FY26 Recompete of the Electro-Therapeutic Modalities for Pain Management (ETMPM) - Transcutaneous Electrical Nerve Stimulation (TENS) Procurement Program

The Department of Veterans Affairs (VA), Veterans Health Administration (VHA), Enterprise Procurement Office (EPO), is releasing an updated edition of the FY26 Recompete Electro‑Therapeutic Modalities for Pain Management (ETMPM) & Transcutaneous Electrical Nerve Stimulation (TENS) Program – Consolidated Request for Information (RFI) Frequently Asked Questions (FAQs). This update incorporates all questions received during the January 20, 2026 and June 25, 2026, RFI cycles, inputs submitted during the FY26 Denver Logistics Center (DLS) Industry Days and newly received industry inquiries submitted during August–September 2026. These updated FAQs continue to support uniform, transparent communication with industry during the market research and presolicitation phases, and they remain strictly informational in accordance with FAR 15.201(e). They do not establish proposal requirements, do not constitute Government direction, and do not provide a competitive advantage to any party. Additionally, the VA is releasing a targeted, Request for Information (RFI). This posting continues the VA’s commitment to transparent, enterprise‑wide communication throughout the market research and presolicitation phases of this national procurement. These exchanges remain strictly informational and are conducted in accordance with FAR 15.201(e); no guidance herein constitutes direction, evaluation criteria, or binding requirements. Final, enforceable requirements will be issued exclusively in the solicitation on SAM.gov.

Acknowledging Industry RFI Fatigue: The VA recognizes that industry partners have already responded to two (2) extensive RFI cycles on January 20, 2026, and June 25, 2026, and that many vendors have expressed RFI fatigue. This feedback is both heard and valid. However, the FY26 ETMPM–TENS Recompete is a national, enterprise‑wide, multi-year, multi-modality procurement, spanning:

• Five distinct device categories (TENS, IFC, SWD Thermal, SWD Non‑Thermal, Neuromodulation);
• Twenty‑plus accessory categories (electrodes, cables, gels/sprays, chargers, garment‑based solutions);
• CLIN‑level therapeutic devices and SLIN‑level consumables;
• Full compliance with the Buy American Act (BAA) and Trade Agreements Act (TAA) for every item offered;
• Distribution across 168 VA Medical Centers and 1,000+ outpatient clinics nationwide.

Because the procurement is so structurally complex and because the VA uncovered significant gaps and inconsistencies in early RFI submissions, the VA must now issue another RFI focused exclusively on Country‑of‑Origin (COO) identification at the CLIN and SLIN level. This step is not repetitive; it resolves the final missing data required to complete the solicitation package.

Why This Third RFI Is Necessary (Based on Prior RFI Analysis): Analysis of responses to the first two RFIs revealed several industry‑wide issues:

1. COO data was incomplete or inconsistent across submissions: Some vendors provided COO at the corporate level, others only at the device level, while many did not provide COO at the SLIN (accessory) level at all.

2. Multiple accessory items lacked origin information entirely: Electrodes, gels, conductive sprays, garment‑based pads, charging blocks, and lead wires frequently had unknown, mixed, or conflicting COO information, making BAA/TAA verification impossible.

3. Several respondents listed product families rather than itemized CLIN/SLIN offerings: This made it impossible for the VA to map COO to each distinct end‑product, which is required by FAR Part 25.

4. Initial RFIs revealed significant variance in supply chains: Some OEMs source components from multiple countries over a given production cycle. The VA must ensure traceability and compliance for every end‑product actually offered for contract award.

5. Without verified COO at the CLIN/SLIN level, the VA cannot finalize:

• BAA/TAA compliance determinations,
• CLIN/SLIN eligibility for award,
• Pricing matrices in the solicitation,
• Mandatory certifications,
• Whether any CLINs or SLINs require BAA non‑availability waivers.

In short, without accurate COO data, the VA cannot legally or structurally finalize the solicitation.

