JUSTIFICATION AND APPROVAL .gov



Justification and Approval to conduct a Limited Source Procurement

authority for exception to issue a Limited Sourse Procurement; Multiple Award Schedule Program definition shown in FAR 8.401- definitions:

“Multiple Award Schedule (MAS)” means contracts awarded by GSA or the Department of Veterans Affairs (VA) for similar or comparable supplies, or services, established with more than one supplier, at varying prices. The primary statutory authority for the MAS program are Title III of the Federal Property and Administrative Services Act of 1949 (41 U.S.C. 251, et seq.) and Title 40 U.S.C. 501, Services for Executive Agencies.

1. Agency and Contracting activity:

Contracting Activity: VA National Acquisition Center

Business Resource Services

P.O. Box 76, Hines, IL 60141.

Requiring Agency: OAL NAC Building 37, Hines IL 60141

National Acquisition Center

2. Nature and Description of Action and Description of Services.

a. Critical Information Technology support has been provided to VA personnel located in Building 37, Hines by Zolon, Tech, Inc. for over a five (5) year period, including a six (6) month extension. Due to unforeseen operational circumstances relating to IT support planning objectives and potential loss of continuity of operations and conclusion of critical long term projects involving applications Programmer and Database Administrator support, a situation is took place that could critically interrupt the operations of all tenants of VA building 37, Hines.

Since the current support task order is due to expire in September 30, 2011, and the non-delivery of projects by NAC IT support personnel, the NAC program office and management has determined it to be in the best interest of the Government to procure a limited source procurement under the exception and authority shown above, in accordance with FAR subpart 8.405-6- Limited Sources. The short term support needs will continue services during fiscal year 2012, beginning on October 1, 2011.

APPLICATION PROGRAMMER AND DATABASE ADMINISTRATOR

b. The Applications Programmer and Database Administrator performed by Zolon Tech are required for the continued development of the NAC CM database. Zolon is currently intimately involved in several very important major projects that are all now at a critical point of development. Because of the detailed technical support of the complex databases that exist within the agency, Zolon has developed a unique understanding, and capability to support these databases. Award to any other source would result in unacceptable delays in fulfilling the agency’s mission.

3. Identification of the exception to conduct a Limited Source Procurement —

The exception to issue a Limited Source Procurement for these critical projects are shown at FAR subpart 8.405-6(a)(1)(i)(B). Zolon Tech., Inc., personnel are the only source capable of providing the service at the level of quality required because the programming and database management services are uniquely designed by Zolon, and is a highly specialized service project they developed over several years.

Rationale;

a. Specifically, Zolon has been working for several years on the integration of the Pharmaceutical Database maintained by the Pharmacy Benefits Management (PBM) Service into the NAC CM. This project is now in the critical final implementation phase. Weekly testing cycles are being performed and issues and discrepancies are being resolved. The testing requires close coordination between Zolon and PBM. This coordination can only be accomplished by individuals who possess a very detailed understanding of the two database structures involved and the programming scripts being employed. Zolon has this understanding which does not currently exist with any other source.

b. Zolon is also involved in the transition of the vendor payment system of the Industrial Funding Fee (IFF) from the agency’s database to GSA’s database. This project entered the final FSS phase of implementation on Apr 1st, 2011 with National Contracts Service schedule for implementation the 1st quarter FY2012. It is anticipated that there will be additional issues that will arise that will continue to require the support of Zolon. Zolon has been intimately involved in this project since its inception and has written the programming scripts that make the process work. They are currently involved in bi-weekly calls to the GSA to discuss and resolve issues that are discovered. Zolon’s expertise in this area is also unique and only exists with Zolon.

Detailed Critical Project Background:

The application front end, which is a browser based graphical user interface (GUI) intranet application running on IIS, exists as and is supported by a collection of applications which include browser based as well as winforms applications. These include export/upload, quality monitoring, reporting and security management applications.

The application front end, which was originally developed by VA personnel, represents an evolution of user requirements and technological improvements over the course of a twelve year period. The front end is heavily dependent on an arrangement of views, layered up to seven levels deep, some of which have been part of the structure since the application's inception. Because the database is not completely relational, additional knowledge based consideration is required when designing changes to the front end. The front end is developed as a combination of (legacy portion) and a C#.net object layer.

Several of the key complexities of the NACCM application involve its relationship to the pharmaceutical application utilized by the Pharmacy Benefits Management (PBM) group. The NACCM application was expanded to absorb approximately 60% of the functionality of the PBM application into the NACCM application. A further 20% of the remaining functionality is under development with the creation of the prime vendor export and the remaining 20% of the functionality of the existing PBM application will continue to exist in its present form, obtaining all pharmaceutical and pricing information via recently developed interfaces from the NACCM.

The design, implementation and maintenance of the pharmaceutical item management portion of the NACCM requires detailed knowledge of business practices surrounding the calculation of federal ceiling price (FCP), pricing types, pricing restrictions and pricing quality analysis formerly implemented by the PBM group.

