B08_Attachment 0005_JA_Vanguard_26AUG FNL_REDACTED.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

Prepared by:

Contracting Officer:

Technical:

Requirements:

Reviews: I have reviewed this justification and find it adequate to support other than full and open competition.

Manager:

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 ($1,500,000.00):

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 $1,500,000.00, broken down across the following key cost drivers:

Redundant Curriculum Design and Customization ($350,000.00):

-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 utili -aligned intellectual property.

Army G-1 and G-3/5/7 Technical and Administrative Review Labor ($250,000.00):

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 $250,000.00 in redundant internal personnel costs.

Procurement and Split-Contract Administrative Overhead ($300,000.00):

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 $75,000.00 annually ($300,000.00 cumulative).

Operational Friction and Command Merger Integration Rework ($600,000.00):

The Picatinny-Detroit merger requires immediate and unified leadership alignment. A multi-regional silos and command friction. Even a conservative 1% degradation in operational efficiency across the affected workforce equates to approximately $300,000.00 annually in administrative rework and productivity loss, generating a projected $600,000.00 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): Committed the requiring activity to publish a formal Sources Sought/RFI on SAM.gov 18 months prior to the contract's expiration to discover if any other commercial vendors have developed comparable integrated curricula or secured Army G-1/G-3 PDSI certifications.

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 TELOS 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 TELOS curriculum. No other source can satisfy the integrated training triad without causing a 2-year administrative delay and incurring over $1.5M 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:

(1) Contract Numbers and Dates: There are no prior contracts for this requirement. This is a first-time service acquisition.

(2) Competitive Status: Not applicable.

(3) Authority Previously Cited: Not applicable.

(4) Summary of Prior Justification: Not applicable.

(5) Changes in Circumstances: Not applicable. This is a newly established command structure as of 2026.

(6) Unusual Patterns: Not applicable.

(7) Changes in Justification Circumstances: Not applicable.

11. Technical 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.

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 or 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.

Approval Levels Dollar Value of Document Approval Authority

> SAT and < $10M Contracting Officer* > $10M and < $100M Competition Advocate > $100M and < $500M Senior Executive Service > $500M Senior Procurement Executive

*Contracting officer signature at paragraph 14 (Contracting Officer Certification) constitutes approval; Approval page not required