Attachment 3-JOFOC_Brand Name.pdf

Solicitation: 75H70426Q00025 Page 1 of 3

Rev. 11/14/2025

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION (Over SAT)

***THIS ONLY JUSTIFIES THE BRAND NAME DESCRIBED AS FOLLOWS ***

Pursuant to Revolutionary FAR Overhaul (RFO) 12.102, for acquisitions valued over the simplified acquisition threshold (SAT) using RFO 12.201-1 Simplified Procedures for commercial products and services

1. Acquisition Title: Grammarly Business Enterprise Licenses (Base + 4) (Brand Name:

Grammarly)

Division: Indian Health Service (IHS) Contracting Activity: Division of Acquisition Policy (DAP) Author: Javier Medina-Velazquez, Contacting Officer

2. Nature and/or Description of the Action being Approved:

The Office of Information Technology (OIT) is requesting a firm-fixed price contract to acquire Grammarly Business Enterprise (Base + 4) (Brand Name: Grammarly). The Government projects award for September 2026 using fiscal year 2026 funds.

Estimated Value:

3. Description of Supplies/Services and Estimated Cost.

IHS OIT is seeks to procure an online English writing assistance software tool to enhance the professional writing capabilities of approximately 600 IHS employees. The primary objective of this software is to enable users to produce clear, concise, accurate, and high-quality written communications. Specifically, the software must include advanced functionalities such as paragraph rewriting to improve readability and coherence; comprehensive proofreading to identify and correct grammatical errors, typographical mistakes, and punctuation inaccuracies;

and seamless integration across multiple desktop and laptop applications and websites utilized by IHS employees.

4. Authority:

This sole source acquisition is being conducted under RFO – FAR 12.201-1 simplified

(THIS

The contracting officer has determined that only one source is reasonably available based on the following rationale:

The acquisition is being conducted on a brand-name basis for Grammarly Business Enterprise because IHS has an established requirement for an enterprise writing-assistance solution that provides integrated grammar, proofreading, rewriting, organizational style and terminology management, and centralized administrative and security controls across applications and web-based workflows used by IHS personnel. Grammarly is currently used within IHS through individually acquired licenses, and this acquisition will consolidate those decentralized purchases into an enterprise-managed solution with standardized functionality, governance, security controls, and license administration.

Solicitation: 75H70426Q00025 Page 2 of 3

Rev. 11/14/2025

As part of its consideration of available alternatives, IHS considered Microsoft Copilot as a potential solution. OIT leadership determined that Copilot was not a cost-effective alternative for this requirement due to Microsoft's tiered licensing and pricing structure relative to the writing-assistance capabilities required by IHS. The Government's requirement is specifically focused on enterprise writing assistance rather than procurement of a broader productivity or artificial-intelligence platform. Based on the Government's requirements and market research, Grammarly Business Enterprise was determined to provide the required combination of specialized writing-assistance functionality, enterprise administration, security and privacy controls, and organizational standardization while meeting the Government's operational needs in a more cost-effective manner.

5. Special Considerations for Certain Contract Extensions or Bridge Contracts: N/A

6. Actions to Increase Competition:

Contracting Officer posted sources sought (75H70426Q00025) seeking to identify Indian Small Business Economic Enterprises (ISBEEs) at SAM.GOV from May 01, 2026, to May 11, 2026.

7. Market Research:

Buy Indian Act Focused Market Research: Pursuant to 48 CFR Part 326, Subpart 326.603-3 and IHM 5.5-6, Indian Health Service must use the negotiation authority of the Buy Indian ever the use of that authority is authorized and practicable. Therefore, the Contracting Officer posted a sources sought (75H70426Q00025) seeking to identify Indian Small Business Economic Enterprises (ISBEEs) at SAM.GOV from May 01, 2026, to May 11, 2026. Three (3) ISBEEs—FedTribe LLC, JTM Enterprises LLC, and Tek Annoa LLC—responded to the Sources Sought notice and were determined capable by the Contracting Officer, as each provided a valid reseller authorization letter from Grammarly.

Based on the results of the research, there are at least two or more ISBEE’s available to provide Grammarly Business Enterprise Licenses. Based on the market research results, this requirement will be procured under the authority of RFO Part 12 and should be competed as an ISBEE set-aside.

8. Procurement History: N/A

9. Additional Information to Support the Justification: N/A

10. Technical or Requirements Program Management Certification: I certify that the supporting data under my cognizance which are included in the justification are accurate and complete to the best of my knowledge and belief.

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