While the Non-federal Average Manufacturer (NFAMP) data collection and FCP calculation functions remain with the PBM group, the NACCM support staff must interpret the results and enforce the FCP according to the business rules established by public law (PL). Known business rules as well as the refinement of those rules over time are reflected in the C#.net object layer which is then enforced at the GUI. Also reflected in the C#.net object layer are functions which in-part form the overall system of programs used to provide for maintenance of pricing history.

The PBM group has detailed legal and fiscal requirements for maintaining pricing history over time, including the pricing history of an individual NDC, the pricing history as a particular drug changes its NDC and finally the pricing history as a particular drug moves from one manufacturer to another. Intimate knowledge of these requirements is a critical component to ongoing maintenance of the history information. These are further supported by the database as discussed below.

Quality analysis applications, consisting of views and data validation, integrated into the NACCM indicate to the user a custom view of outlier situations with regard to vendor reporting and price quality. Presentation of this information requires detailed knowledge of the business requirements surrounding the vendor process. Also, pricing quality analysis implements a 21-point business requirement provided by PBM that ensures the correct relationship between the FCP, FSS price, BIG4 price and restricted prices. In addition, quality reports mirror the real time quality analysis and provide greater detail for management monitoring purposes. Quality reports for pharmaceutical item quality and pricing involve a three layered approach starting with a dashboard top level and providing drill downs to individual areas of concern. These include implementation of additional requirements for cross checking between various data sources which cannot be accomplished by simple validation at the GUI.

In addition to the application front end commonly known to the end users, several supporting applications are required to complete the suite of applications in the NACCM system. These include the medical/surgical pricelist export and upload application, the pharmaceutical pricelist export and upload application, the security manager application and the original sales upload application (which is still available for use in the event that a manual upload of vendor sales data is required).

The medical/surgical item upload application is a winforms based application which is used to upload pricelists exported from the NACCM and modified by the vendor. The application is designed to detect missing or incorrect information during the upload process to prevent loss of data integrity.

The Pharmaceutical pricelist upload application directly supports the public law process for enforcement of federal ceiling price on covered pharmaceutical items. The application is a winforms based application which is responsible for enforcing the current business rules and processes surrounding the public law process. This application forms the core of the applications used during the process and thus requires frequent modification to ensure it reflects the current business processes as modified with each passing public law year.

The security manager application enforces application security in a manner that goes beyond traditional role based security. The security manager implements a 3 dimensional approach involving dynamic role definitions, area of responsibility based on both division and contract type, and application function points which are tightly coupled with the implementation of the NACCM itself, as well as the other applications mentioned here. The application allows creation of new roles and the addition of new areas of responsibility by end users.

The application backend is based on Microsoft SqlServer 2008. Support of the application from the database perspective involves four major areas of concern. First and foremost, are the active interfaces to external customers. Selection of the appropriate data for each of the interfaces is dependent on the database's layered view structure, which, as previously mentioned, is layered up to seven levels deep, and is of a legacy design nature. Since 2006, the number of external interfaces has grown from three to twelve active interfaces with additional interfaces currently under development.

Each of the following interfaces has its own unique requirements as dictated by the recipient of the data. Each is implemented by a series of scripts, data transformation tasks as well as custom C# objects and finally scheduled as appropriate. Support of the jobs requires expert knowledge of the underlying legacy and augmented databases as well as active interception and resolution of error conditions.

• CCST daily data feed - This feed supports the web based Contract Catalog Search Tool (CCST) which is the primary mechanism used by medical professionals throughout the VA for retrieving information about medical and pharmaceutical items on contract.

• GSA Sales quarterly data feed - This feed provides the list of contracts to GSA for collection of sales and payments from VA vendors.

• eLibrary daily data feed - This feed provides support for the eLibrary application.

• DAPA and DSCP monthly data feed - This feed provides support for the DAPA and DSCP applications.

• Syncnicity/ DLA CTR monthly data feed - This feed provides a majority of the input to the National Item File (NIF) application.

• MSPV Semi monthly and Daily data feed to Borschow - This feed and the five that immediately follow provide up-to-date item and pricing information to regional prime vendors of VA medical and pharmaceutical items.

• MSPV Semi monthly and Daily data feed to Buffalo

• MSPV Semi monthly and Daily data feed to Cardinal

• MSPV Semi monthly and Daily data feed to CMOP

• MSPV Semi monthly and Daily data feed to Kreisers

• MSPV Semi monthly and Daily data feed to PHSYES

• Pharmaceutical items feed to PBM in support of the Public law process - This feed enables support for PBM's public law process in which every covered drug item is updated during a two month period starting each October 15th.

• GSA Sales daily data feed - This feed is currently under development and will provide updates of SIN changes to GSA in support of the vendor sales portal.

• DOD BPA - This feed is currently under development and will accept DOD BPA pricing from DOD and provide it to the pharmaceutical prime vendor in support of FHCC.

