47QACA26Q0357_Sole Source_Brand Name Justification (FSS) Redacted v2_07-08-2026.pdf

Sole Source/Brand Name Justification (FSS)

Authority: RFO-2025-FSS-GSAR 538.7104-3 and 538.7104-4

1. Identification of Agency and Activity

● Requesting Agency: Pension Benefit Guaranty Corporation (PBGC) 445 12th Street, SW Washington, DC, 20024-2101

● Contracting Activity: General Services Administration (GSA) Federal Acquisition Service (FAS) Office of Centralized Acquisition Services (OCAS) 77 Forsyth Street, SW Atlanta, GA 30303

● Compliance Statement: This justification is executed pursuant to the requirements for documenting exceptions to fair opportunity under the Federal Supply Schedule (FSS) program as prescribed in RFO-2025-FSS-GSAR 538.7104-3.

2. Description of Action

● Action Type: This is to procure Acquia Cloud Platform Web Content Management System software licensing and website hosting on a FedRAMP certified host. See separately attached Bill of Materials (BOM) for full descriptions, specifications, part numbers, and quantities. The items will be procured on a Firm-Fixed Price basis.

● Estimated Value:

Base Period: 09/30/2026 – 09/29/2027:

Option Year One: 09/30/2027 – 09/29/2028:

Option Year Two: 09/30/2028 – 09/29/2029:

Option Year Three: 09/30/2029 – 09/29/2030:

Option Year Four: 09/30/2030 – 09/29/2031:

● Statutory Basis: This acquisition is conducted under the authority of the Multiple

Award Schedule (MAS) Program, which constitutes a competitive procedure under 41 U.S.C. 152(3) and RFO-2025-FSS-GSAR 538.7102-1(a).

3. Performance Outcome & Requirement

● Requirement:

Version 3/12/2026

c. PBGC would also have to separately procure and integrate hosting, support services, and development tools – adding cost and triggering a new, extended ATO process.

2. (as a hosting foundation for Drupal)

a. is FedRAMP authorized, but it does not provide a Drupal platform or Drupal enterprise support.

b. PBGC would need to build and maintain the entire CMS layer, pipelines, integration tools, and technical architecture.

c. This approach significantly increases implementation cost, cybersecurity risk, and ATO timelines.

3. Other and , are not Drupal-based and therefore do not meet PBGC’s requirement for a Drupal-native system.

4. Impact of using non-Acquia alternatives would result in the following:

a. Additional development and integration would be required to assemble the platform.

b. A new security Authority to Operate (ATO) would be required, resulting in extended security review timelines.

c. Costs would increase due to multiple vendors and integration needs.

d. Cybersecurity and operational risks would increase due to the use of separate and unaligned components.

e. PBGC.gov operations could be disrupted—unacceptable for a mission-critical, public-facing site.

5. Based on the above, these impacts are consistent with market research findings, which states that alternatives “would result in substantial duplication of cost, increased cybersecurity and operational risk, and unacceptable delays to PBGC’s mission-critical public web operations.

Furthermore, PBGC has been utilizing the Acquia WCMS to manage and administer the PBGC.gov website

In conclusion, Acquia remains the only vendor identified that meets all PBGC requirements for a fully integrated, Drupal-native, FedRAMP-authorized hosting and CMS platform with the necessary development tools and enterprise support.

All alternative solutions would require PBGC to procure and integrate multiple

Version 3/12/2026 components, initiate new development efforts, undergo additional security authorization, and assume increased risk and cost. These delays and burdens would negatively affect PBGC’s ability to deliver reliable public web services.

● Statutory Exception (Exceeding SAT): Per RFO-2025-FSS-GSAR 538.7104- 3(b)(1), the specific authority for this action is:

○ Unique/Specialized: Only one source is capable of providing the requirement at the level of quality required because the products or services are unique or highly specialized [Citation: RFO-2025-FSS- GSAR 538.7104-3(b)(1)(ii)].

4. Rationale for Brand Name or Sole Source

● Brand Name Justification: An item peculiar to one manufacturer includes a particular brand name, product, or feature peculiar to one manufacturer as defined in RFO-2025-FSS-GSAR 538.7104-4(a).

5. Best Value and Pricing

● Baseline Fair and Reasonable: Ordering activities are not required to make a fair and reasonable price determination for FSS products, services, or solutions at the order level or BPA level as FSS contract pricing has been determined fair and reasonable per RFO-2025-FSS-GSAR 538.7102-2(d)(2).

6. Future Competition

● Barriers: Actions to remove or overcome barriers to competition for future acquisitions of these supplies or services are documented here as required by RFO-2025-FSS-GSAR 538.7104-3(c)(2)(vi).