Brand Name Justification Google Signed_Redacted 02282024.pdf

BRAND NAME JUSTIFICATION

FOR TASK ORDER MODIFICATIONS EXCEEDING

THE SIMPLIFIED ACQUISITION THRESHOLD

(AUTHORITY: FAR 16.505(a)(4))

USDS Implementation of FSA Google Analytics

1. Agency and contracting activity. Department of Education, Federal Student Aid Acquisitions

2. Nature and/or description of the action being approved.

Federal Student Aid (FSA) requires Unified Servicing and Data Solution (USDS) contractor support to implement Change Request (CR) 6912 titled: USDS Implementation of FSA Google Analytics. Student Experience and Aid Delivery (SEAD) stakeholders are requesting the USDS contractors implement the FSA Google Analytics standard with the implementation of Single Sign- On (SSO). The information provided from the analytic metrics will allow FSA to track the user experience across StudentAid.gov and the servicer websites once SSO goes live. This will help SEAD stakeholders identify anomalies in traffic patterns and identify places within site where customers are experiencing system errors.

This is a brand name justification to issue a firm-fixed price modification against each of the five current task orders for USDS Services to implement the requirements of CR 6912:

USDS Servicer Contract Task Order

MAXIMUS EDUCATION LLC 91003123D0001 91003123F0316

CENTRAL RESEARCH INC 91003123D0002 91003123F0318

EDFINANCIAL SERVICES LLC 91003123D0003 91003123F0319

MISSOURI HIGHER EDUCATION LOAN AUTHORITY 91003123D0004 91003123F0320

NELNET SERVICING LLC 91003123D0005 91003123F0321

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

In order to meet new performance requirements, contractors must use Google Analytics 360.

Google Analytics 360 supports development and operation of an internal, centralized Website Analytics Program by providing strategic guidance, creating and maintaining formalized frameworks and processes, supporting website releases and required updates to analytics, and providing key reporting and insights based on analytics data. The customized implementation of Google Analytics 360 provides business units with a standard enterprise-grade web analytics tool that effectively analyzes user behavior across all FSA websites and measures the impact of communications. It provides access to unsampled data necessary to effectively analyze the volume of data collected.

The servicer will implement the FSA Google Analytics standard as part of the FSA Single Sign-on solution. This includes the servicer including updated code for Tealium Specific Data and Tealium Snippet deployed to every page on the website to enable analytics. The servicer will adhere to the implementation guide for inclusion of Tealium code. In addition, the servicer will work collaboratively with the analytics vendor for deployment efforts.

(Insert PR/RFQ/BPA/Order number, as applicable)

The total estimated cost of this action over the life of all task orders (including options) is .

The estimated cost of this action for each task order is listed below.

USDS Servicer Task Order Amount

MAXIMUS EDUCATION LLC 91003123F0316

CENTRAL RESEARCH INC 91003123F0318

EDFINANCIAL SERVICES LLC 91003123F0319

MISSOURI HIGHER EDUCATION LOAN AUTHORITY 91003123F0320

NELNET SERVICING LLC 91003123F0321

4. Authority and supporting rationale. The following circumstance justifies limiting the source as supported below:

Item(s) peculiar to one manufacturer (including brand name) under the authority of FAR 16.505(a)(4).

Google Analytics 360 is the standard enterprise-wide web analytics tool in place for FSA main customer-facing websites.

5. Determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable consistent with FAR 16.505(b)(2)(ii)(B)(5).

Each of the servicers will be asked to provide a cost proposal for implementation of the CR. The contracting officer will review the pricing proposed and evaluate for price reasonableness.

Historical prices and contract prices from FSA’s contract providing Google Analytics 360 software internally will also be used in the price analysis.

6. Any other facts supporting the justification.

The use of Google Analytics 360 was presented to FSA’s Engineering Review Board on May 5, 2016, and it was approved as FSA’s web analytics standard.

Prior to the use of Google Analytics 360 as a standard, the Agency used a combination of Webtrends and Google Analytics on different websites with varying degrees of tracking capabilities, which resulted in fragmented data collection and siloed analysis of user behavior.

Google Analytics is the most widely adopted web analytics tool across government websites and is used by GSA’s Digital Analytics Program that is an OMB requirement for all government agencies.

Continued use of Google Analytics 360 reduces the dependency on development teams responsible for each website to implement marketing tags and to customize web analytics tracking, results in lower development costs overall, and better measurement in less time, and provides integrated security and privacy features-such as Do Not Track enablement, custom privacy widgets, and explicit/implicit opt-in features-that are not available from other products.

(Insert PR/RFQ/BPA/Order number, as applicable)

7. Actions, if any, the agency may take to remove or overcome any barriers that led to the restricted consideration before any subsequent acquisition for supplies and services is made.

FSA cannot overcome the brand name requirement unless FSA web analytics standards are changed from Google Analytics 360. No changes to FSA’s web analytics or IT standards are anticipated at this time.

8. Technical/Requirements Representative Certification.

I certify that this requirement constitutes the Government’s minimum needs and the supporting data provided herein is accurate and complete to the best of my knowledge and belief.

Project Officer

9. Contracting Officer’s Certification and Approval

I certify this justification is accurate and complete to the best of my knowledge and belief.

Jackson McClam Date Contracting Officer

JACKSON MCCLAM Digitally signed by JACKSON MCCLAM Date: 2024.02.14 08:18:59 -05'00'