Joerns Healthcare, LLC v. United States

CourtUnited States Court of Federal Claims
DecidedApril 28, 2026
Docket25-1688
StatusUnpublished

This text of Joerns Healthcare, LLC v. United States (Joerns Healthcare, LLC v. United States) is published on Counsel Stack Legal Research, covering United States Court of Federal Claims primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Joerns Healthcare, LLC v. United States, (uscfc 2026).

Opinion

In the United States Court of Federal Claims No. 25-1688 Filed: April 1, 2026 Re-issued: April 28, 2026 1 ________________________________________ ) JOERNS HEALTHCARE, LLC, ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES, ) ) Defendant ) ) ________________________________________ )

Aron Beezley, Bradley Arant Boult Cummings LLP, Washington, D.C., for Plaintiff.

Thomas J. Adair, Trial Attorney, Commercial Litigation Branch, Civil Division, Department of Justice, for Defendant. Laura B. Reass, Office of General Counsel, U.S. Department of Veteran Affairs, of counsel.

OPINION AND ORDER

This case primarily calls upon the court to determine what the Department of Veterans Affairs (“VA”) meant when it solicited hospital beds with a “minimum” width of 36 inches and others that could extend to “at least” 42 inches wide. The solicitation also made clear that bed dimensions would be verified with a tape measure to ensure compliance, with no indication that variation from the minimum requirements would be acceptable. In fact, failing to meet minimum dimensions would result in the offer being deemed non-responsive and excluded from further consideration. The answer seems obvious enough; words have meaning after all.

Unhappy with its exclusion from the competition because the beds it submitted for evaluation failed to meet both width requirements, Joerns Healthcare, LLC contends the language was not so clear when viewed through the lens of industry practices. To Joerns, industry practices led it to believe that the VA did not really mean 36 inches or 42 inches. Joerns

1 The court initially issued this opinion and order under seal and directed the parties to confer and propose redactions pursuant to the protective order. The parties have jointly proposed redactions that the court adopts with the following notation: “[ * * * ]”. The court also made one typographical correction to avoid ambiguity by capitalizing one instance of a defined term that was inadvertently not capitalized in the original version of this opinion. See RCFC 60(a). contends that, in the hospital bed market, beds within an inch of the stated dimensions are acceptable. There are several problems with this belief. First, it is not a reasonable interpretation of the solicitation because it ignores “minimum” and “at least” by shifting the focus to a purported industry understanding of 36 inches. But the VA simply is not procuring 36-inch beds, it is procuring beds that are a “minimum” of 36 inches wide and some that can expand to “at least” 42 inches wide. Second, the record confirms that various manufacturers make beds with varying widths, meaning that the VA had to provide clear requirements rather than rely on an amorphous, self-serving assertion that being over 35 inches wide and expanding to more than 41 inches is good enough. That is what the VA did. Third, even if Joerns’ interpretation was reasonable, the disparity between Joerns’ view and the plain text of the solicitation is so great and obvious from the face of the solicitation that Joerns’ failure to protest before the submission of proposals waives its argument. And finally, even if the court were to accept Joerns’ argument, Joerns could not show prejudice because the beds it submitted failed to meet the standard Joerns insists should apply.

Perhaps sensing that it would not prevail with its interpretive argument, Joerns throws in a Hail Mary. Joerns contends that the VA selected beds that do not qualify as commercial products and therefore are ineligible for award in this commercial product procurement under FAR Part 12. But the record simply does not support Joerns’ argument, which Joerns bases on attorney argument and hearsay.

In the end, there is no reason that the VA cannot procure the beds it has asked for since the start of this procurement. As a result, the court denies Joerns’ motion for judgment on the administrative record and grants the United States’ cross-motion for judgment on the administrative record.

I. Background

A. Pre-Solicitation Research

In 2024, the Veterans Health Administration, Prosthetic & Sensory Aids Service identified a need for “Hospital Beds for Home Use w/Accessories.” Tab 13, AR 106. These beds are intended for use by elderly or disabled veterans being cared for outside of a hospital in a community care or home setting. Id. The Department of Veterans Affairs (“VA”) formed an Integrated Project Team (“IPT”), comprised of various government stakeholders and clinical subject matter experts (“SMEs”), to “develop[] minimum technical requirements, acquisition plan, source selection plan, and evaluation criteria, as well as perform[] and document[] the technical evaluation.” Tab 3, AR 11.

The VA began with market research to determine “the most suitable approach” to satisfy its needs. Tab 11, AR 53. It kicked off this effort with an in-person “Industry Day” on June 24, 2024, where thirteen hospital bed manufacturers showcased their beds to SMEs. Id. at 63-64.

Then, on November 1, 2024, the VA posted an RFI notice to SAM.gov to solicit industry feedback on its draft Minimum Technical Requirements (“MTRs”). Tab 7, AR 38-39. Relevant here, draft MTR 1 laid out the physical dimension requirements for the two types of beds that the VA was seeking:

2 Upgraded Electric Bed Frame with minimum length of 80 inches and width of 36 inches; Bed must have the ability to adjust both length (up to at least 84 inches) and width (up to at least 42 inches); Bed must be able to accommodate bed side rails (no mattress)

Basic Electric Bed Frame Model should be made available meeting 80″ x 36″ that does not require adjustable capability (no mattress)

Tab 8, AR 41-42. 2 Five vendors commented on MTR 1. One vendor, [ * * * ], recommended a “minimum width of 35 inches to align with industry standards” and “avoid unnecessary restrictions that could limit competition.” Tab 6 (emphasis added). Joerns had different concerns, suggesting that “[t]he Upgraded Bed Frame and the Basic Electric Bed Frame be listed as separate MTRs and CLINs.” 3 Id. Notably, Joerns did not identify any conflict between the bed width requirements and industry norms. Rather, Joerns itself agreed that MTR 1 requires a “minimum width of 36 inches” and an adjustable width “up to at least 42 inches.” Id.

Based on the market research, the Contracting Officer felt “confident. . . that there w[ould] be 2 or more Small Businesses that provide acceptable proposals.” Tab 11, AR 64. Thus, the VA concluded that its desired hospital beds were “available in the commercial marketplace” and recommended that the solicitation be a small business set-aside. Tab 13, AR 106.

B. The Solicitation

On February 5, 2025, the VA issued Solicitation No. 36C10G25R0011 (“Solicitation”), titled “Hospital Beds for In Home Use.” Tab 19, AR 161. It was designated as a total small business set-aside under the Federal Acquisition Regulation (“FAR”) Part 12’s procedures. Id. at AR 161, 210; Tab 25 at AR 435, 486. 4 The VA would consider four factors when evaluating offers: (1) Technical, (2) Past Performance, (3) Socio-economic, and (4) Price. Tab 19 at AR 218; Tab 25 at AR 494. Because this protest involves only the technical evaluation, the court does not delve into the remaining factors.

The technical evaluation was to proceed in two phases. In Phase 1, the VA evaluated commercial product literature to determine whether the proposed beds preliminarily satisfied all

2 The administrative record contains a pdf printout of the SAM.gov website posting that includes a link to the draft MTRs. See In Home Hospital Beds, SAM.gov, https://perma.cc/2RR2-4G8J. It is unclear why the draft MTRs themselves are not included in the administrative record as they plainly belong there.

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Joerns Healthcare, LLC v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/joerns-healthcare-llc-v-united-states-uscfc-2026.