A06 AOP5 FAR 6 JOFOC AgLearn 1011591 9-25-20 Redacted.pdf

AOP No. 5, J&A-Other Than Full & Open Competition- Attachment 2 (Feb. 26, 2020)

Justification for Other than Full and Open Competition United States Department of Agriculture

Federal Acquisition Regulation (FAR) Part 6.3

1. Identification of the agency and the contracting activity.

United States Department of Agriculture, Departmental Administration, Office of Contracting and Procurement, Procurement Operations Division, 301 S. Howes Street, Suite 321, Fort Collins, CO 80521.

2. The nature and/or description of the action being approved.

The United States Department of Agriculture, (USDA) Office of Chief Information Officer (OCIO) intends to issue a sole source brand-name requirement for the Totara Brand Name Suite.

3. A description of the supplies or services required to meet the agency’s needs (including the estimated value).

The United States Department of Agriculture, Office of the Chief Information Officer (OCIO), requires the authority to renew the entire functionality of the Totara Enterprise Suite Platform including critical version updates.

The USDA, OCIO requires direct access to the Totara Brand Platform Suite in support of the USDA AgLearn environment. The Totara Enterprise Platform shall include access to Totara License Services, Totara Government Cloud Talent Development Platform License Operations and Maintenance Support, and Totara Government Cloud Talent Development Platform Hosting Services and Support for the Enterprise Learning Management System (LMS), known as AgLearn.

Period of performance is October 1st, 2020 to September 30th, 2021. This will include 4 optional periods.

Option Period 1 12 Months October 1, 2021 – September 30, 2022 Option Period 2 12 Months October 1, 2022 – September 30, 2023 Option Period 3 12 Months October 1, 2023 – September 30, 2024 Option Period 4 12 Months October 1, 2024 – September 30, 2025

4. The statutory authority permitting other than full and open competition.

41 U.S.C. 3304(a)(1), as implemented by FAR 6.302-1, titled "Only one responsible source and no other supplies or services will satisfy agency requirements."

5. A statement demonstrating the unique qualifications of the proposed contractor or the nature of the action requiring the use of the authority.

Totara is the only known capable vendor who can provide all versions of the Totara Enterprise Services/Products and most current version platform offerings. Totara is copyrighted by the manufacturer, and no other source is authorized to provide the licenses, maintenance and technical support services.

The USDA AgLearn Program requires customization flexibility and direct access to the Totara vendor to provide Totara License Services, Totara Government Cloud Talent Development Platform License Operations and Maintenance Support, and Totara Government Cloud Talent Development Platform Hosting Services and Support for the Enterprise Learning Management System (LMS). This solution offerings & alignment of USDA as a Totara partner meets the requirements for the delivery and integration of a complete LMS system and AgLearn program, which includes the full range of LMS functionality, AWS hosting, & License Services, Operations and Maintenance Support.

Market research was conducted and reviewed the areas of Total Platform Cost, Primary Platform Risks, and other evaluation factors which included: 508 compliance, mobile support, vendor support and partnerships, 360 assessment functionality, federal market experience, reporting support and structure, FedRamp status, multi-tenancy support, and scalability. It was determined that no other vendor could meet all the unique features of Totara and that there was a significant dollar cost savings along with numerous qualitative benefits. The qualitative benefits utilized were Financial implications, Operation functionality, Security features and enhancements, and various Other Risk Factors.

Totara provides a Solution Strategy which incorporates both existing out of box and all current customizations functionality in the base platform for USDA and US federal partnered organizations, along with any new development & releases to expand the complete range of the LMS base functionality. This includes but is not limited to custom Standard Form (SF)-182 approval module, custom 180 assessment module, custom organization & multi tenancy module, and Totara Version 13 Totara Engage & Version 13 Totara 360 assessment modules.

Totara is more flexible for the USDA environment and provides unique customization features to meet all AgLearn training needs. It is a high-performance platform that functions on mobile devices limiting user down time and provides more access to the vast USDA community while providing multiple plugins. Totara provides a significant benefit with cost sharing among other Federal agencies and provides AgLearn with unique Enhanced Reporting features.

Although AgLearn found Totara to be the best return on USDA’s investment, AgLearn continues to conduct annual market research on different learning management solutions, partnerships with DOI & other federal agencies, and monitor the alternatives LMS options and Agency needs to ensure the best decision is made on behalf of USDA customers. At this point in time, no other vendor is capable of simplistically integrating a new product or services that will function with the same robust performance of Totara without a complete overhaul of the AgLearn platform.

Market research indicated that other LMS solution vendors such as GP Strategies Inc. & DOI IBC System could not offer the “complete” Totara License services for future versions (Version 13).

