A02_FAR_Parts_ 6_And_12_J_Vanguard_10 SEPT_Redacted1.pdf

CUI

JUSTIFICATION REVIEW DOCUMENT

FOR JUSTIFICATION AND APPROVAL

FOR OTHER THAN FULL AND OPEN COMPETITION

Supply/Service:

Authority: 41 U.S.C. 1901 as implemented by RFO FAR 12.201-1

Department of Army Justification and Approval for Other than Full and Open Competition

1a. Requiring Activity: Portfolio Acquisition Executive Agile Sustainment & Ammunition

(PAE AS&A)

1b. Contracting Activity: U.S. Army Contracting Command – Rock Island (ACC-RI), Rock Island Arsenal, Rock Island, IL 61299-8000.

2. Description of Action: Portfolio Acquisition Executive Agile Sustainment & Ammunition (PAE AS&A) requests new, sole-source Firm-Fixed-Price (FFP) with Vanguard XXI, LLC. ACC-RI projects award for 20SEPT26 and will obligate fiscal year 2024, fiscal year 2025 and fiscal year 2026 Procurement, Ammunition, Army (PAA) funds. An acquisition plan is not required because this procurement does not meet the threshold at Revolutionary Federal Acquisition Regulation (FAR) Overhaul (RFO) Defense Federal Acquisition Regulation Supplement (DFARS) 207.103-70(a)(2).

The Government did not compete the requirement prior to this action because this procurement represents the initial acquisition of a comprehensive, customized senior leadership development and military-accredited executive coaching program tailored specifically for PAE AS&A. Therefore, there is no contracting history or prior acquisitions.

3. Description of Supplies/Services: This requirement is for commercial professional development, coaching certification, and mission-readiness organizational performance assessment and facilitation services supporting approximately 100 senior leaders across the newly constituted PAE AS&A enterprise. The requirement does not task any contractor with defining, shaping, or actualizing internal organizational culture. All activities performed under this contract support readiness enhancement through improved leader decision-making, cross-functional coordination, communication effectiveness, and operational synchronization across geographically dispersed command hubs. The contractor’s role is strictly advisory and facilitative, with all strategic determinations and organizational direction retained by Government personnel.

The target senior leadership population comprises O-6/O-5 CSL (Central Selection List) select Program Managers and their civilian deputies, 5 GO/SES (General Officer/Senior Executive Service) leaders, and Division-level Staff Principals. The cohort is distributed across the following geographic hubs:

Picatinny Arsenal, NJ: ~40 senior leaders

Detroit Arsenal, MI: ~40 senior leaders Distributed Sites: ~20 senior leaders split among Huntsville (HSV), Fort Belvoir, Natick, Orlando, and Fort Lee.

The services are to be procured on an FFP basis with an estimated total value (including options) of , to be funded with Procurement, Ammunition, Army (PAA) funds. The IGE contains a certification that the Government independently developed the IGE prior to seeking formal proposals from contractors.

4. Authority Cited:

41 U.S.C. 1901(e)(2), as implemented by RFO FAR 12.102(b), Restricting competition for commercial products and commercial services utilizing simplified procedures.

5. Reason for Authority Cited:

A recent internal assessment identified that outsourcing organizational direction or value-setting presents a significant risk of contractor dependency on inherently governmental functions. Accordingly, the requirement has been revised to ensure the contractor performs only readiness-related assessment, facilitation, synthesis, and advisory support. All decisions concerning organizational priorities, integration strategies, and operational alignment remain exclusively with the Government. The contractor supports a Government-led approach by providing data-driven analysis, technical facilitation, and repeatable processes enabling organic personnel to sustain readiness improvements without contractor reliance.

a. FAR Authority This justification is prepared in accordance with FAR 6.302-1, Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.

b. Unique Qualifications of the Proposed Contractor Vanguard XXI, LLC is the only responsible source capable of meeting PAE AS&A’s specialized requirements for readiness-focused leadership development, certified coaching, and mission-performance assessment facilitation. Vanguard XXI is the sole owner of the Army-validated curriculum approved by U.S. Army G-1 and G-3/5/7 to award the A3B and A4B Professional Development Skill Identifiers (PDSIs). No other commercial vendor possesses the legally protected curriculum, Government-validated mapping, or the authority required to issue these identifiers, which are essential for compliance with Army personnel development policy and for ensuring participation from active-duty military personnel.

c. Proprietary Content and Integration Requirements The contractor’s proprietary curriculum uniquely integrates military, technical, and executive leadership methodologies to address cross-command coordination challenges resulting from the Picatinny–Detroit command merger, strengthening operational cohesion without engaging in prohibited cultural design or value-setting functions. This curriculum uniquely integrates corporate, athletic, and military Special Operations leadership methodologies and is the only solution capable of addressing culture-integration risks associated with the Picatinny–Detroit Command Merger.

