Q521--SBY Medicine Service - Emergency Pulmonary Contract (VA-23-00016944)

VA DIRECTIVE 1663

HEALTH CARE RESOURCES (HCR) CERTIFICATION APPROVAL MEMO

From: Associate Chief of Staff, Medicine Service (11G)

Subj: VA Directive 1663, Certification and Approval Memorandum To: Network Contracting Office (NCO)

Thru: Medical Center Chief of Staff (COS) Medical Center Director

Veterans Integrated Service Network (VISN) Director

1. DESCRIPTION OF SERVICES

The Salisbury VA Healthcare System, 1601 Brenner Avenue, Salisbury, NC 28144, has an emergent need for the provision of an (1) on-site, Board Certified/Board Eligible, Pulmonary Physician. As such, the Salisbury VA HCS requests Network Contracting Office 6, Hampton, VA to process a requisitions package to pursue securing the health care resources described herein in accordance with VA Directive 1663 and the Veterans Health Administration Procurement Manual (VHA PM).

This multi-purpose memo streamlines compliance with VA Directive 1663 approvals, Federal Acquisition Regulation (FAR) requirements for acquisition planning.

The Salisbury VAHCS requires one (1) Board Certified/Board Eligible Pulmonologist/Critical Care provider with Sleep experience to assist in maintaining adequate staffing levels to support clinical operations. Due to unforeseen attrition in staffing levels, the facility is unable to sustain its current staffing requirements to maintain accreditation standards without emergency addition of professional staff to manage the ICU which is temporarily supported by anesthesiologists and staff hospitalists. The contractor shall be responsible for providing Board-Certified Pulmonologists with Basic Life Support (BLS), and Advanced Cardiac Life Support (ACLS) to assist in day-to-day Intensive Care and/or general outpatient Pulmonary services. The candidate will primarily be responsible for inpatient and outpatient care, as well as inpatient consultations and On-Call services. The candidate will be expected to perform inpatient pulmonary consultations and interpret sleep studies while on tour and not rounding in the ICU.

Templates are located on the Medical Sharing Affiliate Office (MSO s) Customer Resource Center (CRC) SharePoint Site.

Sole Source Document Checklist

Competitive Document Checklist

[ ] Acquisition Team members/Integrated Product Team (IPT) appointment from the Medical Center Director (Procurement Policy Memorandum (PPM) 2017-05)/Charter

[ ] Conflict of Interest (COI) acknowledgement (VA Directive 1663/VHA Directive 1660.03) and Non- Disclosure forms for all those involved in the procurement

[ ] Needs Assessment Gap Analysis/Alternate Source Plan supporting data (VHA PM for Federal

[ ] Acquisition Team members/IPT Team appointment from Medical Center Director (PPM 2017-05)/Charter

[ ] COI acknowledgement (VA Directive 1663/VHA Directive 1660.03) and Non-Disclosure forms for all those involved in the procurement

[ ] Needs Assessment Gap Analysis/Alternate Source Plan Supporting Data (VHA PM for FSS/VA Directive 1663 for other HCR). Required to be

included in support of this memo. Section 4 must

Supply Schedule (FSS)/VA Directive 1663 for other HCR). Required to be included in support of this memo. Section 4 must also contain an executive summary of the information. NOTE: Do not EMBED supporting documents

[ ] Security Checklist Appendix A with recommended security language (VA Handbook 6500.6) and Position Designation System and Automated Tool (PDAT) as required. Signed

[ ] PWS. Must use the MSO template, if available [ ] QASP. Must use the MSO template, if available [ ] Market Research Report (VHA PM)

[ ] Independent Government Cost Estimate (IGCE). Must use the MSO template signed by the Program Office

[ ] Contracting Officers Representative (COR) certification as required in Section 2 (VHA PM)

also contain an executive summary of the information. NOTE: Do not EMBED supporting documents

[ ] Security Checklist Appendix A with recommended security language (VA Handbook 6500.6) and PDAT as required. Signed

[ ] Performance Work Statement (PWS). Must use the MSO template, if available

[ ] Quality Assurance Surveillance Plan (QASP).

