47QPCA25R0001_Justification-SoleSource_2025-06-05.pdf

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Justification for Other than Full and Open Competition (JOFOC)

Login.gov Source Issuer Verification Solution

IAW FAR 6.302-1 Only One Responsible Source Document Format IAW FAR 6.303-2

1. Identification of the Agency and Contracting Activity U.S. General Services Administration (GSA) Federal Acquisition Service (FAS) Technology Transformation Services (TTS), Acquisition Division (AcqDiv) 1800 F Street NW Washington, DC 20405

2. Nature and/or Description of the Action Being Approved Pursuant to Federal Acquisition Regulation (FAR) 6.302-1, TTS is seeking approval for contracting without providing for full and open competition under the circumstance of Only One Responsible Source.

3. Description of the supplies/services required (including estimated value) Login.gov enhances federal digital security by implementing robust authentication and identity proofing mechanisms, while proactively monitoring for potential identity theft to mitigate cyber risks. A key aspect of Login.gov’s authentication approach is utilizing a Source Issuer Verification service to electronically verify U.S.

State-issued Driver’s License (DL) and Identity (ID) card data directly with the custodian of the record in real time at Login.gov’s request. This results in a Government-provided “digital identity” for each user, established at National Institute of Standards and Technology (NIST) 800-63-3 (or its successors) Identity Assurance Levels (IAL) 1 or 2 and Authentication Assurance Level (AAL) 2. The resultant digital identity provides users the ability to sign in with a single set of credentials for all participating Government programs.

The Contractor must provide a Source Issuer Verification Solution that:

● Has the ability to electronically verify U.S. State-issued DL and ID card data directly with the custodian of the record in real time at Login.gov’s request.

JOFOC-FAR 6.302 V1.22.1

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● Has coverage of at least 75% of the U.S. population who have been issued a driver’s license, driver’s permit, or other state ID document.

● Will only verify personal information from Login.gov, it will not retain that PII nor use it for any commercial purposes.

● Meets GSA IT Security Policies.

The estimated cost is $22,578,137.11 for a 12-month base period, and four 12-month option periods. In accordance with FAR 52.217-8, TTS reserves the right to extend the service up to six months if continued service is required.

The contract type is anticipated to be Firm Fixed Unit Price (FFUP). Firm fixed prices will be established on a volume-tiered transactional basis, with ceiling values based on the number of transactions estimated by the Government.

Contractor performance is surveyed through quality control methods and cost risk managed through the Firm Fixed Unit Price (FFUP) contract structure. This will be a consumption model, where the Government will only pay for the transactions that it consumes at fixed unit prices. The contractor is not authorized to exceed the ceiling price. The contractor exceeds the ceiling price at its own risk.

4. Statutory Authority permitting other than full & open competition FAR 6.302-1 Only one responsible source and no other supplies or services will satisfy agency requirements, states, in relevant part:

“When the supplies or services required by the agency are available from only one responsible source, or, for DoD, NASA, and the Coast Guard, from only one or a limited number of responsible sources, and no other type of supplies or services will satisfy agency requirements, full and open competition need not be provided for.”

5. A demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited Per the authority cited, when the supplies or services required by the agency are available from only one responsible source, ...and no other type of supplies or services will satisfy agency requirements, full and open competition need not be provided for.

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When a motor vehicle agency issues an identification, they can verify its authenticity as the source issuer of the document (i.e., the custodian of record). Login.gov requires direct access to custodians of record to reduce the risk of fraud and comply with federal digital identity guidelines in NIST SP 800-63-3.

Most motor vehicle agencies don't provide a verification service for their issued identifications to private, commercial, or non-law enforcement entities. To address this gap, the American Association of Motor Vehicle Administrators (AAMVA) offers a Driver's License Data Verification (DLDV) service that provides direct electronic verification; connecting industry and motor vehicle agencies in real-time for immediate identity verification.

AAMVA has agreements with numerous states and jurisdictions (~44). No other source is available/interested that offers direct access to custodian of record data at the coverage required under this contemplated contract. Therefore, AAMVA remains the only provider capable of satisfying the Government's requirement.

6. A description of efforts made to ensure that offers are solicited from as many potential sources as is practicable, including whether a notice was or will be publicized as required by subpart 5.2 and, if not, which exception under

5.202 applies.

AAMVA is the only contractor available to perform the required services. This justification will be posted to sam.gov for a period of 30 days in accordance with FAR 6.305. Upon the post’s closing, and no other indication of capability amongst industry, an offer will only be solicited directly from AAMVA.

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7. A determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable.

The CO anticipates the cost to the Government will be fair and reasonable in consideration of the following factors:

1) Historical prices-paid data is available that will be utilized in establishing fair and reasonable pricing.

2) The Government will be seeking discounted pricing on the price submission to ensure we are receiving fair and reasonable pricing.