Issuance of the Third RFI — What It Is and What It Isn’t: This RFI, titled“FY26 ETMPM & TENS Procurement Program – Country‑of‑Origin & Product Characteristics RFI” is not a repeat of the earlier RFIs. Instead, it is a targeted, single‑purpose data call designed to close the last remaining gap identified through market research, the precise Country‑of‑Origin for each CLIN‑level device and SLIN‑level accessory in your planned proposal. Once COO data is received and validated, the VA will finalize:

• CLIN/SLIN schedules,
• Compliance language,
• BAA/TAA clauses,
• Evaluation factors,
• Section B pricing structures,
• Attachment 0002 - Price Matrices, and
• All certification requirements for the solicitation.

How Tiered Set‑Aside Evaluation Drives COO Identification at Pre‑Solicitation: The FY26 ETMPM–TENS procurement program is employing a Tiered Set‑Aside (Cascading) Evaluation under NAICS 334510 – Electromedical and Electrotherapeutic Apparatus Manufacturing (size standard: 1,250 employees). Awards are pursued at the highest tier where acceptable offers and fair‑and‑reasonable prices exist; if award cannot be made at a higher tier, evaluation cascades to the next tier, and may ultimately result in award at the lowest tier (other‑than‑small business or large business concerns).

Source Selection Methods by CLIN:

• CLINs X001–X004 (TENS/IFC/SWD – COTS items): LPTA procedures will be used within the tiered framework; past performance is a pass/fail evaluation based on three (3) past performance documents, technical acceptability is evaluated against the proposal documentation and product samples CLIN/SLIN Minimum Technical Requirements (MTRs) on a pass/fail basis, and the price factor is significantly more important than the past performance or technical evaluation considerations. The price factor will be evaluated based on the Total Evaluated Price (TEP) based on each Offeror’s Attachment 0002 - Price Matrix submission.   
• CLIN X005 (Neuromodulation – Commercial item): Best Value – Tradeoff procedures apply adjectival rating methodology based on Technical factor (weighted at 60%) and Past Performance factor (weighted at 15%) combined are significantly more important than Price factor (weighted at 25%).

Award Inclusivity of SLINs for CLIN X001 and CLIN X002: To ensure technical compatibility and accessory interoperability, any award for:

• CLIN X001 (TENS Device) is inclusive of the TENS device accessories SLINs X001AA, X001AB, X001AC, X001AD; and
• CLIN X002 (IFC Device) is inclusive of the IFC device accessories SLINs X002AA, X002AB, X002AC, X002AD.
• Offerors must submit responsive proposals on both the parent CLIN and all subordinate SLINs; pricing for the parent CLIN is evaluated with the associated SLINs.

BAA/TAA Application by Tier (Why COO Is Needed Now): Under the tiered evaluation approach, the statutory trade rules differ by tier, which is why the VA must verify COO at the CLIN and SLIN level before releasing the RFP:

• Small‑Business tiers (SDVOSB/VOSB/other small business concerns): The VA centers evaluation on Buy American Act (BAA) compliance for end‑products offered by small business concerns; COO determines whether items qualify as Domestic End Products, or if a BAA non‑availability waiver might need consideration.
• Other‑than‑Small Business tiers (e.g., large business): At the anticipated dollar values of this enterprise procurement, the Trade Agreements Act (TAA) applies to offers from large businesses; COO determines if offered items originate in TAA‑designated countries (eligible) or fall into non‑designated countries (ineligible).

Because award can be made at any tier depending on competition outcomes (highest tier possible (small business concerns), lowest tier if necessary (large business concerns)), the program must pre‑validate COO for every CLIN and SLIN to ensure the solicitation contains correct BAA/TAA clauses, certifications, and evaluation rules for all competition outcome contingencies without delaying award decisions or risking non‑compliant sources.

What the COO RFI Collects (Pre‑Solicitation): The RFI requests each respondent to identify the COO for each product you plan to offer the VA for this procurement effort:

• CLIN/SLIN identification, SKU/part numbers, HCPCS;
• COO classification (BAA Domestic, TAA‑Designated, or Non‑Designated); and
• Ability to provide formal COO certification at proposal submission.
  This one‑time data call enables the VA to finalize CLIN/SLIN schedules, solicitation compliance language, pricing matrices, and certifications that will govern LPTA decisions on X001–X004 and Best‑Value tradeoffs on X005 within the Tiered Set‑Aside structure.

