A.3 FAR 12 J&A For Use of Other Than Full and Open Competition FAR 12 - Microsoft 365 - REDACTED.pdf

UNITED STATES MARINE CORPS

MARINE CORPS INSTALLATIONS NATIONAL CAPITAL REGION

MARINE CORPS BASE QUANTICO

3250 CATLIN AVENUE

QUANTICO, VIRGINIA 22134-5001

DISTRIBUTION: U/GENERAL

MEMORANDUM TO THE FILE

Subj: For Use of Other Than Full and Open Competition FAR 12 – Commercial Products and Commercial Services Under the Simplified Acquisition Threshold (SAT)

1. Contracting Activity

The Contracting Activity is the Marine Corps Installations National Capital Region – Regional Contracting Office (MCINCR-RCO), located at 2010 Henderson Road, MCB Quantico, VA. The requiring activity is Marine Corps University (MCU), located at MCB Quantico, VA 22134.

2. Description of Action Being Approved

The action being approved is the use of an exception to fair opportunity to fulfill a brand-name requirement for follow-on software support and maintenance for one-thousand two-hundred fifty (1,250) Microsoft 365 A5 Faulty License, twenty (20) Microsoft Planner, Project Plan 3, thirty (30) Visio Plan 2, twenty-five (25) Defender for Business License, sixty (60) Microsoft Power Automate Premium annual licensing and fifty-thousand (50,000) Microsoft 365 Student Use License. These products constitute a commercial suite of office and enterprise applications—including Outlook, Word, Excel, PowerPoint, OneNote, Publisher, and Access—acquired under FAR 12.201-1, which authorizes simplified procedures for commercial products and commercial services below the SAT.

This action is intended to result in a brand-name award to a source capable of providing the required Microsoft software support and maintenance through a competitive posting on SAM.gov.

3. Description of Supplies/Services

The Marine Corps University (MCU) requires the procurement of one-thousand two-hundred fifty (1,250) Microsoft 365 A5 Faculty Licenses, twenty (20) Microsoft Planner/Project Plan 3 licenses, thirty (30) Visio Plan 2 licenses, twenty-five (25) Defender for Business licenses, sixty (60) Microsoft Power Automate Premium annual licenses, and fifty-thousand (50,000) Microsoft 365 Student Use Licenses.

Microsoft 365 A5 provides a comprehensive suite of enterprise-grade applications—including Outlook, Word, Excel, PowerPoint, OneNote, Publisher, and Access—along with integrated cloud services such as Exchange, OneDrive, SharePoint, Teams, Planner, Sway, Forms, Stream, and Power Automate. The A5 suite delivers seamless, secure, and device-agnostic access for both faculty and students while providing advanced threat protection, compliance capabilities, and centralized management tools essential to MCU’s academic and operational mission.

The Government intends to issue a single Firm-Fixed-Price (FFP) order with fixed-price CLINs under an open-market contract vehicle. The required base delivery/performance start date is within 60 days after date of award. The estimated cost for this procurement is $176,932.00. Marine Corps Operations and Maintenance (O&M) appropriations will fund the twelve-month period of performance as outlined in the table below:

FY26 Total Period O&M

Base Period

Brand Name / Manufacturer

Item Name / Description Manufacturer Part Number

Quantity Unit Price Extended Price

Microsoft Microsoft 365 A5 (Education Faculty Pricing)

CFQ7TTC0LHPJ:0015 1,250

Microsoft Microsoft 365 A5 Student use benefit (Education Student Pricing)

CFQ7TTC0LHP8:0005 50,000

Microsoft Planner and Project Plan 3 for Faculty (Education Faculty Pricing)

CFQ7TTC0HDB0:000X 20

Microsoft Visio Plan 2 (Education Faculty Pricing)

CFQ7TTC0HD32:0012 30

Microsoft M365 Defender for Business CFQ7TTC0HX56:0002 25 Microsoft M365 Power Automate Premium CFQ7TTC0LSGZ:0001 60 Microsoft Microsoft Power Apps Premium-

Education Faculty Pricing

CFQ7TTC0LH2H:0013 50

4. Statutory Authority Permitting Other Than Full and Open Competition

This acquisition is conducted under FAR 12.201-1, which authorizes the use of simplified procedures for commercial products and commercial services below the Simplified Acquisition Threshold (SAT).

Limiting competition for this brand-name requirement is authorized under 10 U.S.C. 3204(a)(1), When Procedures Other Than Competitive Procedures May Be Used.-The head of an agency may use procedures other than competitive procedures only when (1) the property or services needed by the agency are available from only one responsible source or only from a limited number of responsible sources and no other type of property or services will satisfy the needs of the agency.

5. Rationale Justifying Use of the Cited Authority

The Marine Corps University (MCU) has a brand-name requirement for one-thousand two-hundred fifty (1,250) Microsoft 365 A5 Faculty Licenses; twenty (20) Microsoft Planner/Project Plan 3 licenses; thirty

(30) Visio Plan 2 licenses; twenty-five (25) Defender for Business licenses; sixty (60) Microsoft Power Automate Premium annual licenses; and fifty-thousand (50,000) Microsoft 365 Student Use Licenses.