They could also not provide direct access nor modify the proprietary the functional components of the Totara Learn base and custom code. To make a change to another platform other than Totara would require a complete re-architecture of the existing platform, would require significant code changes and in some cases full rewrites of applications, data and design and a new LMS product for the solution delivery currently in production. Additional license and maintenance costs of a new solution, in parallel to the costly migration activities would be extremely cost prohibitive for the USDA, OCIO. A complete technology overhaul would be required to onboard another vendor costing millions of dollars without a guarantee that the minimum requirements of the Totara platform could be met and successfully incorporated into the existing AgLearn environment.

6. A description of efforts made to ensure offers are solicited from as many potential sources as is practicable.

The Contracting Officer will be posting this requirement via the Government Point of Entry-beta.SAM.gov utilizing Contracting Opportunities. This posting will afford all interested parties the opportunity to review the requirement.

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

The Contracting Officer has determined that the anticipated cost to the Governement will be fair and reasonable. Due to the commercial nature of the services to be acquired, FAR 15.403-1(b)(3) prohibits the Contracting Officer from requiring certified cost and pricing data. In the absence of certified cost and pricing data or adequate price competition, the price reasonableness determination will be based on prices paid for the same or similar commercial services under comparable terms and conditions by both Government and commercial customers, including pricing information contained in published price lists and previous contracts for the same or similar services; and comparison to the Independent Government Cost Estimate.

8. A description of the market research conducted and the results or a statement of the reason Market Research was not conducted.

Historical renewals for this product offering and services were previously purchase by delivery order from GP Strategies GSA Schedule. Totara has selected to no longer offer the complete and necessary Totara Suite to authorized resellers and now only provides access to this platform via direct sell from manufacturer.

9. Any other facts supporting the use of other than full and open competition.

None

10. A listing of the sources, if any, that expressed a written interest in the acquisition.

N/A

11. A statement of actions, if any, the agency may take to remove or overcome any barriers to competition if subsequent acquisitions are anticipated.

As the primary Totara Enterprise single platform offering becomes obsolete or requires replacement, competitive sourcing market research will be conducted to determine if other interested sources or service offerings are available. It will assess if it is within the best interest of the Government to pursue other options while maintaining the integrity of the platform without incurring substantial duplication of costs or cause a gap in services. Option years provide a fast off-ramp that allows the Government to quickly adapt to emerging technologies and make smart business decisions that leverage the competitive marketplace going forward.

Certifications & Approvals

Supporting data that form the basis for and included in this justification are certified accurate and complete.

Jerome Davin Director, Enterprise SaaS Branch

The information contained in this Justification for Other Than Full and Open Competition is certified accurate and complete to the best of my knowledge and belief.

Tracy Lynn Jackson Contracting Officer

Additional Reviews & Approvals

Signatures are required at each threshold up to the total estimated dollar value of the acquisition

Procurement Operations Division (POD) Branch Chief (if not the Contracting Officer) (if over $700,000). I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief.

Jason Kuhl Branch Chief, Procurement Operations Division

POD Competition Advocate (if over $700,000). I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief.

Danielle Knipper Competition Advocate, Procurement Operations Division

POD Senior Procurement Analyst (if over $700,000). I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief.

Senior Procurement Analyst, Procurement Operations Division

JEROME DAVIN Digitally signed by JEROME DAVIN Date: 2020.09.24 18:36:14 -05'00'

TRACY

JACKSON

Digitally signed by TRACY

JACKSON

Date: 2020.09.24 17:39:15 -06'00'

JASON KUHL Digitally signed by JASON KUHL Date: 2020.09.24 17:48:24 -06'00'

DANIELLE KNIPPER

Digitally signed by DANIELLE

KNIPPER

Date: 2020.09.24 17:54:16 -06'00'

BRINDER BILLUPS

Digitally signed by BRINDER

BILLUPS

Date: 2020.09.25 08:51:37 -04'00'

POD Deputy Chief (if over $700,000). I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief.

Kelly Moore Deputy Chief, Procurement Operations Division

Advocate for competition for the procuring activity (if over $700,000, but not exceeding $13.5 million). I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief. Therefore, unless additional approvals are required as prescribed below, as advocate for competition for the procuring activity, I hereby approve this justification.

Kelly Moore Acting Chief, Procurement Operations Division Procuring Activity Advocate for Competition

KELLY MOORE

Digitally signed by KELLY

MOORE

Date: 2020.09.25 09:29:36 -06'00'

KELLY MOORE Digitally signed by KELLY MOORE Date: 2020.09.25 09:29:56 -06'00'