Why COO Matters for This Procurement: Under FAR Part 25, the VA must determine whether every product offered is:

• A Domestic End Product under BAA (in play for small business concerns);
• A TAA‑designated Country End Product (in play for large business concerns); or
• A Non‑Designated Country End Product (generally prohibited from procurement unless eligible for BAA non-availability waiver).

Because the ETMPM–TENS Program includes multiple device modalities, a wide slate of accessories, and SKU‑level consumables, COO must be confirmed for each unique CLIN/SLIN end‑product, not generically referenced. This ensures:

• Protection against gray‑market goods;
• Supply chain integrity for Veteran patient care;
• Compliance with federal law;
• Eligibility determinations for each CLIN/SLIN in the solicitation;
• Proper evaluation structure for the Best Value Tradeoff and LPTA CLINs;
• Ability to establish uniform national standards across all VA medical facilities.

RFI Issuance: This RFI requests that all interested industry respondents provide Country‑of‑Origin (COO) information for every product offered under each CLIN and SLIN. COO certification is required under FAR Part 25, including Buy American Act (BAA) and Trade Agreements Act (TAA) considerations. To support compliant solicitation development, the VA must confirm:

• Whether proposed CLIN‑level therapeutic devices (TENS, IFC, SWD Thermal, SWD Non‑Thermal, and Neuromodulation) are Domestic End Products under the BAA;
• Whether proposed CLIN/SLIN‑level items (electrodes, gel/spray consumables, lead wires, power accessories, garment‑based options) qualify as TAA‑designated end‑products;
• Whether any items originate from non‑designated countries, which would require evaluation for potential BAA non‑availability waivers;
• Whether vendors can provide formal COO certification at the time of solicitation submission.
   

Why the VA Requires COO Data Before Solicitation Release: The collecting of the COO information at the CLIN and SLIN level is essential for:

1. Ensuring FAR Part 25 compliance (BAA/TAA) across all product categories under this enterprise procurement;
2. Finalizing solicitation language regarding eligibility of domestic and designated‑country end‑products;
3. Determining whether any CLINs or SLINs require BAA non‑availability waiver consideration;
4. Protecting VA supply chain integrity, preventing procurement of non‑compliant or gray‑market products;
5. Establishing accurate evaluation criteria and certification requirements for the technical and price factors;
6. Ensuring enterprise‑wide standardization of clinically essential devices and accessories across 168 VA Medical Centers, 1,000+ CBOCs, and federal partner sites.

The VA cannot finalize the solicitation, CLIN/SLIN schedules, or product compliance requirements without receiving complete COO data for all prospective offerings.

Instructions for Respondents Completing the RFI: Industry partners are requested to:

1. Download and complete the RFI template (attached to this posting).
2. Provide detailed COO information for every CLIN and SLIN they intend to offer.
3. Convert the completed document to PDF, digitally sign, and date it.
4. Email it to:
   • john.overstake@va.gov
   • Subject line: “RFI Response – ETMPM/TENS Program – [Company Name]”
5. Ensure submission includes all required product data, such as:
   • CLIN/SLIN identification
   • Product descriptions and technical specifications
   • HCPCS information
   • SKU/part numbers
   • COO classification (BAA Domestic, TAA‑Designated, or Non‑Designated)
      

Closing Remarks:

We understand that responding to repeated RFIs consumes time, personnel, and resources. Industry partners have been exceptionally responsive, and the VA genuinely appreciates the participation across all phases of the FY26 procurement cycle. The VA recognizes the burden this places on vendors and does not issue this RFI lightly. This step is essential to protect Veterans, federal supply chain integrity, and statutory compliance requirements that govern VA acquisitions. Your continued partnership enables the VA to move this large, complex, mission‑critical procurement into the solicitation phase with confidence, clarity, and regulatory compliance. The VA sincerely appreciates your patience and professionalism as we work to ensure that Veterans nationwide receive safe, FDA‑cleared, clinically reliable electro‑therapeutic devices backed by a compliant, stable, and modernized acquisition structure. All future updates including release of the formal RFP will be published exclusively on SAM.gov.