47QFDA26Q0005_Justification_ServiceNowRedacted_2026-01-28.pdf

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ServiceNow Licensing
Solicitation number
47QFDA26Q0005
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This is a Justification for Sole Source Procurement document for a ServiceNow software licensing order under GSA's Assisted Acquisition Services (AAS). The solicitation number is 47QFDA26Q0005, issued in support of the Department of Health and Human Services (HHS) Office of the Inspector General (OIG) under Interagency Agreement 47QFWA21S0013. The contracting officer is Derrick Wade. The procurement utilizes GSA's 2nd Generation Information Technology (2GIT) Blank Purchase Agreement (BPA) 7QTCA21A000R with Carahsoft Technology Corporation as the sole authorized reseller/distributor. This is a follow-on to the previous ServiceNow Licenses order 47QFWA22F0003 awarded on December 15, 2021. The government requires ServiceNow licenses to support approximately 1,900 users (including 300 contractors) across 81 HHS OIG offices located in the Continental United States (CONUS) and outside the Continental United States (OCONUS) locations, with on-site field support provided by Carahsoft Technologies as needed.

The justification for sole source procurement rests on two primary grounds: (1) only Carahsoft Technology holds the Letter of Supply authorization as the sole reseller of ServiceNow software under GSA's Federal Supply Schedule, and (2) ServiceNow represents a brand-name item unique to one manufacturer, with the proprietary software already fully integrated into HHS OIG's existing IT infrastructure supporting 24-hour service desk operations. The justification cites an urgent and compelling need to maintain service continuity and avoid disruption to critical infrastructure capabilities including Demand Management, Automated Discovery, Cloud Management, Asset Management, Change and Release Management, and Project and Portfolio Management. Market research identified 177 small businesses with ServiceNow capabilities in the SBA Dynamic Small Business Search database; however, Carahsoft was determined to be the only viable source for the required licenses. The procurement was signed and approved on January 13, 2026, with pricing quotes to be requested from Carahsoft under Special Item Number 54151S, subject to price reasonableness review and best value determination.

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JUSTIFICATION

DESCRIPTION OF ACTION

SOLE SOURCE

Solicitation 47QFDA26Q0005

ServiceNow Licenses in support of:

Department of Health and Human Services

(HHS)

Office of The Inspector General (OIG)

United States (U.S.) General Services Administration (GSA) Federal Acquisition Service (FAS)

Assisted Acquisition Services (AAS) Civilian

Interagency Agreement Number 47QFWA21S0013

Controlled by AAS Contracting Officer Derrick Wade: derrick.wade@gsa.gov

The General Services Administration (GSA) Assisted Acquisition Services (AAS) makes this Justification for orders pursuant to the General Service Administration Manual/Regulation 538 Deviation.

i.) Identification of Agency and Contracting Activity:

Agency:

GSA AAS acting in support of Health and Human Services (HHS) Office of the Inspector General (OIG)

Contracting Activity:

GSA AAS Contracting Office (QFDA) 1800 F Street, NW

Washington, D.C. 20405 ii.) Nature and/or Description of Action Being Approved:

The purpose of this Justification is to support the solicitation and contemplated award of a Firm Fixed Price (FFP) order for a sole source and brand-name justification for ServiceNow software licenses / products via GSA’s Multiple Award Schedule’s (MAS) 2nd

Generation Information Technology (2GIT) Blank Purchase Agreement (BPA).

This Justification is being provided in accordance with Federal Acquisition Regulation (FAR) 8 and GSAM 538.7104-3:

“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”

● Carahsoft Technology is currently the only authorized reseller / distributor with a Letter of Supply for ServiceNow software under the GSA Federal Supply Schedule program. The HHS/OIG Service Desk operates solely on ServiceNow® software and provides twenty-four (24) hour a day support to over 1,600 personnel. All processes supporting these operations are based on ServiceNow® modules. In order to ensure continuity within HHS’ IT ecosystem, ServiceNow® must be reprocured in order to maintain continuity of service and avoid any potential disruption to HHS’s user support.

