C38_SOA_Attachment__-_LSJ_PRISM_FE_redacted_1.pdf

United States Department of the Interior

INTERIOR BUSINESS CENTER

Washington, DC 20240

LIMITED-SOURCES JUSTIFICATION

AUTHORITY: FAR 8.405-6 and 40 U.S.C. 501

Solicitation No: 140D0425Q0217

This acquisition is conducted under the authority of the General Services Administration’s (GSA) Multiple Award Schedule (MAS) Program.

1. Identification of the agency and contracting activity, and specific identification of the document as a “Limited-Sources Justification.”

The Department of the Interior (DOI), Interior Business Center (IBC), Acquisition Services Directorate (AQD), Division I, Branch IV on behalf of the Business Integration Office (BIO).

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

This is a Limited Sources Justification for a recompete of proprietary Procurement Request Information System Management (PRISM), Security Assertion Markup Language (SAML) and Financial Assistance (FA) software to Unison (formerly Compu search) via GSA’s MAS program in accordance with FAR 8.405-6(b), Items Particular to One Manufacturer. This is a recompete of order140D0420F0180 which will expire March 31, 2025. The required items are available under Unison's GSA Schedule 47QTCA19D00EP under special item number 511210 – Software Licenses.

The Financial and Business Management System (FBMS) solution, specifically, the Unison PRISM, SAML, Financial Assistance and Federal Acquisition Regulation/Defense Federal Acquisition Regulation Supplement (FAR/DFARS) licenses, require on-going software maintenance to continue integration efforts. This maintenance is available only from the developer, Unison. Unison does not grant third party licenses.

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

DOI requires continued software maintenance for PRISM, SAML and FA software, DOI requires continued software maintenance for PRISM, SAML and FA software. DOI uses Unison's FA to manage grants and PRISM to manage acquisitions in all its operating locations. SAML is an open standard for exchanging authentication and authorization data between parties. SAML enables user sign-on through FBMS into PRISM and FA without custom coding. While the standard is open only the developer of the software can provide the necessary upkeep.

4. The authority and supporting rationale (see 8.405-6(a)(1)(i) and (b)(1)) and, if applicable, a demonstration of the proposed contractor’s unique qualifications to provide the required supply or service.

FAR 8.405-6(b)(1) – Items particular to one manufacturer.

This acquisition is being conducted under the authority of the MAS program. The primary statutory authorities for the MAS program are Title III of the Federal Property and Administrative Services Act of 1949 (41 U.S.C.251, et seq.) and Title 40 U.S.C. 501, Services for Executive Agencies. The basis for this justification is set forth in FAR 8.405-6(b)(1) – Items particular to one manufacturer.

Unison is the sole manufacturer of PRISM/SAML/FA software and owns the intellectual property rights for this software. Unison does not allow any other sources to sell their software maintenance, perform security patches or bug fixes; they are the sole GSA-authorized provider of PRISM/SAML/FA web software and maintenance subscription (GSA contract

47QTCA19D00EP).

The BIO already owns the required licenses and requires continued maintenance of these products essential to the operational status of the BIO and its customers. Without maintenance, the risk of a major disruption to users across all of DOI’s acquisition management systems is elevated, to include AQD. Access to upgrades, updates, fixes and patches ensures the software continues to perform optimally.

5. A determination by the ordering activity contracting officer that the order represents the best value consistent with FAR 8.404(d).

As provided in FAR 8.404(d), GSA has already established the prices offered for supplies and services under schedule contracts to be fair and reasonable. By placing an order against a schedule contract using the procedures in FAR 8.405, the Contracting Officer (CO) has concluded that the order represents the best value and results in the lowest overall cost alternative to meet the Government’s needs. In addition, the CO will seek a price reduction for prices offered.

Additionally, before making award, the CO will verify that all items proposed are currently available on the GSA schedule and offered at or below the current approved GSA prices. The CO will also seek further price discounts in accordance with FAR 8.404(d) and make a separate determination that the price is fair and reasonable based on comparison to the IGE, previous purchases, and current market pricing.

6. A description of the market research conducted among schedule holders and the results or a statement of the reason market research was not conducted.

Market research demonstrates that PRISM/SAML/FA software is a proprietary product licensed exclusively by and available only from Unison. Previous orders 140D00420F0180, D14PD00370, N09PD1894 and NBC20584 were awarded on a sole source basis to Unison as they are the software developer and intellectual property owner.

A search of GSA, SAM.gov, as well as a Google search reveal that only Unison Systems, Inc.

offers the required maintenance for Unison's software.

7. Any other facts supporting the justification.

DOI has over 1,660 PRISM users. PRISM is integrated into FBMS. It would take several years to implement a new system, integrate it with our financial system, and re-train all the users. This would result in significant expense and delay to DOI.

8. A statement of the 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.

Subsequent purchases shall be evaluated for additional sources on a case-by-case basis. DOI will continue to look for opportunities to compete its integrated contracts solutions packages as future requirements for enhancements become known.

9. The ordering activity contracting officer’s certification that the justification is accurate and complete to the best of the contracting officer’s knowledge and belief.

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

Heather Watroba, Contracting Officer

10. Evidence that any supporting data that is the responsibility of technical or requirements personnel (e.g., verifying the Government’s minimum needs or requirements or other rationale for limited sources) and which form a basis for the justification have been certified as complete and accurate by the technical or requirements personnel.

I certify the technical data which forms a basis for this justification is complete and accurate and meet the Government’s minimum needs.

Amy Goral, Contracting Officer’s Representative

AMY GORAL Digitally signed by AMY GORAL Date: 2025.02.10 07:35:28 -05'00'

HEATHER

WATROBA

Digitally signed by

HEATHER WATROBA

Date: 2025.02.10 07:50:34 -05'00'

11. For justifications under 8.405-6(a)(1), a written determination by the approving official identifying the circumstance that applies.

In consideration of the above justification, it has been determined that this procurement is appropriate for a limited competition under FAR 8.405-6(b)(1) – Items particular to one manufacturer (brand name).

12. Reviews and Approvals

Concur

Rajendra Panchal, Branch Chief

Concur

Shelita Saint-Louis, Division Chief

Approve

Michael Farrell, Competition Advocate

RAJENDRA

PANCHAL

Digitally signed by

RAJENDRA PANCHAL

Date: 2025.02.11 07:37:48 -05'00'

SHELITA SAINT-

LOUIS

Digitally signed by SHELITA

SAINT-LOUIS

Date: 2025.02.11 09:16:58 -05'00'

MICHAEL FARRELL

Digitally signed by MICHAEL

FARRELL

Date: 2025.02.11 16:07:19 -05'00'