Description
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Brand Name Justification >SAT
VHAPG Part 806.3 OFOC Page 2 of 5
Revision: 04 Effective Date: 12/15/25
Acquisition ID#:
and workflow standards. The performance period covers the delivery and installation
timeframe required to integrate the drawers into active pharmacy infrastructure, and
installation must be coordinated with Pharmacy, OIT, and Biomedical Engineering as
outlined in the previously approved Statement of Work
4. Demonstration that the Contractor’s Unique Qualifications or Nature of the
Acquisition Requires the Use of the Authority Cited Above (applicability of
authority):
The acquisition requires the use of a brand-name justification because BD Pyxis
Cubie Drawers are highly specialized, proprietary components that integrate directly
with the BD Pyxis MedStation ES medication dispensing platform. These drawers
use BD-specific firmware, calibration protocols, and security features that no
third-party product can replicate or integrate with.
Any attempt to use non-BD components would compromise system certification,
void warranties, and require expensive revalidation and reprogramming of the entire
automated dispensing system, resulting in significant delays and duplication of cost.
Additionally, the Pyxis ES platform is a closed, FDA-regulated system in which
alternative components are not validated or supported; therefore, only brand-name
BD drawers satisfy the clinical, cybersecurity, and operational requirements. The
drawers also support VHA Directive 1195 by providing controlled
single-compartment access, secure medication segregation, and automated audit
trails, which are essential for high-alert drug management.
No other product meets these mandatory features, and no alternative manufacturer
offers a compatible or substitutable solution. As such, while the procurement will be
competed among authorized SDVOSB distributors, the brand-name restriction is
essential to meeting the Government's requirements.
5. Description of Efforts Made to ensure that offers are solicited from as many
potential sources as possible (including whether a notice was or will be
publicized as required by RFO Part 5 and, if not, which exception under RFO
Part 5 applies):
Efforts were made to maximize competition to the extent practicable. A Notice of
Intent (NOI) to sole source was posted on the Governmentwide Point of Entry,
Contract Opportunities, from July 15 through July 18, 2025. The NOI sought industry
feedback from any capable vendor that could provide the required BD Pyxis Cubie
Drawers. No responses were received during the NOI period, which initially
suggested that only one responsible source existed.
However, during the subsequent solicitation phase, multiple SDVOSB firms
submitted quotations for the requirement. The manufacturer later confirmed that
these firms were authorized distributors of BD Pyxis capital equipment. As a result,
rather than awarding a sole source contract, the acquisition was transitioned to a
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Brand Name Justification >SAT
VHAPG Part 806.3 OFOC Page 3 of 5
Revision: 04 Effective Date: 12/15/25
Acquisition ID#:
competitive SDVOSB set-aside, ensuring that as many potential sources as feasible
could participate. Additional market research was conducted through eCMS, GSA
eLibrary, DSBS, VetCert, AbilityOne, and SAM, with no evidence of any non-BD
manufacturer capable of offering equivalent or compatible items.
These actions demonstrate that the Government took steps to identify competitive
sources and ultimately obtained multiple viable SDVOSB quotes consistent with
VA’s small business priorities.
6. Determination by the CO that the Anticipated Cost to the Government will be
Fair and Reasonable:
The Contracting Officer has determined that the anticipated cost for this acquisition
will be fair and reasonable based on several factors. First, multiple SDVOSB firms
submitted competitive quotes for the same BD brand-name items, providing
adequate pricing competition within the authorized distributor network. Second, the
estimated value of $302,544.00 is consistent with previous procurement history for
this equipment and aligns with BD’s established pricing for federal customers.
Third, any awarded contractor must be an authorized distributor, ensuring pricing
reflects genuine, authorized product sources and not inflated or reseller-inflated
rates. Cost and price analysis will include comparison of competing quotes,
verification of authorized distributor status, evaluation against historical pricing, and
assessment of price reasonableness for installation services. Certified cost or pricing
data is not required due to the competitive nature of the SDVOSB set-aside and the
firm-fixed-price structure of the procurement.
7. Description of the Market Research Conducted and the Results, or a
Statement of the Reasons Market Research Was Not Conducted:
Market research complied with RFQ Part 10 and VAAR 810.001-70. Searches of
VetCert identified hundreds of SDVOSBs under NAICS 339112, but only three were
identified by the manufacturer as authorized distributors of BD Pyxis drawers.1
Additional searches of AbilityOne, DSBS, and GSA eLibrary identified zero
alternative manufacturers or equivalent products capable of meeting VA’s needs. An
NOI was posted and received no responses. However, during the formal solicitation,
multiple SDVOSBs submitted quotes and the manufacturer independently confirmed
their authorized status. This established the VA “Rule of Two,” supporting an
SDVOSB set-aside. Market research also confirmed that BD is the sole
manufacturer of the required drawers, that no equivalent products exist, and that a
brand-name justification is required.
8. Any Other Facts Supporting the Use of Other than Full and Open Competition:
The use of a brand-name restriction is justified because BD Pyxis Cubie Drawers
are the only products compatible with the VA’s existing BD Pyxis MedStation ES
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Brand Name Justification >SAT
VHAPG Par…
Source: SAM.gov, as posted. Verify the current solicitation before responding.