JnA VA-27-00004345 AWS Additional Cloud Credits final_Redacted.pdf

AWS Additional Cloud Credits Control Number VA-27-00004345

JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY

1. Contracting Activity: Department of Veterans Affairs (VA)

Office of Procurement Operations Technology Acquisition Center 23 Christopher Way Eatontown, New Jersey 07724

2. Description of Action: The proposed action is to modify VA Contract/Order NNG15SD22B / 36C10B22F0207 with Four Points Technology, LLC, an authorized Amazon Web Services (AWS) reseller, to increase the ceiling to purchase additional AWS cloud credits for a consumption period estimated at 12 months while a new requirement is competitively solicited. The Delivery Order is a firm-fixed-priced effort for AWS cloud credits issued under the National Aeronautics and Space Administration (NASA) Solutions for Enterprise-Wide Procurement (SEWP) V Government-Wide Acquisition Contract (GWAC) to access AWS cloud service capabilities and professional services.

3. Description of the Supplies or Services: VA, Office of Information and Technology, Enterprise Cloud Solutions Office (ECSO) has a requirement to issue a modification to increase the Not-To-Exceed (NTE) credit ceiling to ensure continued availability of brand name AWS cloud service capabilities and professional services for the VA Enterprise.

The VA Enterprise Cloud (VAEC) strategically built a multi-cloud environment.

Beginning in 2017, ECSO successfully built a new enterprise cloud solution following a competitive solicitation to award its initial Enterprise Cloud Contract (ECC). The solicitation was open to all Cloud Service Providers (CSPs) that could fully meet VA’s security requirements of Federal Risk and Authorization Management Program (FedRAMP) High Government Community Cloud (GCC) with existing VA Authorities to Operate. At that time, only AWS and cloud services could fully meet these technical requirements. In 2022, VA solicited an AWS brand name requirement among authorized resellers on NASA SEWP V to replace the initial 2017 delivery order for AWS cloud credits and professional services.

The VAEC-AWS cloud environments are currently used by over 540 VA systems and applications throughout the VA enterprise. VA systems and applications refer to a wide range of capabilities including but not limited to applications, systems, services, and/or platforms. The minimum technical requirements under this effort shall comply with the following U.S. Government and VA Agency requirements:

1. Provide cloud service offering with VA Authority To Operate (ATO) within each service level including Infrastructure as a Service (IaaS), Platform as a Service

(PaaS), and Software as a Service (SaaS) in their GCC at all FedRAMP security levels.

2. Provide continued operations and expansion of VAEC-AWS and all VA Information Technology (IT) Capabilities operating, migrating to, and being developed within its boundaries.

The proposed effort shall increase the NTE credit ceiling and procure additional AWS credits that can be used for continued access to the full suite of AWS cloud products and services for VA systems and applications that operate within the existing VAEC- AWS environment. The credits are required to maintain the operational availability and security of a multitude of critical VA systems, applications, and workloads already residing in, being migrated to, or being developed in VAEC-AWS environments. AWS credits are also required to enable the development of new, and migration of, additional legacy systems and applications into VA’s existing VAEC-AWS environments, as well as to maintain and expand upon VAEC-AWS infrastructure components including security, tooling and general support services.

This action increases the NTE credit ceiling only; it does not extend the period of performance (PoP) of the underlying contract, which was originally planned to run until 2029. Due to the consumption of AWS cloud credits at a rate faster than originally planned, credits associated with Option Periods 5 and 6 were previously realigned into the Optional Task CLIN established for additional cloud credits. VA anticipates those credits will be exhausted in November 2026. The increased ceiling will provide additional AWS credits estimated to sustain VAEC-AWS operations for approximately 12 months from exhaustion of current credits, continuing VAEC operations in AWS within the existing contract PoP while a competitive contract is solicited, awarded, and transitioned. The additional credits may be exercised at any time, and from time to time, within the remaining life of the order. The original contract was awarded on August 02, 2022 with a total contract value of $521,824,443.39 consisting of a 6 month base period, 6 12-month option periods, and an optional task for additional cloud credits. To date, the base period, option periods 1-4, and the optional task have been exercised and fully funded in the amount of $521,824,443.39. The total estimated value of the proposed action is for an estimated 12-months of cloud credits.

4. Statutory Authority: This action is being justified and approved as an exception to fair opportunity under the statutory authority of Section 41 U.S.C. 4106(c)(2) as implemented by FAR 16.507-6(b)(2), entitled “Only one awardee is capable of providing the supplies or services required at the level of quality required because the supplies or services ordered are unique or highly specialized.”

