Justification and Approval – Transcription Services (Eglin AFB)

Notice Type: Justification and Approval

Posted Date: 16-JAN-14

Office Address: Department of the Air Force; Air Force Materiel Command; AFTC/PZIO - Eglin; 308 West D. AveBldg 260 Suite 130 Eglin FL 32542-5418

Subject: Transcription Services (Eglin AFB)

Classification Code: R - Professional, administrative, and management support services

Contact: Jordan D. Farrand, Phone 8508820358, Email jordan.farrand@us.af.milFAR 6.302-1

Description: Department of the Air Force

Air Force Materiel Command

AFTC/PZIO - Eglin

JUSTIFICATION FOR OTHER THAN

FULL AND OPEN COMPETITION

I. CONTRACTING ACTIVITY

The Air Force Test Center (AFTC), Operational Contracting Division, Base Operating Support Branch (AFTC/PZIOAC), 308 West D Avenue, Bldg 260 Ste 130, Eglin AFB, FL 32542-5418 is the contracting activity supporting this individual Justification for Other Than Full and Open Competition.

II. NATURE AND/OR DESCRIPTION OF THE ACTION BEING PROCESSED

This action will extend service of the contract awarded to America's Price, FA2823-13-M-R012 for an additional 3 months. This J&A will cover one action, for the contractor to provide Medical Transcription Services to Eglin AFB. The period of performance for this extension will be 1 January 2014 through March 31 2014.

III. DESCRIPTION OF THE SUPPLIES/SERVICES REQUIRED TO MEET THE AGENCY'S NEEDS

Under the contemplated contract, America's Pride will provide Medical Transcription Services at the Eglin AFB Hospital. The contractor shall accurately transcribe common medical terminology. Transcribed reports shall be returned with no errors in spelling, grammar, or punctuation and with no missing words. Reports submitted containing errors shall be returned to the contractor for correction and not included in the line count. Corrected reports shall be delivered no later than the next scheduled duty day. The contractor shall provide medical transcription services for a wide range of medical specialties. The contractor will establish and maintain mechanisms/processes to receive/retrieve/store voice recordings of provider transcriptions. The contractor will insure that all transcriptions are stored and made available in an XML-Enabled format. The contractor will provide review, revision, and electronic signature capabilities from a browser-based application that provides HIPAA compliant access, security, and authentication. The contractor will insure that all transcriptions conform to 96 MDG common templates for transcriptions. Contractor on-site employees will periodically access and download completed transcriptions from contractor server. The contractor is currently transcribing in excess of 63,000 lines each month. The period of performance of this effort will be from 1 January 2014 to 31 March 31, 2014. Appropriations (Defense Health Program, Operations and Maintenance, Air Force) 0130 will fund this effort.

IV. STATUTORY AUTHORITY PERMITTING OTHER THAN FULL AND OPEN COMPETITION

The statutory authority permitting other than full and open competition is 10 USC 2304(c)(1), as implemented by FAR 6.302-1, Only One Responsible Source.

V. DEMONSTRATION THAT THE CONTRACTOR'S UNIQUE QUALIFICATIONS OR NATURE OF THE ACQUISITION REQUIRES THE USE OF THE AUTHORITY CITED ABOVE (APPLICABILITY OF AUTHORITY)

Only One Responsible Source 6.302-1: This acquisition requires highly specialized service, requiring knowledge, skills and experience already in place and only available from America's Pride and would cause unacceptable delays in fulfilling the agency's requirements.

