P03 AKP VA-26-00055209 Attachment 6 - Template - JA FAR Part 8 CO Signed PAAC_Redacted.pdf

DEPARTMENT OF VETERANS AFFAIRS

Office of Procurement, Acquisition and Logistics (OPAL)

Strategic Acquisition Center (SAC) 5202 Presidents Ct, Suite 103

Frederick, MD 21703

LIMITED-SOURCES JUSTIFICATION

(1) Identification of the agency and the contracting activity, and specific identification of the document as a "Limited-Sources Justification."

This effort is being conducted under the authority of the Multiple Award Schedule Program. This is a Limited-Sources Justification to obtain Virtual Acquisition Office (VAO) and Acquisition Knowledge Portal (AKP) Subscription services from a Large Business, Unison Virtual Acquisition Office LLC (Unison) on behalf of the Requiring Agency by the Contracting Activity as identified below.

Requiring Activity: Department of Veterans Affairs (VA), Office of Acquisition and Logistics (OAL), Functional Acquisition Manager - Contracting Management Office (FAM-C/COR), Washington, DC

Contracting Activity: Strategic Acquisition Center - Frederick (SAC-F).

(2) Nature and/or description of the action being approved.

The Virtual Acquisition Office (VAO) subscription is proprietary software available on Unisons FSS. This requirement also includes the maintenance of innovative tools, systems, and resources within the AKP targeted for VA’s acquisition workforce, from the only source that is currently providing them:

UNISON VIRTUAL ACQUISITION OFFICE LLC

21251 RIDGETOP CIR, STE 100

DULLES VA 20166

The anticipated award will be a Firm-Fixed-Price (FFP) task order against Unison’s General Services Administration (GSA) Federal Supply Services (FSS) GS-35F-

131GA.

Period of Performance:

Base Year: 09/29/2026 - 09/28/2027 Option Year 1: 09/29/2027 - 09/28/2028 Option Year 2: 09/29/2028 - 09/28/2029 Option Year 3: 09/29/2029 - 09/28/2030 Option Year 4: 09/29/2030 - 09/28/2031

Independent Government Cost Estimate (IGCE):

➢ Total IGCE Value: [REDACTED]

SAC-F Procurement History:

1. 36C10X25P0063 – AKP Portal Maintenance

a. Total Contract Value (TCV): $892,465.00

b. Period of Performance (PoP): 1 Year (9/24/2025 - 9/23/2026)

2. 36C10X24P0040 – VAO and AKP Subscriptions

a. TCV: $4,217,617.00

b. PoP: 1 Year (3/31/2024 – 3/30/2025) + FAR 52.217-8 6 Month extension ultimately ending 9/28/2025

3. 36C10X22C0056 – VAO and AKP Subscriptions

a. TCV: $5,739,813.79

b. PoP: Base (9/30/2022 – 9/29/2023) + 6 Months ultimately ending

3/30/2024

4. 36C10X21C0010 – AKP Portal Maintenance

a. TCV: $1,322,961.35

b. PoP: 8 month base (2/1/2021-9/29/2021) + 1 year Option (9/30/2021-

9/29/2022)

5. 36C10X19F0089 – VAO Subscriptions

a. TCV: $7,943,155.24

b. PoP: Base 9/30/2019 – 9/29/2020 + 2 years ultimately ending 9/29/2022

Based on the acquisition history above, VA OAL has a recurring requirement to procure VAO software licenses which enhance acquisition workforce user access to daily acquisition regulatory and policy updates, targeted training, acquisition tools, and various acquisition webinars for just-in-time training. Additionally, VA OAL has a recurring requirement to obtain real-time knowledge, content management, and other support/services to improve U.S. Department of Veterans Affairs (VA) Acquisition Management, utilizing the existing AKP delivered as Software-as a- Service (SaaS) in conjunction with VAO powered tile services provided by Unison.

The VAO subscription offers real-time information, content, support, and services which are to improve the AKP SaaS through use of VAO powered tile services.

(3) A description of the supplies or services required to meet the agency’s needs (including the estimated value).

The total estimated value of the acquisition is $15.2 Million. The VAO subscription allows VA’s acquisition workforce access to daily acquisition regulatory and policy updates, targeted training, acquisition tools, and various acquisition webinars for just-in-time training; thus, building on the current methods of delivering training and meeting the GAO recommendation to improve acquisition workforce training.

Furthermore, the VAO subscription offers real-time information, content, support and services that would improve VA’s Acquisition Management processes through using the AKP in conjunction with VAO powered tile services.

The development and maintenance of innovative AKP tools, systems, materials, and resources provides the VA acquisition workforce with innovative system technology, such as artificial intelligence and robotic process automation tools to eliminate repetitive acquisition tasks throughout the acquisition lifecycle; thus, producing more efficiency, reliable data systems, and data access streams for a more efficient VA acquisition workforce.

The VAO subscription coupled with the AKP tools, systems, materials, and resources fill critical gaps such as a single source for policy, business practices, templates, tools and access to various other VA and federal systems needed to support the functionality and capability required to complete various acquisition activities throughout the acquisition lifecycle.

