JA_GX2_Final_Redacted.pdf

CONTROL NUMBER VA-25-00085155

JUSTIFICATION

FOR AN EXCEPTION TO FAIR OPPORTUNITY

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

Office of Procurement, Acquisition, and Logistics Technology Acquisition Center 23 Christopher Way Eatontown, NJ 07724

2. Description of Action: The proposed action is for a firm-fixed-price delivery order to be issued under the National Aeronautics and Space Administration (NASA) Solutions for Enterprise-Wide Procurement (SEWP) V Government-Wide Acquisition Contract (GWAC) for brand name Cority GX2 Subscriptions.

3. Description of the Supplies or Services: The proposed action is for brand name Cority GX2 subscription licenses in continued support of VA enterprise rollout of the Occupational Safety and Industrial Hygiene Plus (VA OSI+) initiative. Cority is a commercial off the shelf (COTS) platform that provides integrated functionality across occupational safety, industrial hygiene, and ergonomics, featuring analytics, dashboards and case management tools on a consolidated, secure enterprise platform. This requirement includes subscription quantities sufficient to support the enterprise rollout of the Safety Module, as well as a limited number of licenses for Industrial Hygiene, Ergonomics and MyCority. This will allow the Integrated Project Team (IPT) to continue requirements elaboration, and planning for broader deployment of the additional Cority modules. This strategy will meet VA’s Occupational Safety, and Health (OSH) number one priority, of delivering an Enterprise Safety Module for illness and injury reporting.

Further it supports ongoing planning and preparation efforts for future modules within the Cority GX2 platform to meet VA’s complete requirements. The period of performance shall be a 12-month base with one 12-month option period, and one optional task. The total estimated value of the proposed action is , inclusive of the option and optional task.

VA awarded a competitive Delivery Order (DO) to Four Points Technology, LLC in August 2024 for an initial configuration and evaluation efforts through a proof of concept which allowed the VA Subject Matter Experts to have hands on opportunity to validate whether Cority GX2 could meet VA requirements. Upon completion of the proof of concept, VA has confirmed Cority GX2 meets the government requirements.

4. Statutory Authority: Pursuant to Federal Acquisition Regulation (FAR) Subpart 16.505(a)(4), the following brand name requirement 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 16.505(b)(2)(i)(B), 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: Based on market research, as described in Section 8 of this justification, it was determined that Four Points Technology, LLC is the only authorized provider of the required brand name Cority

GX2 Subscriptions that is able to meet the Government’s need. In August 2024, VA awarded a competitive DO that resulted in the selection of the Cority solution. Cority allowed VA to accomplish a proof of concept by hands on participation of VA’s Subject Matter Experts (SMEs). Additionally, the highest priority for VA, Incident Reporting, was configured demonstrating the ability to support a full VA deployment to meet the urgent need of VA. VA has determined that only Cority brand name solution meets the program’s enterprise-wide functional, technical, and integration needs for occupational safety, industrial hygiene, and ergonomics case management. Cority is the only Environmental, Occupational Safety, and Health (EOSH) solution that meets the full scope of VA's requirements within a single, integrated, multi-tenant Software as a Service (SaaS) platform. Cority has received FedRAMP moderate authorization, ensuring compliance with stringent federal security standards. Cority provides advanced Bayesian statistical analysis capabilities, enabling precise risk assessments and data validation for workplace safety. Furthermore, the Cority solution also features a single mobile application (myCority) that integrates all EOSH functional capabilities in one interface, accessible across various hardware platforms including PCs, tablets, and smartphones. No other solution offers such comprehensive and integrated capabilities in an EOSH SaaS platform, making Cority uniquely suited to the VA's needs.

During the proof-of-concept period, VA OSH and Administration subject matter experts identified Injury and Illness Incident Reporting as VA’s number one priority.

In response, the system integrator configured and delivered (based on IPT requirements gathering) a comprehensive set of system requirements to support full enterprise functionality for this priority use case. As a result of these efforts, the solution to meet VA’s most critical need, incident and injury reporting, is now ready for production delivery, further demonstrating the urgency and unique need to continue with brand name Cority SaaS subscriptions. If VA procured an entirely new SaaS subscription solution, it would result in approximately in duplicative costs and it would require an estimated two to four years to completely replace the current Cority software integrated in VA’s EOSH platform. These estimated duplicative costs would not be recovered through competition. Failure to procure the required Cority subscriptions would negatively impact VA’s ability to modernize and deploy VA enterprise-wide injury and illness incident reporting platform. Without the current Cority subscription, VA will continue in the current environment of fragmented processes, inconsistent data collection, and limited visibility into patient safety-related trends across facilities and negatively impacting the safety of VA employees and Veterans.

6. Efforts to Obtain Competition: Market research was conducted, details of which are in section 8 of this justification. This effort did not yield any additional sources that can meet the Government’s requirements. In accordance with FAR 16.505(a)(4)(iii)(A)(1), this justification will be provided with the solicitation to all appropriate NASA SEWP V GWAC holders. Furthermore, in accordance with FAR 5.301, 16.505(b)(2)(ii)(D), and 16.505(a)(4)(iii), the award notice for this action will be synopsized on the Contract Opportunities website and this justification will be made publicly available within 14 days of award.

7. Actions to Increase Competition: The Government will continue to conduct market research to ascertain if there are changes in the marketplace that would enable future actions to be completed.

8. Market Research: Market research was performed as part of an assessment of needs from January through June 2025 to determine if there are viable sources other than brand name Cority who could provide the necessary SaaS solution that could meet VA’s requirement. Specifically, the Government’s technical expert researched and reviewed similar brands such as Salesforce and ServiceNow. However, none of these brands can meet VA’s requirements because only Cority or an authorized reseller can provide the required functionality through out-of-the-box capabilities, minimizing the need for extensive customization and integration efforts. In addition, VA’s SME regularly review industry trade publications and conduct internet research to ascertain if any other brand name is available. Currently, there is no other alternative solution available in the marketplace that can meet VA’s requirements. Based on all these market research efforts, the Government’s technical experts have determined that only Cority brand name can meet all of the Government’s requirements.

Additionally, market research was conducted in June 2025 by utilizing the NASA SEWP V GWAC Provider Look-up Tool to determine whether the brand name Cority is available from NASA SEWP V GWAC Contract holders. It was determined that the Cority GX2 subscriptions can be procured from Cority or its only approved reseller, Four Points Technology, LLC.

Furthermore, Cority provided confirmation that Four Points Technology is the sole authorized provider of Cority, and that the required GX2 subscriptions are sold exclusively through one authorized reseller, Four Points Technology, LLC, a Service- Disabled Veteran-Owned Small Business.

9. Other Facts: N/A

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: ___ _________________

Signature: _____ ___

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 anticipated competition. Additionally, NASA SEWP V GWAC has already determined the prices on contract to be fair and reasonable ad more competitive pricing may result from competition. Finally, the successful quote will be compared with the Independent Government Cost Estimate.

Date: ______ ________________

Signature: ____ ___

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

Date: ____ _________________

Signature: ___ __