The second major area of support is for the export and import of medical/surgical and pharmaceutical item data. The item data for medical and pharmaceutical based contracts is unique in its changing nature. Over the lifetime of each contract, the vendor catalog corresponding to that contract is constantly in a state of flux thus tools must be provided to enable the contracting officers to keep their catalogs current in support of this critical function.

Thirdly, support must be provided for the Fiscal group for receipt and maintenance of payment information for payment of the Industrial Funding Fee (IFF) or Cost Recovery Fee (CRF) provided by vendors to the VA as dictated by law. Payment information is received via an interface from the GSA sales reporting vendor portal via into the NACCM database as supported by a series of jobs which retrieve and process the GSA sales and activity files. Most critically, the processing of the debit vouchers requires expert knowledge of the business processes of how to apply the changes against the existing payment records.

And finally, support must be provided to enable the database to interface to the NACCM application front end as previously described in the above sections.

The application data structure, in addition to being dependent on the legacy views, is actually many databases working in concert. They include the main NACCM database, the security database, and the pharmaceutical item management database among others.

Each database has its own challenges. The main database was built many years ago with limited knowledge of relational database concepts and limited planning. Existing table structures that are part of the legacy portion of the database are not consistently constructed using a normal relational model. This has resulted in a complex structure that has evolved over the course of a twelve year period rather than one created by design. This constraint often requires unique approaches to obtaining the desired result. For example, there is increased complexity for performing otherwise common tasks, such as relating new tables with legacy tables, due to the specialized knowledge required to implement such tasks. All recently created objects, however, follow a strict relational model.

The security manager database is designed for performance to provide authorization support for the main NACCM GUI as well as the second tier applications which support it. The security manager makes heavy use of stored procedures that address the implementation of the three dimensional security arrangements by maintaining encoded lists of function points within individual fields. The lists are packed and unpacked using a set of custom encoding and decoding functions implemented in sql.

Finally, the pharmaceutical item management database, in addition to maintaining current catalog items, also has item and pricing history, and presents the information in a way specifically required by law. Maintaining pricing history includes the pricing history of an individual NDC, the pricing history as a particular drug changes its NDC and finally the pricing history as a particular drug moves from one manufacturer to another over time. In addition, the pricing history must be gathered and summarized for use by the GUI level as well as for various reports used to investigate the pricing history of a particular drug item. Very detailed knowledge of the business requirements for the sequencing, splitting, replacing or updating of the history records is a critical component to the ongoing maintenance of the history database.

4. Best Value Determination: (FAR Subpart 8.405-6(c)(2)(v))

Based on the labor hours/rates in the 2010 task order, the total annual labor hours for the programmer and database manager will remain at 2000 hrs. The total cost using 2010 rates is $177,300.00. Between the very long learning curves involved in taking over a project of the depth and magnitude by procuring new services from another company with no knowledge of the projects, the cost of the new task order in fiscal year 2012 is determined to be less than one half of the cost of hiring new personnel. The cost for the 2012 task order, not quantifying the potential affect on the continuity of operations, if procured by another company, could cost over $328,000.00. Given the timely and quality work of Zolon personnel, and shorter performance period, and compared to 2010 labor costs, the limited source task order to Zolon Tech, Inc., will save approximately 150,000.00, or 56% compared to hiring new IT personnel,

5. Market Research:

Market research was narrowed to previous procurement history.

6. Government Estimate:

The estimate based on 2010 labor rates for 12 month performance period is $177,300.00, or with a 3% change over 2010 rates totals $182,619.00. Total Government estimate for this procurement is $ 183,000.00.

7. Other Factors Supporting the Justification:

Overall, the program managers, and technical planning members have determined that the current critical projects for the applications programmer and database administrator should be completed within twelve (12) months. The probability of extending the task order for a 6 month period is low however; it was determined risky not to including a six (6) month extension statement in the task order.

8. Statement of Action on Barriers that led to Restrictions:

The initial intent of the procurement was to conduct a competitive process using GSA schedule 70, Category (SIN) 132-51, Information Technology Professional Services. Since the critical projects will now not cause operational interruptions, or longer learning curves that cost additional time and money, there will be very little chance that any future requirements. These requirements will terminate after the 12 month task order expires.

9. Certifications:

Technical and Requirements Certification (FAR 8.405-6(C)(2)(x));

I certify that the facts, representations and supporting data which form a basis for the justification, are complete and accurate.

_________________________________ ___________________

Reginal Campbell, NAC Project Officer Date

Contracting Officer’s Certification (FAR 8.405-6(g)(2)(ix));

I certify that the facts and representations under my cognizance, which are included in this justification, are complete and accurate to the best of my knowledge and belief:

_________________________________ ____________

Timothy A. Scanlan, Contracting Officer Date

Contracting Officer’s Approval (FAR 8.405-6(d)(2)(ix));

I approve, and certify that the facts and representations under my cognizance, which are included in this justification, are complete and accurate to the best of my knowledge and belief:

_________________________________ ____________

Timothy A. Scanlan, Contracting Officer Date

................
................

In order to avoid copyright disputes, this page is only a partial summary.

Google Online Preview   Download