5. Rationale Supporting Use of Authority Cited Above: As described in Section 3, this effort is to increase the NTE credit ceiling that will provide for continued access to AWS cloud products and services being consumed within VAEC-AWS cloud environments and continued migration and development of VA IT Capabilities while a new competitive solicitation is prepared and subsequent contract awarded earlier than anticipated. VA is charged with protecting an enormous amount of sensitive Veteran and staff protected personal information and protected personal health information. VA currently operates one of the largest multi-cloud environments in the US Federal Government and leverages an extremely diverse ecosystem of cloud services from multiple CSPs to accomplish its mission. VAEC is a premier and secure enterprise cloud with an architecture anchored around core GCC environments within AWS and equipped with common tools and services at the highest level of security (FedRAMP High). The VAEC is a multi-tenant eco-system, managed and controlled by VA, currently supporting over 498 different IT capabilities in production and more than 42 additional IT capabilities at various stages of development or migration. VAEC-AWS requires and uses AWS Cloud Services from all three cloud service models, IaaS, PaaS, and SaaS as delivered in a GCC High deployment model to deliver common security and other tooling to ensure the environment has the services available to support a diverse range of IT Capabilities. The VAEC-AWS environment and its tenant IT capabilities use a growing number of AWS SaaS services (>12), AWS PaaS services (>41) and AWS IaaS services (>43). The Federal Information Security Management Act (FISMA) Classification, confidentiality, integrity, and availability of the multiple applications hosted in VAEC-AWS require a classification of FedRAMP High. Therefore, the CSP’s FedRAMP High GCC must provide services across all three service models (IaaS, PaaS and SaaS) which are fundamental to ensure seamless functionality throughout VAEC. Use of a CSP without all three service models would prevent VA from implementing the VAEC architecture.

To define, solicit, evaluate, award, and transition to a new solution would require significant resources and time. Replacement of the AWS CSP with a different CSP is estimated to take at least 12 months. The 12-month estimate is based on VA’s past experience with standing up AWS and initially as the VAEC. The estimate also accounts for insight and efficiencies established since the initial establishment of VAEC. VA currently has a high volume of 540 systems and applications including bedrock systems hosted in VAEC-AWS. Transitioning to another CSP or solution would require substantial time, and significant effort to onboard a new vendor, establish an ATO, rearchitect, and migrate VA systems and applications. VA would incur a high operational risk of continued services to Veterans supported by systems and applications currently hosted in VAEC-AWS. VA would need to re-establish bill-back and show-back processes that interface with other existing tools and platforms in VA. These include International Business Machines Apptio and Cloudability, multiple ServiceNow modules, and VA’s monitoring tools.

VA estimates transitioning to another AWS reseller would take up to 12 months to complete, based on transition activities that would need to occur. A replacement effort would require VA to transition AWS Payer Accounts, billing processes, credit monitoring, financial reporting, and onboard a new contractor. VA would need to re-architect and establish new Application Programming Interfaces for reporting, bill-back and show-back processes that interface with established toolsets within VA. These include Apptio, Cloudability, and multiple ServiceNow modules. Each month, these processes ingest, assess, sort, and categorize more than 650,000 individual AWS cost and usage charges. Re-establishing these existing processes would require substantial

8. Market Research: On October 28, 2025, VA issued a Request for Information (RFI) via the System for Award Management website (SAM.gov) to industry requesting feedback on increased CSP strategy, pricing models, cost optimization tools, Artificial Intelligence integration, and innovation strategies. On November 12, 2025, VA received 44 responses. This helped with gathering information to define the VA CSP strategy and requirements. On June 2, 2026, VA issued a second RFI via SAM.gov to industry requesting detailed information on how to establish a unified Cloud Brokerage service to manage and onboard CSPs within the VAEC. On July 6, 2026, VA received 31 responses. This provided VA with strategy information and capabilities from Industry.

On August 17, 2026, VA issued a third RFI via SAM.gov to industry seeking feedback to the VA’s Problem Statement for a solution to manage cloud credit procurement, utilization tracking and auditable reconciliation across and future CPS. The results from the third RFI are being used to define the future requirement as the brokerage strategy is new to VA and not something VA has procured before.

VA is actively conducting market research and issued multiple RFIs to gather industry feedback, evaluate opportunities to incorporate additional CSPs, assess vendor capability in the brokerage space, and help refine future VA requirements. The RFI’s demonstrated varying levels of vendor capability in the brokerage space, but all of the alternatives would require substantial time to onboard, approve, and implement as discussed above. This proposed effort, to increase the NTE credit ceiling and procure additional AWS credits, will maintain the current state until the brokerage contract is executed. The original contract that was awarded in 2022 was scheduled to continue until February 2029, but because of the underestimated lifecycle growth of products and applications that migrated to AWS cloud, as well as the growth of the applications themselves, VA exhausted the ceiling much faster than originally anticipated. VA now anticipates running out of cloud credit ceiling in November 2026. Because of the rapid expenditure of cloud credits, VA now requires the credit ceiling to be increased to provide sufficient AWS cloud credits needed for the next 12 months of consumption while the replacement contract is anticipated to be solicited and awarded concurrently as discussed in Section 5 above.

9. Other Facts: None.

10. Technical and Requirements Certification: I certify that the supporting data under my cognizance, which are included in this justification, are accurate and complete to the best of my knowledge and belief.

Date: __________________________

11. Fair and Reasonable Cost Determination: I hereby determine that the anticipated price to the Government for this contract action will be fair and reasonable based on current contract pricing. Additionally, NASA SEWP V has already determined the prices on contract to be fair and reasonable. Finally, if necessary, the successful quote will be compared with the Independent Government Cost Estimate.

Date: ________________________________

12. Procuring Contracting Officer Certification: I certify that this justification is accurate and complete to the best of my knowledge and belief.

Date: ________________________________

13. Office of General Counsel (OGC) Review: I have reviewed this document and find it legally sufficient, based on the representations set forth in the documents and, if any, attachments. The Senior Procurement Executive’s approval is an independently supported decision not wholly reliant on the legal sufficiency determination.

Date: _______________________________