Microsoft 365 A5 is the most comprehensive offering in the Microsoft Education suite, providing advanced security, compliance, analytics, and collaboration capabilities not available in lower-tier plans.

The A5 suite includes the full range of Microsoft Office applications—Outlook, Word, Excel, PowerPoint, OneNote, Publisher, and Access—along with enterprise cloud services such as Exchange, OneDrive, SharePoint, Teams, Planner, Sway, Forms, Stream, and Power Automate.

Key A5 features essential to MCU’s mission include:

• Advanced Security: Defender for Endpoint, Defender for Identity, and Microsoft Sentinel provide enterprise-grade protection for sensitive academic and military data.

• Enterprise Compliance: FEDRAMP-aligned controls support Marine Corps cybersecurity and integration requirements.

• Analytics & Insights: Power BI Pro and MyAnalytics enable data-driven decision-making across academic and administrative functions.

• Unified Communications: Phone System and Audio Conferencing support global collaboration for faculty, staff, and students.

• Seamless Integration: Native compatibility across the Marine Corps network and all major device platforms.

• Centralized Management: Intune and Entra ID provide secure identity, device, and application management.

• Global Accessibility: Secure, cloud-based access for distributed student and faculty populations.

• Dedicated Engineering Support: Microsoft provides direct technical expertise and platform-level support unavailable from third-party vendors.

To ensure standardization, interoperability, and security across MCU’s academic environment, a consistent and fully compatible platform is required. Microsoft 365 A5 is the only solution that meets all mission, cybersecurity, and enterprise integration requirements for both faculty and student users. As a result, Microsoft 365 A5 constitutes a valid brand-name requirement for this procurement.

Market research indicates that there are multiple office productivity suites on the market, the below table compares other products and their features to Microsoft 365:

Feature Microsoft 365 Google

Workspace LibreOffice Apple iWork Zoho Office

Collaboration

Strong real-time collaboration with Teams & SharePoint

Excellent real-time editing in Docs, Sheets, Slides

Limited cloud collaboration

Apple ecosystem collaboration

Cloud-based collaboration tools

Security & Compliance

Enterprise-level security, FEDRAMP-certified

Good security, but lacks some enterprise standards

Open-source, security depends on user setup

Secure, but Apple-focused

Secure, but lacks enterprise-level certifications

Integration

Seamless integration across Windows, Mac, and mobile

Well-integrated in Google ecosystem

Works with various platforms but lacks deep integrations

Best for Apple users

Cloud-based but fewer enterprise integrations

Advanced Features

AI-powered tools, Excel macros, Power BI, automation

Basic productivity features, fewer advanced tools

Strong document editing but lacks business intelligence tools

Elegant design-focused tools, but limited features

Good for small businesses, lacks enterprise functionality

Updates & Support

Regular updates, professional support

Frequent updates, basic support

Community-driven support, slower updates

Apple-supported updates, limited customization

Affordable but may lack extensive customer support

Given these critical features, Microsoft Office 365 is essential for meeting the government requirements.

Extensive research confirms that no other products possess the necessary capabilities or the ability to integrate rapidly into existing environments, its reliability, security, and extensive capabilities.

6. Efforts to Obtain Competition

Market research was conducted in accordance with FAR Part 10 to identify all potential sources capable of providing the required Microsoft 365 A5, Project Plan 3, Visio Plan 2, Defender for Business, Power Automate Premium, and Microsoft 365 Student Use licenses. Research efforts included a review of commercial cloud-based productivity and collaboration platforms; comparison of available enterprise licensing suites; examination of GSA, DLA, and commercial catalog offerings; and outreach to authorized Microsoft resellers and cloud solution providers.

This research confirmed that while several productivity suites exist in the commercial marketplace, no alternative product meets the Government’s minimum requirements for security, compliance, interoperability, and enterprise integration. Additionally, only Microsoft and its authorized licensing partners are able to provide the required Microsoft 365 A5 and associated license types in a manner consistent with DoD cybersecurity and enterprise architecture requirements.

Because the estimated value of this procurement is below the Simplified Acquisition Threshold, a synopsis is not required in accordance with FAR 5.202(a)(13).

7. Determination of Fair and Reasonable Cost

The Contracting Officer will determine the anticipated price to be fair and reasonable by comparing the quoted pricing against commercial market data, historical Government purchases, and pricing available from other authorized open-market sources. Because this requirement will be posted on SAM.gov, the Contracting Officer will evaluate all quotes received to ensure pricing reflects current competitive market conditions. If pricing from other commercial vendors demonstrates a more advantageous value to the Government, the Contracting Officer will rely on standard price analysis techniques under FAR Part 12 to ensure the Government obtains the best available price.

8. Actions to Remove Barriers to Future Competition

The Government will reassess market conditions prior to future acquisitions to determine whether alternative solutions can meet Marine Corps cybersecurity, interoperability, and enterprise requirements.

Due to the proprietary nature of Microsoft’s licensing and integration ecosystem, no viable alternatives exist at this time, but this will be reevaluated during follow-on acquisition planning.