Must use MSO template, if available

[ ] Market Research Report (VHA PM) with recommended source list, evaluation criteria and evaluation team

[ ] IGCE. Must use MSO template signed by the Program Office

[ ] COR certification as required in Section 2 (VHA PM)

Procurement Summary:

Salisbury VA Healthcare System

NEEDS ASSESSMENT EXECUTIVE SUMMARY: The Salisbury VA Healthcare System (Salisbury VAHCS) has an emergency need for 1.0 FTE BC/BE Pulmonary Physician(s) to provide on-site inpatient critical care and outpatient clinical care at the Salisbury VA Healthcare System, Building 2, located at 1601 Brenner Ave, Salisbury, NC 28144. The Salisbury VAHCS requests to procure 1.0 FTE Pulmonologist through contractual means, either through FSS, GSA or open market contracts. 1.0 FTE Pulmonologist Physician procurement to provide on-site services (2080 FTE hours including 312 On-Call Hours):

Historically, the Salisbury VA HCS Pulmonary & Critical Care Section was staffed with 6.0 FTE VA paid Pulmonologist to accommodate outpatient clinics, critical care coverage, Resident supervision, and supervision of 3 VA Midlevel/Advanced Practice Providers. However, there has been a significant reduction in the availability of Pulmonologists to cover the clinical/critical care volume at Salisbury VA HCS. Currently, the Pulmonary & Critical Care service has 4.0 combined FTE filled to staff clinic and critical care, thereby leaving a shortfall of 2.0 FTE pulmonologist. Of the 4-remaining pulmonologist, only 2.0 can provide critical care coverage leaving a shortfall of actual FTE greater than 2.0.

The challenge of staffing board certified/board eligible pulmonologists as full-time VHA providers is the cost to do so. Currently the VA cannot compete with the salaries offered to Pulmonologists in the private sector especially during the tail end of the worldwide COVID-19 pandemic.

The Pulmonary & Critical Care Department at the Salisbury VA HCS is a fairly unique clinical operation in that it is one of three Pulmonary & Critical Care departments within VISN 6, that are not staffed with academically affiliated staff nor conjoined physically with their academic affiliate. The others being Asheville and Fayetteville VAMC s. The staffing model ensures that the providers performing treatment and follow-up care in the department are all well rounded and seasoned providers who have performed countless procedures annually as this measure is directly correlated to better outcomes and safety. Physicians already employed in a large and busy academic program continue to accrue a volume of various procedures when not practicing at the VA, therefore always guaranteeing presence of high-quality physicians in our facility to ensure the veterans receive the highest quality of care.

Given that the Salisbury VA HealthCare System Pulmonary & Critical Care department is also a training site for Pulmonary residents from our academic affiliate, Atrium Health Wake Forest Baptist, the most reasonable approach for capacity building is to advertise and procure contractual physician(s) with an academic background that can both meet the clinical and academic needs.

The widely sourced contract will also bring a diverse skill set of physicians including general intensivists as well as pulmonary and sleep medicine trained physicians. The Salisbury VA HCS has a critical need for fulltime staff in these areas and does not have the pay structure to be sufficiently competitive to attract full-time providers from the community. The Salisbury VA HCS has advertised and continues to extensively advertise for Pulmonary & Critical Care positions without success. The most recent attempt was unsuccessful due to a major salary disparity between VA Pay Tables and salaries in the local community.

HCR

Recruitment of 1.0 FTE Board Certified/Eligible Pulmonary Physician

And/or other services (describe):

Period of Performance (POP) - Dollar Value (from IGCE)

If the POP is less than a base period plus four years, the Section 9 justification must be addressed. Total Estimated Value: $750,000.00

Base Period: 1 January 2023 to 31 December 2023

Line Item 0001 One (1) Board Certified/Board Eligible Pulmonary Physician - 2080 hours each x Rate $350.00/hr Total = $728,000.00.

Line Item 0002 - Board Certified/Board Eligible Pulmonary Physician On-Call rate (pager call only):

312 hours x $70.50/hr = $22,000.00 Total Base Period Cost: $750,000.00

Current Contract Information

Current contract #: N/A Contractor name: N/A

Value:

Current contract POP - Award date: Expiration date:

Describe how services are currently being provided: FTE/Hourly

Type of Procurement

[ ] Sole Source with an Affiliate

[ ] Competitive [ ] FSS Task Order (competitive)

[ ] Sole Source (not Affiliate) FSS Task Order

[ ] Transplant

Place of Performance

[ X ] On-site (performed at the Salisbury VA Health Care System)

1601 Brenner Ave, Salisbury, NC 28144

[ ] Off-site (performed at the contractor facility)

(See Section 9 for Office of Community Care (OCC) waiver approval:

Reimbursement Method

[ X ] Full Time Equivalent (FTE)/hourly/(FTE)/hourly/another fixed unit

[ ] Per procedure

[ ] Other pricing methodology (i.e. Mixed, work Relative Value Unit (wRVU)

2. ACQUISITION TEAM (or IPT) RECOMMENDATION AND PLANNING CERTIFICATION

The VISN Director (if it is a VISN level procurement) or the Medical Center Director (if it is a facility level procurement) has appointed the following members to the Acquisition Planning Team.