● A brand name item, whether available on one or more schedule contracts, is an item peculiar to one manufacturer. The Service Now offerings meet the definition of a “brand name item” as required by the citation, and its ServiceNow offerings are only distributed through Carahsoft Technologies, the sole authorized reseller/distributor. ServiceNow provides critical infrastructure capabilities such as Demand Management, Automated Discovery, Cloud Management, Asset Management, Change and Release Management, Project and Portfolio Management, as well as several others, to support HHS/OIG business and IT support processes. The software modules provide over thirty (30) integrated information technology (IT) support capabilities based upon commercial best practices.

This requirement is a follow-on to the 47QFWA22F0003 ServiceNow Licenses order awarded by GSA on 12/15/2021.

with an estimated value of

After careful consideration of the client’s requirements and review of GSA/FAS/AAS selected the 2GIT BPA 7QTCA21A000R as the best alternative to meet the Government’s needs.

iii.) A Complete Description of Supplies/Services Required to Meet Agency’s Need (Including the Estimated Value):

HHS OIG OCIO has an immediate need for ServiceNow Licenses. These licenses shall be provided at HHS OIG sites to support approximately 1,900 users (including 300 contractors) at 81 offices throughout the Continental United States (CONUS) and the Outside the Continental United States (OCONUS) locations. In addition, Carahsoft Technologies shall provide on-site field support as required at CONUS and OCONUS locations as specified by HHS OIG. The brand name ServiceNow platform is for software licenses and product maintenance. With the ServiceNow platform being utilized, only ServiceNow licenses can be integrated for use due to the propriety and incompatibility of

The total estimated value of the The Period of Performance for in the solicitation (RFQ) and associated with the award are brand-name items.

iv.) The Authority and Supporting Rationale:

a. __X__ An urgent and compelling need exists, and following GSAM 538.7103 competitive ordering procedures would result in unacceptable delays.

b. _X_ Only one source, Carahsoft Technologies, is capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized. The existing vendor, Carahsoft Technologies, was identified as the only source able to fulfil the Government’s requirement in this timeframe. Any subcontracting competition and/or limitation requirements have already been addressed at either the MAS Contract and/or 2GIT BPA level, but subcontracting is not anticipated for this requirement. The Government intends to award a sole source contract to Carahsoft Technologies. This determination is based on current market research and acquisition history indicating that Carahsoft Technologies is the only authorized Government reseller capable of providing all the required ServiceNow products HHS OIG.

c. ____ In the interest of economy and efficiency, the new work is a logical follow-on to an original Federal Supply Schedule order provided that the original order was placed in accordance with the applicable Federal Supply Schedule ordering procedures. The original order or BPA must not have been previously issued under sole-source or limited-sources procedures.

d. __X__ An item peculiar to one manufacturer, ServiceNow, is a particular brand name, product, or a feature of a product. A brand name item, whether available on one or more schedule contracts, is an item peculiar to one manufacturer. This procurement will be conducted in accordance with GSAM 538.7104-3 and GSAM 538.7104-3(b)(ii) because a reasonable expectation of receiving multiple quotes for price comparison does not exist, and Carahsoft Technologies is uniquely or highly specialized as the single source capable of meeting the required level of quality. The planned acquisition strategy is to use the GSA 2nd Generation Information Technology (2GIT) BPA.

v.) Determination by the Ordering Activity Contracting Officer that the Order Represents the Best Value Consistent with FAR 8 and 538:

A best value determination will be documented. Prior to placing the order, the Contracting Officer will seek price discounts (in accordance with GSAM 538.7102-2(c)(2))from Carahsoft Technologies under Special Item Number (SIN) 54151S, quoting the required ServiceNow part numbers listed above. The quote will be reviewed to ensure that pricing and terms are IAW the quoter's Multiple Award Schedule (MAS) contract.