Replacement by a non-integrated vendor would require disaggregation of leadership development, coaching certification, and cultural actualization into separate contract vehicles, resulting in fragmented delivery, reduced effectiveness, and operational misalignment across the merged command.

d. Technical and Operational Impact of Alternative Sources Engaging an alternative vendor would require the Government to redevelop a curriculum equivalent to Vanguard XXI’s proprietary program, initiate a new multi-year credentialing review with Army G-1 and G-3/5/7, and manage multiple contract lines for leadership development, coaching certification, and organizational performance improvement activities tied to readiness. This fragmentation would significantly increase administrative burden, degrade mission cohesion, and delay critical readiness objectives required for successful command integration.

e. Cost Rationale and Explanation of Estimate Increase The updated Independent Government Estimate (IGE) of over a 48-month period represents a complete and accurate scoping of the multi-site, readiness-driven nature of the requirement, including mission-performance assessments, leader development, certified coaching, and facilitation support aligned to operational execution needs required by the Picatinny–Detroit Command Merger. The prior planning placeholder was based on generic, open-enrollment training seat rates and did not account for customized curriculum delivery, Army-credentialed coaching certification, multi-site enterprise operational assessment, sustainment coaching, executive cohort development, or on-site facilitation across dual command hubs. The revised estimate averages per leader for approximately 100 senior leaders, aligning with the lower range of equivalent commercial C-suite transformation offerings and constitutes a realistic cost basis for the required level of customization and professional certification.

f. Quantified Redundant Cost Impact An Independent Government Cost Avoidance Estimate (IGCAE) indicates that Alternative sourcing would generate approximately in redundant costs and create delays that degrade operational alignment across Picatinny and Detroit workforce elements. These include curriculum redevelopment, Army technical review labor, expanded procurement and contract-administration overhead, and merger-related operational inefficiencies. These costs would materially delay mission execution and create systemic leadership and cultural inconsistencies across the merged Picatinny– Detroit workforce.

Based on the finalized Independent Government Estimate (IGE) and subsequent technical reconciliation, the total estimated cost for the PAE AS&A Senior Leadership

Development and Cultural Actualization Program is across a 48-month Period of Performance (Base Year and three Option Years).

This finalized estimate represents a necessary variance from the initial pre-solicitation planning placeholder, which relied on basic, open-enrollment commercial seat rates. The updated figure reflects the highly customized, multi-site operational transformation mandated by the Picatinny-Detroit Command Merger and includes the following year-by-year cost builds:

Base Year ( : Program set-up, baseline culture assessment across dual primary command hubs (Picatinny Arsenal, NJ and Detroit Arsenal, MI), full 3-part cohort training, proprietary ICF Level 1 Coaching, and initial PDSI tracking.

Option Year 1 ): Continued delivery of 3-part training, annual culture re-assessments, and executive coaching sustainment for Base Year graduates.

Option Year 2 ( Enterprise cultural roadmap scaling, annual culture re-assessments, advanced masterclasses, and executive/peer coaching sustainment.

Option Year 3 ( : On-site workshops, continuing executive coaching sustainment, and final enterprise transition roadmap.

This total cost of averages per leader for approximately 100 senior leaders and deputies, which is highly competitive and falls at the lower end of the commercial benchmark for equivalent C-suite leadership transformations per leader) offered by major consulting firms.

Standard commercial training firms and in-house capability are restricted to delivering generic, “off-the-shelf” modules that lack a unified organizational language and cannot integrate psychological baselines directly with operational tactical execution. A fragmented multi-vendor approach would create systemic incoherence across the leadership cohort, degrading the merger's intended cultural alignment. Rather than mitigating friction between Picatinny and Detroit, such fragmentation would exacerbate existing regional silos and hinder mission execution.

4. Quantified Government Redundant Cost Impact ( ):

A detailed Independent Government Cost Avoidance Estimate (IGCAE) indicates that procuring these services from alternative commercial sources would result in a total redundant cost to the Government estimated at $ , broken down across the following key cost drivers:

• Redundant Curriculum Design and Customization ( ):

Because Vanguard XXI’s curriculum and 5-Step Coaching Model are proprietary, an alternative vendor would require extensive instructional design hours to research, author, pilot, and refine a brand-new, customized acquisition-focused curriculum from scratch. These costs are fully avoided by utilizing Vanguard XXI’s existing, Army-aligned intellectual property.