Medical Transcription Services at the Eglin AFB Hospital is needed to transcribe medical records. The contractor is currently transcribing in excess of 63,000 lines each month on their InfoPro software program. The transcription process is very complicated with meeting system technical needs, contract needs and the needs of the Providers. Recent DoD policy restrictions have dictated a change in firewall security measures. A Business to Business Gateway ( B to B) has to be added to the technical solution. This was not known before award and pushes the timeline for the new contractor to January 2014 instead of September 2013. These changes have made it very difficult for the hospital to develop a technical solution and a corresponding Performance Work Statement (PWS) which prohibited the acquisition process from moving forward. The 96 Medical Group (MDG) Strengths, Weaknesses, Opportunities, Threats (SWOT) team has finalized a technical solution that they are confident will meet the needs of the 96 MDG system security, contract, and the 96 MDG Providers. This additional bridge contract is needed due to new requirements by AFMS for a Business to Business (B to B) gateway for private health information. The work required is an extension to Contract #FA2823-13-M-RO12. The Contractor would handle approximately 328,000 lines of transcription during this period. Interruption in services would cause serious harm to the Government since approximately 46,000 eligible beneficiaries and over 20 clinics would be affected. A lapse of Medical Transcription Services simply is not an option. Failure to have these services will result in unacceptable mission degradation. Performance in-house by either government civilian or military personnel is not available. Without this service patient care will be jeopardized. The providers will have to complete hand written progress notes, history and physicals, and operative notes. The electronic medical record would be compromised as there would be a lapse in data stored in this record. Utilizing the current contractor has been determined to be in the best interest of the Government. Other options have been considered but the contracting officer does not believe award to anyone other than the incumbent is possible, based on cost effectiveness and continuation of services. Therefore, this acquisition is for continued performance of a highly specialized service.

The contractor's specialized capabilities and qualifications that are currently in place and continuing the services will allow continuation of the Government's needs. The contractor's personnel are already cleared, trained, and on-site. The equipment is owned and operated by the contractor, and the InfoPro software system is already in place. Awarding to another company would cause undue delay for utilization and adaption of another contractor's equipment, another company's software, as well as obtaining training and clearances for on-site personnel.

The 96 MDG believes that award to any other source would result in unacceptable delays in fulfilling the Air Force's requirements. It would take another contractor at least six months to fully incorporate their equipment, software, and personnel into the new DoD restrictions for security requirements of communications equipment. This would cause transcription to be non-existing in medical records. The 96 MDG SWOT would have to work one-on-one with the new contractor to make them whole, causing a backload of transcription reports. The current contractor is capable of performing the effort due to their early involvement in DoD security requirements. The government was unable to provide information in time concerning security certifications until just recently. Potential contractors would not have had the technical solution to accomplish the work. The beneficiaries would not have current and up-to-date medical information in their medical records which would cause adverse issues with medical care.

Accordingly, America's Pride is the only firm capable of providing the supplies and services described in Section III above without the U.S. Air Force experiencing unacceptable delays in fulfilling its requirements. Services for transcription will continue allowing the beneficiaries to have access to up-to-date medical records.

VI. DESCRIPTION OF EFFORTS MADE TO ENSURE THAT OFFERS ARE SOLICITED FROM AS MANY POTENTIAL SOURCES AS DEEMED PRACTIBABLE

A Sources Sought notice was posted on http://www.fbo.gov [www.fbo.gov] on 31 August 2010, Solicitation # Transcription. The Sources Sought stated the contractor shall provide dictation/transcription software, hardware, and off-site servers that have been DIACAP certified for storage and retrieval of transcribed provider dictations. The contractor hosted system is logically and physically separated from the systems/networks hosted at the same facility.

Twenty-one interested contractors responded to the sources sought notice. However, due to the technical requirements of the DIACAP certification we were unable to determine if any of these contractors would be able to technically meet the requirements of the contract. The current security efforts in place for EAFB prevented internet access off base thus resulting in a delay to the acquisition and a solution sought by the 96 MDG.

A Pre-Solicitation Notice Amendment for Medical Transcription Services at Eglin was posted on http://www.fbo.gov [www.fbo.gov] on 2 June 2011 requesting industry comments concerning the requirement for IT platform/transcription service and technical capability. We also requested that the contractors provide a Rough Order of Magnitude for Transcription/IT services for planning purposes and whether they are able to satisfy the technical criteria posted. There were three responses received in August 2011.

March 2012 - PWS was re-posted on Feb Biz Ops for 45 days as Small Business with an IT NAICS.

