4d_Simplified Acquisition Procedures (SAP)- M365 2026- resigned.pdf
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- Attached to
- MS 365 SUBSCRIPTION
- Solicitation number
- 70Z03926PCGA00037
About this file
This is a U.S. Coast Guard Justification for Other Than Full and Open Competition for commercial products and services at or below the Simplified Acquisition Threshold (SAT). The document justifies a single-source procurement for Microsoft software licensing required by the U.S. Coast Guard Academy's educational IT environment, valued at $106,276.58 under Purchase Request Number 60100PR260036629.
The Coast Guard is procuring Microsoft 365 licensing, server licensing, and associated software to support academic instruction, administrative operations, and enterprise IT services at the Academy. The suggested vendor is SHI International Corp (UEI: CEFCD41CLDJ8) located in Somerset, NJ. The justification cites that Microsoft 365 Education licensing for eligible academic institutions is administered through Microsoft's education licensing program and made available via the NERCOMP consortium agreement, which establishes standardized licensing terms and eligibility-based provisions unavailable through other channels. Alternative Microsoft licensing channels do not provide equivalent education-specific terms or eligibility-based discounts. The contracting officer determined fair and reasonable pricing through comparison of the proposed price with prices found reasonable on previous purchases. The Technical and Requirements Point of Contact and Contracting Officer signed the document on 16 June 2026.
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Last Updated 03/03/2026
U.S. COAST GUARD JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION
COMMERCIAL PRODUCTS AND SERVICES AT OR BELOW THE SAT
FAR 12.102(a), FAR Class Deviation 25-21 Rev. 1 for FAR Part 12 PURCHASE REQUEST OR REQUISITION NUMBER: ESTIMATED TOTAL VALUE, INCLUDING OPTIONS:
(Over Micro-Purchase Threshold, but up to the SAT)
AUTHORITY JUSTIFICATION TYPE
Restricting Competition FAR 12.102(a), FAR Class Deviation 25-21 Rev. 1 for FAR Part 12
☐ Only One Source Is Available (e.g., urgency, exclusive licensing agreements, or industrial mobilization).
☐ Brand Name - Items peculiar to one manufacturer: The particular brand name, product, or feature is essential to the Government’s requirements, and market research indicates other companies’ similar products, or products lacking the particular feature, do not meet, or cannot be modified to meet, the agency’s needs
BRIEF DESCRIPTION OF SUPPLIES OR SERVICES REQUIRED AND THE INTENDED USE:
SUGGESTED SOURCE NAME, ADDRESS, & UNIQUE ENTITY IDENTIFIER (UEI):
RATIONALE FOR JUSTIFICATION TYPE SELECTED ABOVE TO INCLUDE RELEVANT INFORMATION GAINED
THROUGH YOUR MARKET RESEARCH TO SUPPORT THE JUSTIFICATION TYPE:
Statements like "Only known source" or "Only source which can meet the required delivery date" are inadequate, and marketing language like
“This company has made its mark,” “This company is recognized as industry’s best,” and “This company is the leader in…” is unacceptable.
CONTRACTING OFFICER - FAIR AND REASONABLE PRICE DETERMINATION METHODS:
☐ MARKET RESEARCH
☐ COMPARISON OF PROPOSED PRICE WITH PRICES FOUND REASONABLE ON PREVIOUS PURCHASES
☐ CURRENT PRICE LIST
☐ COMPARISON WITH SIMILAR ITEMS IN A RELATED INDUSTRY
☐ COMPARISON TO IGCE
☐ CONTRACTING OFFICER’S PERSONAL KNOWLEDGE (EXPLAIN)
☐ OTHER (EXPLAIN)
SIGNATURE AND TITLE OF TECHNICAL AND REQUIREMENTS POC DATE
SIGNATURE OF CONTRACTING OFFICER DATE
https://www.acquisition.gov/far-overhaul/far-part-deviation-guide/far-overhaul-part-12#FAR_12_102 https://www.acquisition.gov/far-overhaul/far-part-deviation-guide/far-overhaul-part-12#FAR_12_102
| PURCHASE REQUEST OR REQUISITION NUMBER: 60100PR260036629 |
| ESTIMATED TOTAL VALUE INCLUDING OPTIONS Over MicroPurchase Threshold but up to the SAT: $106,276.58 |
| Restricting Competition FAR 12102a FAR Class Deviation 2521 Rev 1 for FAR Part 12: |
| Only One Source Is Available eg urgency exclusive licensing: On |
| Brand Name Items peculiar to one manufacturer The particular brand: Off |
| BRIEF DESCRIPTION OF SUPPLIES OR SERVICES REQUIRED AND THE INTENDED USE: Microsoft software licensing for the U.S. Coast Guard Academy’s educational IT environment, including Microsoft 365, server licensing, and associated software required to support academic instruction, administrative operations, and enterprise IT services. |
| SUGGESTED SOURCE NAME ADDRESS UNIQUE ENTITY IDENTIFIER UEI: SHI International Corp290 Davidson Avenue, Suite 101Somerset, NJ 08873-4145UEI: CEFCD41CLDJ8 |
| RATIONALE FOR JUSTIFICATION TYPE SELECTED ABOVE TO INCLUDE RELEVANT INFORMATION GAINED THROUGH YOUR MARKET RESEARCH TO SUPPORT THE JUSTIFICATION TYPE Statements like Only known source or Only source which can meet the required delivery date are inadequate and marketing language like This company has made its mark This company is recognized as industrys best and This company is the leader in is unacceptable: Microsoft 365 Education licensing for eligible academic institutions is administered through Microsoft’s education licensing program and made available via the NERCOMP consortium agreement, which establishes standardized licensing terms, conditions, and eligibility requirements for member institutions. These education-specific licensing provisions are fulfilled through authorized resellers designated under the agreement, including SHI International Corp. Alternative Microsoft licensing channels do not provide access to these same education program terms or eligibility-based constructs. Accordingly, pursuant to 10 U.S.C. § 3204(a)(1), only one responsible source is capable of fulfilling the Government’s requirement under the applicable Microsoft education licensing framework. | |
| MARKET RESEARCH: | |
| CURRENT PRICE LIST: | |
| COMPARISON WITH SIMILAR ITEMS IN A RELATED INDUSTRY: | |
| COMPARISON TO IGCE: | |
| CONTRACTING OFFICERS PERSONAL KNOWLEDGE EXPLAIN: | |
| OTHER EXPLAIN: | |
| SIGNATURE AND TITLE OF TECHNICAL AND REQUIREMENTS POC: | |
| DATE: 16 June 2026 | |
| SIGNATURE OF CONTRACTING OFFICER: | |
| DATE_2: 16-June-2026 | |
| Check Box1: Off | |
| Check Box2: Yes | |
| Check Box3: Off | |
| Check Box4: Off | |
| Check Box5: Off | |
| Check Box6: Off | |
| Check Box7: Off | |
| 2026-06-16T10:01:39-0400 | |
| HORNUNG.KEVIN.SCOTT.1013660618 |
| 2026-06-16T10:42:57-0400 | |
| DISCENZA.KATHERINE.MARIE.1369009172 |
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