Justification and Approval (J and A) for PDS - AMCamExchange.pdf

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

SECTION 1: IDENTIFICATION OF THE AGENCY AND THE CONTRACTING ACTIVITY

Department of State Contracting Activity ☒ Overseas Post: U.S. Embassy in Phnom Penh

Requiring Activity Public Diplomacy Section (PDS) for AmCam Exchange space leasing and services

SECTION 2: NATURE AND/OR DESCRIPTION OF THE ACTION BEING APPROVED

Approval is requested to award on a sole source for space leasing and staffing to provide EducationUSA counseling services and American Spaces programming from September 30, 2025, to September 29, 2026.

The estimated cost is $70,963 for the supplies and/or services described in Section 3 on behalf of the Requiring Activity.

SECTION 3: DESCRIPTION OF SUPPLIES/SERVICES REQUIRED TO MEET THE AGENCY’S NEEDS

The requirement is to provide EducationUSA and American Spaces services, provide the facility, and maintain “AmCam Exchange”, located at Exchange Square Mall on street 106, Sangkat Wat Phnom, Phnom Penh. The estimated value for the entire period of performance is $ 70,963.

The rental space hosts the Phnom Penh American Corner (AmCam Exchange), where staff oversee daily operations, programming, outreach activities and guest interfacing, and the leasing and maintenance of the physical space. The contractor is responsible for ensuring the EducationUSA advising center and American Corner remain open to the public 10 hours per day, 7 days a week, while maintaining smooth operations and alignment with U.S. foreign policy priorities, as directed by the U.S. Embassy Public Diplomacy Section staff.

SECTION 4: IDENTIFICATION OF THE STATUTORY AUTHORITY PERMITTING OTHER THAN

FULL AND OPEN COMPETITION

This acquisition is conducted under the authority of 41 USC 3304, as implemented by FAR 6.3 and substantiated by the following:

☒ FAR 6.302-1 – Only one responsible source and no other supplies or services will satisfy agency requirements.

SECTION 5: DEMONSTRATION THAT THE PROPOSED CONTRACTOR’S UNIQUE

QUALIFICATIONS OR THE NATURE OF THE ACQUISITION REQUIRES USE OF THE AUTHORITY

CITED

In partnership with Pannasastra University of Cambodia (PUC), Embassy Phnom Penh established the American Corner in 2004 and expanded it in 2012 by adding an EducationUSA advising center to the space. In

2020, Embassy Phnom Penh continued its partnership with PUC when establishing the AmCam Exchange— formerly known as the Phnom Penh American Corner—at Exchange Square Shopping Mall. The mall’s location directly behind the Embassy offers greater convenience for Mission staff, facilitating program implementation and enabling meetings with contacts to be conducted more efficiently. To align with the mall’s operating hours, AmCam Exchange is open to the public 10 hours per day, 7 days a week. There is currently an MOU in place for PUC to provide the venue, services, and equipment in AmCam Exchange.

AmCam Exchange is also the U.S. Embassy’s EducationUSA advising center. The Director of AmCam Exchange has undergone extensive training and is the only non-embassy EducationUSA advisor in Phnom Penh certified by the Department of State’s Bureau of Educational and Cultural Affairs (ECA). Additional support staff have received training provided by the Office of American Spaces (ECA). PUC is the only organization in Phnom Penh that meets the embassy’s EducationUSA advising requirements, as evidenced by the following training transcript:

- 2023: Attended American Spaces Cambodia Staff Training by Elenita Tapawan, Regional Public Engagement Specialist.

- 2022: Received EducationUSA Award for "Innovative Programming in East Asia and Pacific Region" at the EducationUSA Forum, Washington, D.C., USA.

- 2020: Earned certificate in recognition of completing the EducationUSA Level Two Adviser Training Institute.

- 2019: Participated in NAFSA: Association of International Educators and school visits in San Antonio, Texas, and Washington, D.C., USA.

- 2017: Attended International Association for College Admission Counseling in Cleveland, Ohio, and Washington, D.C., USA.

- 2016: Participated in the 16th EducationUSA East Asia and Pacific Regional Forum in Seoul, South Korea.

- 2013: Completed ECA training on "Effective American Corners Management" in Siem Reap, Cambodia.

- 2011: Attended training on "American Corners and Centers: Refresh!" in Taipei, Taiwan.

- 2009: Participated in the workshop "Supporting and Sustaining Your American Corners" at U.S.

