DEPARTMENT OF VETERANS AFFAIRS SOLE SOURCE JUSTIFICATION UNDER SIMPLIFIED PROCEDURES FOR CERTAIN COMMERCIAL ITEMS IN ACCORDANCE WITH FAR 13.5 Acquisition Plan Action ID: 36C255-21-AP-1710 Contracting Activity: Department of Veterans Affairs, VISN 15, Kansas City VA Medical Center; Network Contracting Office (NCO) 15; 589-21-957-0017 Nature and/or Description of the Action Being Processed: This procurement is for a new Medical Coding Contract. The is medical coding will be for Outpatient coding, medical coding inpatient PTF, medical coding inpatient professional services, medical coding ambulatory surgery in accordance with FAR 13.5 Simplified Procedures for Certain Commercial Items and specifically FAR 13.501 Special Documentation Requirements, where acquisitions conducted under Simplified Acquisition Procedures are exempt from the requirements of FAR Part 6, but still require a justification using the format of FAR 6.303-2. The proposed requirement is a firm fixed priced service contract for one year. Description of Supplies/Services Required to Meet the Agency s Needs: The services provided will be for Medical Coding for Outpatient, inpatient PTF, Inpatient Professional Services, and Ambulatory Surgery. The anticpated value is $455,000.00, the coding services will be for twelve (12) months starting 3/20/2021 3/19/2022. Statutory Authority Permitting Restricted Competition: FAR 13.5 Simplified Procedures for Certain Commercial Items. The statutory authority for applying the Simplified Procedures for Commercial Items of FAR 13.5 is 41 U.S.C. § 1901 and is implemented by FAR 13.106-1(b)(2) for restricting competition on this procurement. - Competition is restricted on this procurement for the reason below: - - - - ( ) Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements - - - - ( ) Unusual and Compelling Urgency - - - - ( ) - Industrial Mobilization, Engineering, Developmental or Research Capability or Expert Services - - - - ( ) International Agreement - - - - ( X ) Authorized or Required by Statute - - - - ( ) National Security - - - - ( ) Public Interest Demonstration that the Contractor s Unique Qualifications or Nature of the Acquisition Requires the Use of the Authority Cited Above (applicability of authority): 41 USC §3304(a)(5), 38 U.S. Code § 8127(c), as implemented by FAR 6.302-5 (Authorized or Required by Statute). COs may use the non-competitive (sole source) procedures authorized in VAAR 819.7007 up to $5,000,000. Check the specific VAAR clause used below: (X) 819.7007 Sole source awards to a verified service-disabled veteran-owned small business Description of Efforts Made to ensure that offers are solicited from as many potential sources as deemed practicable: A National BPA was supposed to be in place by this time for coding services within the Department of Veteran Affairs, but due to COVID 19, those actions have been delayed. The current task order 36C25520F0039 is set to expire 3/19/2021. There is not sufficient time remaining to seek additional potential sources. Determination by the CO that the Anticipated Cost to the Government will be Fair and Reasonable: The cost to the Government will be found fair and reasonable based comparison of prices on previous awards for the same service provided to Kansas City VA Medical Center. Description of the Market Research Conducted and the Results, or a Statement of the Reasons Market Research Was Not Conducted: Search results from Vendor Information Pages (VIP), there were 289 SDVOSB/VOSB vendors listed under the applicable NAICS code of 541219. However, the current contract is set to expire 3/19/2021 and a VA National BPA for medical coding was delayed due to COVID 19, there is not sufficient time to promote competition, therefore I am employing the use of the non-competitive (sole source) procedures authorized in VAAR 819.7007 up to $5,000,000, as appropriate. Any Other Facts Supporting the Use of Other than Full and Open Competition: . Due to COVID-19 delaying the completion of reviews and access to the new national BPA s the facility requested and received a 3-month extension on the current contract that is set to expire 3/19/2021, however Kanasas City VA Medical Centerwas alerted of another unforeseen delay in the technical review process causing a continued delay in the National BPA s being available to all VA Medical Centers who utilized the National Coding BPA s. This delay leaves the KCVA facility at risk with meeting the business need and national standard of completion of coding workload in a timely manner. Listing of Sources that Expressed, in Writing, an Interest in the Acquisition: Axiom Corporation A Statement of the Actions, if any, the Agency May Take to Remove or Overcome any Barriers to Competition before Making subsequent acquisitions for the supplies or services required: Once the VA National BPA ifor coding services is in place, the facility will utlilize those provided services. Requirements Certification: I certify that the requirement outlined in this justification is a Bona Fide Need of the Department of Veterans Affairs and 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. Approvals in accordance with the VHAPM Part 806.3 OFOC SOP: Contracting Officer or Designee s Certification (required): I certify that the foregoing justification is accurate and complete to the best of my knowledge and belief. /////UNDERSIGNED//// _____________________________ ________________________ Philip Bouffard 3/16/2021 Contracting Officer NCO 15