• Army G-1 and G-3/5/7 Technical and Administrative Review Labor ( :

Securing the mandatory A3B and A4B Coaching PDSIs through another vendor would require initiating a new, multi-year curriculum mapping audit with the Army G-1, G-3/5/7, and PEO acquisition staff. Managing this 24-month technical review panel would consume approximately 1.0 FTE of senior Government labor (O-6, GS-15, and GS-14 PM levels). This process would need to be recreated completely from scratch for any non-Vanguard vendor, resulting in an estimated in redundant internal personnel costs.

• Procurement and Split-Contract Administrative Overhead ( ):

Competing and managing three distinct contracts to cover the leadership, coaching, and cultural pillars of the SOO—rather than utilizing a single integrated task order—would triple the administrative burden on the contracting activity. This includes additional technical evaluations, increased COR surveillance, and expanded procurement package development, estimated at ).

• Operational Friction and Command Merger Integration Rework ( ):

The Picatinny-Detroit merger requires immediate and unified leadership alignment. A multi-year delay to customize and certify a new vendor’s curriculum would prolong regional silos and command friction. Even a conservative 1% degradation in operational efficiency across the affected workforce equates to approximately in administrative rework and productivity loss, generating a projected cost over a 2-year period.

6. Efforts to Obtain Competition:

ACC-RI shall publish the notices required by RFO FAR 5.101.

Because this is a sole source action, effective competition is not applicable. The Government will achieve subcontracting competition by ensuring the resulting contract contains RFO FAR clause 52.244-5, Competition in Subcontracting, which states that the contractor shall select subcontractors on a competitive basis to the maximum practicable extent consistent with the efficient performance of the contract.

7. Actions to Increase Competition:

1. Continuous Market Surveillance (SAM.gov RFIs):

2. PDSI Equivalency Advocacy: Established a plan to work directly with the Army G-1, G-3/5/7, and the Army Coaching Program Office to advocate for a standardized, vendor-neutral mapping process. This will allow other commercial ICF-accredited vendors to qualify for the A3B/A4B PDSIs, breaking the proprietary barrier.

8. Market Research:

In accordance with RFO FAR Part 10 and 10 U.S.C. 3905, comprehensive market research was conducted by the requiring activity's technical and acquisition team on September 15, 2026, to identify all qualified sources.

1. Market Research Results & Exclusions: The GSA eLibrary, GSA Advantage!, and SAM.gov databases were queried under NAICS 611430 (Professional and Management Development Training) and PSC U009 (Education/Training - General).

o : Evaluated as an alternative. While is the sole provider of "Outward Mindset" training, their curriculum lacks a pathway to ICF accredited Level 1 professional coaching certifications and cannot grant the official Army A3B/A4B PDSIs. They do not possess the custom military/acquisition curriculum required for PAE AS&A.

o : Evaluated as an alternative. They provide standard executive coaching services but do not hold the proprietary character-centric framework required to unify the Picatinny-Detroit command cultures, nor are they certified by the U.S. Army to award coaching PDSIs.

2. Why Another Contractor Cannot Meet the Requirement: Vanguard XXI, LLC is the only commercial source holding the official U.S. Army G-1/G-3 certification to award the A3B and A4B Coaching PDSIs, and they are the sole owner of the proprietary 14-module curriculum. No other source can satisfy the integrated training triad without causing a 2-year administrative delay and incurring over in redundant design and review costs.

3. Mandatory Source Screening (10 U.S.C. 3905 / RFO Part 8): Federal Prison Industries (FPI/UNICOR) and AbilityOne were formally screened. FPI and AbilityOne do not provide advanced strategic leadership training, organizational cultural actualization, or accredited executive coaching certifications. The Contracting Officer has made a unilateral determination that these mandatory sources cannot satisfy the specialized requirement.

4. Posting Exemption under RFO DFARS 206.104-70(a)(2): Because this J&A cites the simplified procedures of 41 U.S.C. 1901 and is a brand-new, first-time acquisition (and not a non-competitive follow-on procurement previously awarded under RFO FAR 12.102(b), nor an action citing the authority of RFO FAR 6.103- 1), the requirement to post a sources sought notice or request for information under RFO DFARS 206.104-70(a)(2) and RFO DFARS PGI 206.103-170 is not applicable.

9. Interested Sources: To date, no other sources have expressed a written interest in this requirement.

10. Other Facts:

a. Procurement History:

Approval

Based on the foregoing justification, I hereby approve the procurement of commercial professional development, coaching certification, and organizational culture actualization services on an other than full and open competition basis pursuant to the authority of 41 U.S.C. 1901 as implemented by RFO FAR 12.201.The estimated value of this action is for one-year base and three one-year evaluated options to include 52.217-8. The approval is subject to availability of funds, and provided that the services or supplies herein described have otherwise been authorized for acquisition.