List members and roles:

Dr. Charles DeComarmond - Associate Chief of Staff, Medicine Service Dr. Steven Marks Chief, Pulmonary & Critical Care

Steve I. Johnson - Contracting Officer s Representative

- Contracting Officer

M - Contracting Specialist List nominated COR(s):

Steve I. Johnson - COR

3. COI/ NON-DISCLOSURE CERTIFICATION

COI requirements cannot be waived. The Medical Center Director certifies by signing this memo that all steps have been taken to ensure compliance with VHA Directive 1660.03 to include all facility VA employees that could be involved in any pre-award processes (i.e., development of the PWS and participation on the evaluation panel) have received a copy of VHA Directive 1660.03, signed the acknowledgement included in VHA Directive 1660.03 and any applicable non-disclosure forms). Acknowledgement forms and Non- Disclosure forms are included in package to support this certification.

4. COS NEEDS ASSESSMENT/ALTERNATE SOURCE PLAN

Select Reimbursement Method: [ X ] FTE/Hourly [ ] Per procedure [ ] Other

Check if the Needs Assessment includes on-call (must be addressed if included in the PWS): [ X ] Gap Analysis Data:

Alternate Source Plan: (See Alternate Source Plan - SAMPLE on MSO s CRC SharePoint Site.)

Alternate Source Plan Pulmonary & Critical Care Services Salisbury VA Healthcare System

ALTERNATE SOURCE PLAN

Alternate source plan consists of two phases, phase 1 includes utilization of Hospitalists and Anestheisologist to provide immediate ICU coverage in the short term. Phase 2 is the most drastic and includes placing the ER on diversion, surgical operations would be curtailed due the offset of anesthesisologist covering the ICU.

Outpatient and inpatient veterans requiring critical care would be referred to care in the community.

COST

Cost of coverage includes salaried cost of FTE provided to cover as well as missed opportunity associated cost of lost revenue equivalency from diverting/suspending surgeries as well as ED diversion costs. An estimated cost to the Salisbury VAHCS for 1 week s worth of coverage equates to $311,313.31 (16,188,292.12 annual cost) (CITC surgical referrals + Anestheisologist Salary + Hospitalist salary coverage per 1

week)

IMPLEMENTATION PLAN

Upon notification that a contract cannot be awarded, Salisbury VAHCS will engage with anesthesiology, hospitalists, ED leadership as well as Community Care Service to facilitate and request to send patients out to community providers for their medical

care.

TIMELINE

The Associate Chief of Staff, Medicine Service will brief the Chief of Staff and Medical Center Director, who in turn will notify the Care in the Community (fee-basis) and Consult Management Service accordingly.

Day 1 Initial Notification from the Director to Non-VA Purchased Care/CITC to turn-off incoming IFCs for neurosurgery

Day 1 Notify VISN 6 office of service impact/limitation.

Day 2 Notify Affiliate (Duty Secretary of Health) of potential impact to graduate medical program operation

Day 3 & 4 CITC (Fee Basis) engages area Veteran s CHOICE Third Party Administrator (TPA) to inform the TPA of service limitations and to anticipate an increased demand.

Enter the estimated cost of the Alternate Source Plan: $3,735,759.72 for 52 weeks.($194,259,505.44 annual cost)

5. SOURCING OPTIONS

Determination applies to all health care resource procurements. All the following options must be considered prior to contracting for services.

Send patients to another VAMC or Military Treatment Facility (MTF) (38 U.S.C. 8111)

The closest VA facilities geographically include the Columbia VA (SC), around 1.5 - 2hours drive from the Charlotte HCC VA Center and the Durham VA center which is close to 3.5 hours driving time. Veterans would be given that option but given the

driving times, that would be a less of a practical route.

HR Fee basis appointment (IAW 38 U.S.C. 7405(a)(2) HR Requirement

Care in the community is an option on a temporary

basis. This option is the most expensive to the Government. Fee basis is not an option due to the

paucity of local groups and universities to provide such service while they are relatively short staffed

with more lucrative practices financially .

6. PWS/STATEMENT OF OBJECTIVES (SOO) & QUALITY ASSURANCE SURVEILLANCE PLAN (QASP)

The Clinical Service Chief, Chief of Staff, and Medical Center Director certify by signing this document that (1) the PWS and QASP defines the scope of services and outcomes that address all applicable VA quality standards of care, (2) that the using service and required clinical leadership has determined the appropriate quality assurance standards and data collection methods are in place for monitoring contract performance, and

(3) the PWS and QASP includes the most current clinical standards as noted in the PWS template.

7. CONTRACT AUTHORITY. Select the contract authority

7. CONTRACT AUTHORITY. Select the contract authority

38 U.S.C 8153:

[ ] This procurement will be competed using 38 U.S.C 8153 and VA Directive 1663.

[X] This procurement will be sole sourced using 38 U.S.C 8153, VAAR 873.108 (b) and VA Directive 1663.