April 2012 - Solicitation proposals were received from interested vendors and evaluations were conducted in May 2012; however, a protest was also filed in April 2012. Subsequently, the requirements were separated, with the IT/Software portion awarded 15 Jan 2013, under an IT NAICS. The Transcription Service was scheduled to be awarded on GSA, set aside for a SDVOSB, by 31 March 2013.

Feb 2013 - AFMS changed their security requirements and all private health information has to flow through a Business to Business (B to B) gateway. The software/hardware solution cannot be implemented without the B to B modification to the software contract, thus creating this need for a new bridge transcription service contract.

Sept 2013 - AFMS changed their security requirements and all private health information has to flow through a Business to Business (B2B) gateway. The software/hardware solution cannot be implemented without the B2B modification going through extensive testing at SG6 and DIACAP certification process. The paperwork has been submitted for this process and should receive approval within the next four months thus creating this need for an extension of the present bridge contract.

Nov 2013 - 3M and the Surgeon General Information Assurance (SGIA) team completed security testing on Nov 14, 2013. The Authority to Operate (ATO) was received on 27 December 2013. This extension is necessary due to the testing of the Business to Business gateway (B to B), the Composite HealthCare System (CHCS) and the Essentris interfaces for the electronic record during the period of Jan 2014 - 31 March 2014. The training of providers and staff on the new equipment and software will also occur during this time period. A new medical transcription contract will be competed and awarded, and their personnel will have to be trained on the new government owned equipment.

VII. DETERMINATION BY THE CONTRACTING OFFICER THAT THE ANTICIPATED COST TO THE GOVERNMENT WILL BE FAIR AND REASONABLE

Anticipated costs will be determined fair and reasonable based on price analysis in accordance with FAR 13.106(3)(a). The proposal will be evaluated by the government's technical representatives prior to award. The determination of fair and reasonable pricing is based on the fact that America's Pride has agreed to extend the contract at the current rates on the original contract, which was competed. The only adjustments made to those prices were due to increases to the Wage Determination. The contractor also agreed to maintain option year three pricing levels for this effort due to the economic situation.

VIII. DESCRIPTION OF THE MARKET RESEARCH CONDUCTED AND THE RESULTS, OR A STATEMENT OF THE REASONS MARKET RESEARCH WAS NOT CONDUCTED

As described in Section VI above, market research, in accordance with FAR Part 10 was conducted by synopsis of proposed acquisition, advising industry of the pending acquisition and soliciting inquiries from interested parties. Due to time constraints, America's Pride is the only company able to provide this service so there is no interruption in service and no harm to the Government. Their employees are currently in place under the current FA2823-13-M-R012 contract. However, we are unable to finalize the technical solution as anticipated due to the change in requirements thus creating a need for an extension of the bridge contract.

IX. ANY OTHER FACTS SUPPORTING THE USE OF OTHER THAN FULL AND OPEN COMPETITION

The technical specifications and PWS for the upcoming contract have been completed and the upcoming contract will be awarded during the three month period of performance that this contract will cover.

X. LIST OF SOURCES, IF ANY, THAT EXPRESSED INTEREST IN THE ACQUISITION

See Section VI above.

XI. 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

A fully competitive follow-on acquisition is planned. This competed contract will have a period of performance start date of 1 April 2014.

XII. CONTRACTING OFFICER'S CERTIFICATION

The contracting officer's signature on the Coordination and Approval Document evidences that he/she has determined this document to be both accurate and complete to the best of his/her knowledge and belief (FAR 6.303-2(a)(12)).

XIII. TECHNICAL/REQUIREMENTS PERSONNEL CERTIFICATION

As evidenced by their signatures on the Coordination and Approval Document, the technical and/or requirements personnel have certified that any supporting data contained herein, which is their responsibility, is both accurate and complete (FAR 6.303-2(b).

Link/URL: https://www.fbo.gov/notices/b6b467c91d2423e22a95a7592216efbe