3) The Government will review other identity verification pricing information, as applicable, to support price analysis and determination.

8. A description of the market research conducted (see part

10) and the results or a statement of the reason market research was not conducted.

The following methods were utilized to conduct market research (in accordance with FAR 10.002(b)(2)):

● (i) Contacting knowledgeable individuals in Government and industry regarding market capabilities to meet requirements.

○ GSA corresponded with the National Law Enforcement Telecommunications System (NLETS) to determine if they offered a potential solution. This correspondence was unsuccessful as NLETS was nonresponsive and unable/unwilling to indicate whether their solution was an option for fulfilling this requirement.

○ GSA corresponded with AAMVA about its response to the RFI (detailed later). The purpose of this correspondence was to clarify aspects of AAMVA's capabilities with respect to the requirements of this contemplated contract.

● (ii) Reviewing the results of recent market research undertaken to meet similar or identical requirements.

○ Based on previous market research for the last acquisition of this requirement, which built off of market research from the initial acquisition, there are only two organizations that have direct access to large amounts of motor vehicle agency data (coverage of more than 50% of U.S Population) - NLETS and AAMVA.

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Both of these organizations are non-profits that have state officials directly involved as executive leadership and on the board of directors.

This leadership structure and direct input on operations, funding, and other key decisions have enabled these organizations to build trusted relationships with the States; something that for profit companies have been unable to emulate. A subset of states directly sell information from their motor vehicle agencies, but only these two sources have access to the states that don’t directly sell the information. Changes to this structure would require statutory changes to state laws and/or direct relationships with each state.

AAMVA and NLETS provide the same information needed for Login.gov’s identity verification and authentication needs. While NLETS allows access to data from nearly all 50 states, AAMVA only provides access to 44. However, NLETS also provides additional information on users that may come with added security risk.

Acquisition teams for both of the previous acquisitions corresponded with NLETS to determine if it had a potential solution. In both cases, NLETS advised that this requirement was outside their core mission of public safety and would not be interested in responding to any resultant solicitation.

● iii) Publishing formal requests for information in appropriate technical or scientific journals or business publications.

○ TTS issued an RFI on 03/05/2025 via sam.gov that closed on 03/21/2025. It received one respondent indicating it’s capable of fulfilling the requirement: AAMVA the incumbent other-than-small business.

○ Login.gov technical personnel reviewed AAMVA’s response and determined it's capable of this opportunity. A technical evaluation for acceptability will be conducted prior to award to officially determine if the contractor’s proposed solution for this requirement is acceptable to the Government.

● (v) Participating in interactive, on-line communication among industry, acquisition personnel, and customers.

○ See paragraph (i) above.

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● (vi) Obtaining source lists of similar items from other contracting activities or agencies, trade associations or other sources.

○ Searches via GSA Advantage for ‘driver’s license verification/validation’ and ‘identity card verification/validation’ were unsuccessful in obtaining any results and concluded that the requirements can’t be satisfied through the uses of the other sources prescribed by FAR 8.004.

The conclusion of these activities was that AAMVA provides the only comprehensive solution to meet the organization’s needs and that it is in the best interest of the Government to pursue a sole-source contract directly to AAMVA .

9. Any other facts supporting the use of other than full and open competition, such as:

All facts are detailed under the corresponding section herein.

10. A listing of the sources, if any, that expressed, in writing, an interest in the acquisition.

TTS issued an RFI on 03/05/2025 via sam.gov that closed on 03/21/2025. It received one respondent indicating it’s capable of fulfilling the requirement: AAMVA the incumbent other-than-small business.

11. A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition for the supplies or services required.

Given the nature of the requirement and the anticipated source, no modifications to the requirement that would enhance competition are possible at this time. TTS understands the need to continue to monitor the market for these services on any re-procurements or future requirements of a similar nature, and anticipates continuous monitoring throughout performance. TTS project teams will continue to perform market research on available alternatives, aiming to increase competition in accordance with FAR 6.303-2.

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12. Contracting officer certification that the justification is accurate and complete to the best of the contracting officer’s knowledge and belief.

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

Jonah Jordan, Contracting Officer

GSA/FAS/TTS

Date

Technical/requirements certification I certify that the supporting data provided, which form the basis for this justification, are complete and accurate to the best of my knowledge and belief.

Dustin Spiehler, Acquisition Project Manager

GSA/FAS/TTS

Approvals (remove signature line if not applicable)

Jackie Xu, Competition Advocate

GSA/FAS/TTS

Thomas Shedd, Head of Contracting Activity

GSA/FAS/TTS

Docusign Envelope ID: D7D222E3-3C84-4D82-8E2E-C7E34A199954

5/27/2025

5/27/2025

Docusign Envelope ID: B2C04FF0-4CB0-4BC3-91F1-E52D425AF37C

6/2/2025

6/5/2025

Approvals (remove signature line if not applicable)