[ ] Proposed sole source contractor is an institution affiliated with VA (including medical practice groups and other approved entities associated with the affiliated institution). Section 8 of this memo outlines the information on the qualifying educational program or affiliation. A separate sole source justification document is not required. This document will be processed by the contracting office using routing procedures as specified in the VHA PM.

[ ] This procurement will be sole sourced using 38 U.S.C 8153, VA Acquisition Regulation (VAAR)

873.108 (b) and VA Directive 1663. Proposed sole source contractor is an institution affiliated with the VA (including medical practice groups and other approved entities associated with the affiliated institution, which are not associated with a residency program. Section 8 of this memo outlines why the award would represent best value to the government.

38 U.S.C 513:

[ ] This procurement will be competed and will result in task order(s) issued against FSS 621i Schedule Contracts.

8. EDUCATIONAL RESIDENCY PROGRAM INFORMATION FOR SOLE SOURCE

[X] This procurement will be sole sourced and will result in task order(s) issued aginst FSS 621i Schedule Contracts following the procedures outlined in the VHA PM in accordance with FAR Part 8.406 for limited sources.

Sole source affiliate contracts (SSAC) proposed for clinical HCR services not associated with a residency program should be checked below as not applicable for educational residency program. Provide an explanation to demonstrate best value to the government.

[X] Applicable [ ] Not Applicable

9. APPROVAL FOR WAIVERS/DEVIATIONS: COMPLETE IF SEEKING ANY OF THE OUTLINED WAIVERS OR DEVIATIONS FROM THE REQUIREMENTS OUTLINED IN VA DIRECTIVE 1663, VHA PM

OR OTHER REQUIRED APPROVALS, i.e., waiver from OCC usage of national contracts.

[X] (If

requesting)

Description of requested action

Justification (If deviation/waiver does not apply

- enter N/A)

[

]

Waiver from OCC national contracts (VHA10Daction@va.gov)

Provide justification and attach required waiver approval from OCC

[

]

POP approval, if less than a base year + four options

[

]

Approve payment for concurrent on- call services, if proposed

[ X ]

Cannot recruit or recruitment not appropriate

Unable to recruit qualified Pulmonary and Critical Care Physicians. Have been recruiting since 2020 due to COVID-19 pandemic.

[

]

Approve part-time VA employment (dual appointment) to provide services under the contract, if proposed

[

]

Approve per procedure at the VA facility, if proposed

[

]

Approve FTE/hourly rate contracts performed at the contractor facility, if

proposed

[

]

Approve other pricing methodology

(i.e. Mixed, work Relative Value Unit (wRVU)

[

]

Other

The following signatures certify that each individual has contributed to the development of this document(s), acknowledges all applicable certifications as outlined in this document and approves/disapproves as indicated below. Inclusion of additional signatures is at the discretion of the Network.

Clinical Service Chief

Date

Printed name and signature of the Service Chief

If disapproved, provide comments:

Date

Printed name and signature of the Medical Center Director

The COS certifies that the Needs Assessment represents the factual support establishing a bona fide need to contract for the medical services specified and that the PSW/SOO and QASP contain current VHA standards of care and appropriate performance monitoring systems.

Circle One: AApppprroovvee//Disapprove

Chief of Staff (COS)

If disapproved, provide comments:

Date

Printed name and signature of the Medical Center Director

The Medical Center Director certifies by signing this memo that all steps have been taken to ensure compliance with VA Directive 1663, VHA PM and VHA Directive 1660.03, that an Acquisition Planning Team or IPT (as required) conducted planning, that the COS Needs Assessment is approved, that recruitment efforts have been conducted/documented (whether the recruitment is successful or not) and that all deviations/waivers requiring review and approval under VA Directive 1663 and the VHA PM have been completed.

Circle One: AApppprroovvee//Disapprove

Medical Center Director

VISN CERTIFICATIONS AND APPROVALS

Printed name and signature of VISN Director Date

If disapproved, provide comments:

Date: 2022.11.17 10:57:18 -05'00'

Paul S. Crews

The VISN Director certifies, by signing this memo, that all steps have been taken to ensure compliance with VA Directive 1663 and VHA PM and all processes for all HCR requirements.

Digitally signed by PAUL CREWS

Circle One: Approve/Disapprove

VISN Director

SOLE SOURCE APPROVALS

Contracting Officer (CO) and one level above CO signatures are required for all sole source HCR

Sections 7 & 8 of the Approval Memo contain adequate justification and VISN level approvals have been obtained.

If disapproved, provide comments:

Date

One level above CO signature

Circle One: Approve/Disapprove

One level above CO

Contracting Officer

Date

CO signature

This certifies I have reviewed this document and to the best of my knowledge find it complete. Awarded contract 36C24623Q0171 to MILLBROOK SUPPORT SERVICES INC for 837000.00000000 on 2023-01-03.