Embassy Phnom Penh.

- 2005: Attended "American Corners: A Workshop for American Corner Staff" FSI course at the American

Embassy in Bangkok.

PUC’s role as a partner is irreplaceable. They hold the current lease on the space, and they are the only entity in Phnom Penh with the EducationUSA expertise. This partnership has provided Post unprecedented access to young, strategic audiences, enabling the Embassy to effectively communicate American society, culture, values, and policies to large groups of individuals critical to achieving public diplomacy goals in Cambodia.

SECTION 6. DESCRIPTION OF EFFORTS TO ENSURE THAT OFFERS WERE SOLICITED FROM AS

MANY POTENTIAL SOURCES AS IS PRACTICABLE, INCLUDING WHETHER A NOTICE WAS OR

WILL BE PUBLICIZED AS REQUIRED BY FAR SUBPART 5.2 AND, IF NOT, WHICH EXCEPTION

UNDER FAR 5.202 APPLIES

- No additional market research was conducted because it is not practicable, for the reasons discussed in paragraph 5 above, for any company other than PUC to provide the required supplies and services.

SECTION 7. DETERMINATION BY THE CONTRACTING OFFICER THAT THE ANTICIPATED COST

TO THE GOVERNMENT IS FAIR AND REASONABLE

The Contracting Officer has determined the anticipated price to the Government of services covered by this J&A will be fair and reasonable based on price competition, price analysis, market prices, historical prices, and cost estimate. By signing the justification, the Contracting Officer makes a determination that the price to the Government is expected to be fair and reasonable.

SECTION 8. DESCRIPTION OF THE MARKET RESEARCH CONDUCTED (SEE PART 10) AND THE

RESULTS OR A STATEMENT OF THE REASON MARKET RESEARCH WAS NOT CONDUCTED

No additional market research was conducted because it is not practicable, for the reasons discussed in paragraph 5 above, for any company other than PUC to provide the required supplies and services.

SECTION 9. ANY OTHER FACTS SUPPORTING THE USE OF OTHER THAN FULL AND OPEN

COMPETITION

SECTION 10. LISTING OF THE SOURCES, IF ANY, THAT EXPRESSED, IN WRITING, AN INTEREST

IN THE ACQUISITION

To date, no other sources have written to express an interest.

SECTION 11. STATEMENT OF THE ACTIONS, IF ANY, THE AGENCY MAY TAKE TO REMOVE OR

OVERCOME ANY BARRIERS TO COMPETITION BEFORE ANY SUBSEQUENT ACQUISITION FOR

THE SUPPLIES OR SERVICES REQUIRED

In order to change the conditions that would preclude use of full and open competition for acquiring the same or similar supplies or services in the future, the State Department Bureau of Educational and Cultural Affairs (ECA) would have to be able to ensure funding to train a new EducationUSA advisor at a different organization. Due to budget uncertainties, Post cannot estimate a date of the first competitive acquisition.

SECTION 12. CERTIFICATIONS

All reviews and approvals should be completed in the order listed unless otherwise authorized or required.

TECHNICAL AND REQUIREMENTS CERTIFICATION (FAR 6.303-2(b))

I certify that the facts and representations under my cognizance which are included in this Justification and its supporting acquisition planning documents, except as noted herein, are complete and accurate to the best of my knowledge and belief.

Technical/Requirements Cognizance:

SIGNATURE:

Name Date: Aug. 27, 2025 Sara Feuerstein Public Diplomacy Officer

CERTIFICATIONS (Continued)

CONTRACTING OFFICER CERTIFICATION (FAR 6.303-2(a)(12)) I certify that this submission is accurate to the best of my knowledge, and that it contains complete information necessary to enable other officials to make an informed recommendation for approval or disapproval.

Daniel Wilson Contracting Officer

SECTION 13. APPROVALS

HEAD OF THE CONTRACTING ACTIVITY

Daniel Wilson

HCA

NOTE: Each review must stipulate and include lower level signatory concurrence only prior to the higher dollar threshold approval. Signatories shall not exceed FAR or U.S.C. dollar threshold authority.

08/27/2025 09:16 GMT

Feuerstein, Sara (FeuersteinS@state.gov)

08/27/2025 10:10 GMT

Wilson, Daniel (WilsonDL@state.gov)

08/27/2025 10:10 GMT

Wilson, Daniel (WilsonDL@state.gov)