(4) The authority and supporting rationale (see GSAM 538.7104-3(b)(ii)).

Authority: GSAM 538.7104-3(b)(ii) Only one source is capable of providing the products, services, or solution required at the level of quality required because the products, services, or solutions are unique or highly specialized;

IAW GSAM 538.7104-3 Orders placed or BPAs established against FSS contracts are exempt from the requirements in FAR part 6. However, an ordering activity must justify its action when awarding on a sole source basis in accordance with this subsection.

Unison Virtual Acquisition Office LLC’s VAO Subscription is the only one source capable of providing these services at the level of quality required because they are unique and highly specialized. Other competitors and products lack many features that are already developed by Unison. Significant developments have already been made to this SaaS platform under the 5 previous awards over the last 7 years. This contract was initially awarded to help the Acquisition Workforce and the contractor has been successful. Market research found no alternatives or competitors without causing significant delays and user impact due to technology, integration, security, and schedule risks – Ref. Acquisition Plan, Section 7: Risks. Unison provides access to a diverse staff of highly regarded former officials from both defense and civilian agencies. There are no VAO resellers or other vendors that provide extensive toolkits for 1102s, CORs, and PMs. Unison developed and designed the AKP on SAC Contract GS-35F-131GA 36C10X19F0089 and the intent of this contract will further align those requirements. Unison piloted several tools (Market Research Assistant, Navigator, and now RFI Assistant) over the years. VA users will not be able to access these capabilities without a current subscription service. Acquisition workforce user impact could be significant if they were to lose the AKP maintenance services coupled with the VAO subscriptions because they are integrated into the AKP tiles. As Unison developed the AKP under the initial VAO contract (GS-35F- 131GA 36C10X19F0089), it is considered within scope to award both requirements together (VAO Subscriptions + AKP Portal and Maintenance). As documented above, market research has shown that Unison has no Small Business reseller that can provide the requirement.

(5) A determination by the ordering activity contracting officer that the order represents the best value consistent with GSAM 538.7102-2 and .

Pursuant to GSAM 538.7102-2(d) GSA has already determined that the items on the contractors FSS are contract level prices of supplies and fixed price services, and rates for services offered at hourly rates, under schedule contracts to be fair and reasonable. For FSS items/services the CO is not required to make a separate determination of fair and reasonable pricing. For all open market items, a fair and reasonable price determination shall be made by the CO.

By placing an order against a schedule contract using the procedures in GSAM 538.7103, the CO has concluded that the order represents the best value (as defined in FAR 2.101) and results in the lowest overall cost alternative (considering price, special features, administrative costs, etc.) The CO will seek further price discounts in accordance with GSAM 538.7102-2(c)(2).

The Contracting Officer will perform a thorough price analysis to ensure a fair and reasonable price. Price analysis may include, but is not limited to comparison with historical pricing, commercial pricing, GSA pricing, other Government vehicle pricing and the Independent Government Cost Estimate.

(6) A description of the market research conducted among schedule holders and the results or a statement of the reason market research was not conducted.

Market research was conducted via a search of GSA, SAM.gov and Federal Procurement Data. The market research revealed that no other company has the capability to provide these specific subscription services or maintain the current AKP tools near the extent that the Unison can or already does. Additionally, there are no resellers on GSA for the VAO annual licensing fee. the justification will be made public per GSAM 538.7104-3(b)(3)(i) Justifications must be made publicly available within 14 days after award; and (ii)(C) For a minimum of 30 days.

(7) Any other facts supporting the justification.

There are no additional facts to be reported in this section.

(8) A statement of the actions, if any, the agency may take to remove or overcome any barriers that led to the restricted consideration before any subsequent acquisition for the supplies or services is made.

FAM-C/COR will continue to conduct market research to determine if other vendors have entered the marketplace; however, at this time our market research found that there is no other vendor to provide the same innovative solution as Unison.

(9) Evidence that any supporting data that is the responsibility of technical or requirements personnel (e.g., verifying the Government ’s minimum needs or requirements or other rationale for limited sources) and which form a basis for the justification have been certified as complete and accurate by the technical or requirements personnel.

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.

Signature: _________________________________ Date: ____________

[REDACTED]

Associate Executive Director/Director Office of Acquisition and Logistics

(10) The ordering activity contracting officer ’s certification that the justification is accurate and complete to the best of the contracting officer ’s knowledge and belief.

I certify that this justification is accurate and complete to the best of my knowledge and belief.

Contracting Officer Enterprise Procurement Office

(11) For justifications under GSAM 538.7104-3(b), a written determination by the approving official identifying the circumstance that applies.

See 4 above.

For acquisitions over $900K not exceeding $20M

Approval

In my role as Contracting Activity Competition Advocate, based on the foregoing justification, I hereby approve this acquisition on an “other than full and open competition” basis pursuant to the statutory authority cited in paragraph four above, subject to availability of funds, and provided that the property and services herein described have otherwise been authorized for acquisition. As this action does not exceed $15M, the certification below required by FAR 8.405-6(d)(2) serves as approval.

Procuring Activity Advocate for Competition

Enterprise Procurement Office