20260327_CUI_FLVN_JEFO_2026_29_Redacted.pdf

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Blackboard Licenses and Annual Subscriptions - Justification for Exception to Fair Opportunity
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Leavenworth_JEFO_2026_29
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Summary

This is a Justification Review Document for an exception to fair opportunity under FAR Part 16, approving a Firm-Fixed-Price (FFP) delivery order for Blackboard licenses and annual subscriptions at Fort Leavenworth, Kansas. The procuring activity is the U.S. Army University (ArmyU) and its subordinate colleges, including the Command and General Staff College, Command and General Staff School, School of Advanced Military Studies, Army Management Staff College, and United States Army Sergeants Major Academy. The contracting activity is the U.S. Army Mission and Installation Contracting Command (MICC) at Fort Leavenworth. The estimated contract value is $9.5 million for a five-year period of performance consisting of a base year (01 APR 2026 – 31 MAR 2027) and four option years extending through 31 March 2031. Funding will be provided through Operations and Maintenance (OMA) funds for April 2026 and Fiscal Year 2026.

The justification supports restricting competition to authorized resellers of Blackboard licenses under FAR 16.505(a)(4) – Items Peculiar to One Manufacturer. ArmyU has utilized Blackboard as its learning management system (LMS) since at least 2018 to distribute educational materials and maintain academic accreditation. The specific Blackboard licenses and subscriptions required include Technical Services Custom Development Subscription, EACVisualData, Universal Authentication System Annual Subscription, Professional SaaS Advantage packages, Collaborate for enterprise communications, and Blackboard Video Studio. The justification establishes that alternative LMS platforms (such as Canvas, Zoom, or Adobe Connect) would require significant investment in time and money to migrate existing educational materials and train students and staff. The document confirms that effective competition will be achieved through solicitation on the Army's Digital Marketplace, a mandatory source under AFARS 5139.101-90, which will be posted to the Digital Marketplace for Information Technology Enterprise Solutions Software 2 (ITES-SW2) contract holders. The award was approved on 06 March 2026 by Scott D. Kukes, Alternate Advocate for Competition.

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Control No: MICC 2026-29

Director, MICC-Fort Leavenworth:

Assistant Director, Small Business Program:

These vendors are authorized resellers of Blackboards licenses and subscriptions. Due to requiring licenses and subscriptions for an existing LMS system, only authorized vendors of Blackboard supplies are capable of fulfilling the government’s requirement.

To maintain continuity and operations of the existing LMS, Blackboard licenses and subscriptions are required to continue providing POIs IAW the ALM. Any other licenses or subscriptions will not fulfill the government’s requirement due to not being able to integrate with the existing LMS.

Other LMS such as Canvas, Zoom, and Adobe Connect can fulfill the government’s request for licenses and subscription; however, to utilize these LMS will require a significant investment in time and money to rewrite existing educational materials, transfer POIs to a new system, train students and staff on the new LMS, and purchase new software to obtain the same level of educational operations Blackboard currently provides.

When considering the significant investment in time and money required to transfer the current LMS to a new one, it is most advantageous for the government to procure licenses and subscriptions for the existing LMS, Blackboard.

Other technical data packages, specifications, engineering descriptions, statements of work or purchase descriptions suitable for full and open competition are not available for this procurement due to the nature of the required supplies. No other licenses or subscriptions will integrate with the existing LMS, Blackboard, to allow ArmyU to maintain educational operations.

7. Efforts to Obtain Competition: IAW FAR 5.101(b)(1)(iv), a pre-solicitation notice is not required for this action since the award will be a delivery order issued under a delivery order contract.

a. Effective Competition: Effective competition will be achieved through soliciting the requirement on the Army’s Digital Marketplace, a mandatory source, with the applicable redacted limited source justification. The requiring activity (RA) posted a request for information (RFI) to the Digital Marketplace and received a response from an other than small business.

b. Subcontracting Competition: Subcontracting competition is not feasible for this action due to all vendors being authorized resellers of Blackboard licenses and subscriptions. There are no subcontracting possibilities for providing licenses and subscriptions resold from the sole manufacturer.

8. Actions to Increase Competition: IAW AFARS 5139.101-90(a)(1), The Army's Digital Marketplace under the oversight of PEO Enterprise is the mandatory source for

Competitive Status: Other than full and open competition Authority: FAR 16.505(a)(4) Restricting consideration to an item peculiar to one manufacturer.

Approval

Based on the foregoing justification, I hereby approve the procurement of ArmyU Blackboard Licenses and subscriptions using an exception to fair opportunity pursuant to the authority of Federal Acquisition Regulation16.505(a)(4) – Items Peculiar to One Manufacturer. The estimated value of the delivery order is $9.5 million for a five-year period of performance consisting of a base year and four option years from approximately 01 April 2026 through approximately 31 March 2031. The approval is subject to the availability of funds, and provided that the services or supplies herein described have otherwise been authorized for acquisition.

SCOTT D. KUKES

Alternate Advocate for Competition U.S. Army Mission and Installation Contracting Command, JBSA Fort Sam Houston, TX

KUKES.SCOTT.

DEAN.1151934

Digitally signed by

KUKES.SCOTT.DEAN.1151

934346 Date: 2026.03.06 12:06:37 -06'00'

File details come from the government source that posted it. Updated .