The Request for Quotation (RFQ) will be released to Carahsoft Technologies, the single authorized ServiceNow vendor,. A price reasonableness determination will be documented to include any "open market" items.

The sole source justification will be posted in accordance with GSAM 538 deviation, which includes GSAM 538.7104-3(b)(3).

vi.) Description of the Market Research Conducted Among Schedule Holders and the Results of the Research:

The market research efforts consisted of various methods that are generally accepted or mandatory under the FAR. The market research process for this acquisition included the following:

. Determining the need for the services being procured.

. Reviewing available information from:

1. Interagency Contract Directory (ICD).

2. Small Business Administration’s (SBA) Dynamic Small Business

Search (DSBS) database.

3. GSA’s Acquisition Category Management Tool.

a. Reviewing existing sources, including the GSA vehicles.

Each GWAC: (Alliant 2, 8(a) Streamlined Technology Acquisition Resource for Services (STARS) III, One Acquisition Solution for Integrated Services (OASIS) One Acquisition Solution for Integrated Services (OASIS) was evaluated and considered based on feasibility, relevancy, and applicability.

An inspection of the ICD revealed several BPAs which supplied these services; however, many were limited to outside the agency. Of the BPAs, 47QTCA21A000R was one which both supplied the services matching the government’s requirement and was available for use by GSA - with an awardee to an other than small business.

The SBA DSBS indicated on a cursory search for "ServiceNow" 177 small businesses which had ServiceNow within their profile.

Small businesses were evaluated to determine if there were a sufficient number of small businesses capable of performing work for this acquisition as a prime contractor. Initial evaluation of the data gathered from the DSBS indicated small business may be a feasible alternative, however, additional research revealed that Carahsoft Technologies, an other than small business, was the only source for the ServiceNow Licenses. As such, a small business set-aside was not a feasible acquisition alternative.

vii.) Any Other Facts Supporting the Justification:

Utilization of the GSA 2GIT BPA, a Best in Class (BIC) BPA solution, for this order award will also benefit GSA as well as HHS through the BPA’s incorporation of enhanced National Institutes of Standards and Technology (NIST) based Supply Chain Risk

Management (SCRM) requirements and operational controls that significantly improve secure supply chains.

All factors supporting Justification are described under Section iv. and v. above.

viii.) 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:

Previous market research showed there were 17 vendors interested in providing ServiceNow. Currently, only Carasoft Technologies is a resellers of ServiceNow.

The acquisition activity will continue to conduct market research to determine if other software subscriptions are viable alternatives. The ServiceNow licenses, being sourced through Carahsoft Technologies, are deemed the only technically viable option for this requirement because it is already integrated with the HHS OIG IT infrastructure. No other alternative software was found to be technically viable. As this Justification entails items peculiar to one manufacturer and is required to be posted with the solicitation via GSA eBuy.

ix.) Contracting Officer Certification that the Justification is Accurate and Complete to the Best of the Contracting Officer’s Knowledge and Belief:

I hereby certify that this Justification is accurate and complete to the best of my knowledge, and I determine on the basis of the findings above that the limited sources approach is in accordance with the requirements and is in the best interest of the Government.

Derrick A. Wade Date Contracting Officer, AAS Civilian Assisted Acquisition Services

Technical and Requirements Personnel Assertion:

Date

Technical Point of Contact (TPOC) Department of Health & Human Services

Concurrence

Acquisition Branch Chief, APEX 3 (Civilian), Sector 5 Date Assisted Acquisition Services Reviewed by Branch Chief

Program Director, APEX 3 (Civilian), Sector 5 Date

Concurred by Program Division Director

Final Approval:

I certify that this justification is accurate and complete to the best of my knowledge and belief, and I determine on the basis of the findings above that an other than full and open competition approach is in accordance with the requirements and is in the best interest of the Government.

Contracting Director, APEX 3 (Civilian), Sector 5 Date

Approved by Acquisition Division Director

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