overall value to the Government. This was competed as a total small business set-aside and awarded on 31 January 2014.
8. Market Research: Technical experts from the requiring activity conducted market research to stay abreast of the ability of the marketplace to meet requirements for the MMAST program, prior to contract award in January 2014. During FY 13 and FY 14, market research was ongoing in preparation of the competition. This continuous research consisted of reviews of trade journals and catalogs, attendance at Healthcare, Simulation and Engineering symposiums and analyses of contract history and available technical data for AFMMAST. Complete market research has been accomplished via a Source Sought Notice and an Industry Day for the total Small Business Set-Aside
(SBSA).
Market Research is currently in progress for the forthcoming RFP encompassing the MMAST requirements within the competitive action.
Specifically for this requirement, Market Research was conducted via the synopsis posted to FBO.gov. Details of the synopsis and responses are located in paragraph 6, above.
9. Interested Sources: Notices required by FAR 5.201 have been published and all proposals received have been considered by the Government. As outlined in detail in paragraph 6, above, one response to the synopsis posted to FBO.gov on 13 August 2015 was received.
10. Other Facts:
a. Procurement History:
Contract/Modification Number
Award Date Contractor Extent Competed/Authority
04/10/2012 Sole Source/FAR 6.302-1 Only One Responsible Source
02/07/2013 Sole Source/FAR 6.302-1 Only One Responsible Source
W900KK-14-C-0007 01/31/2014
ECS Competed FAR Part 15:
Total Small Business Set- Aside
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