7 - WMATA JOFOC_SAM.pdf

FOR OFFICIAL USE ONLY

Source Selection Information -- See FAR 2.101 and 3.104

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

CFTC intends to solicit on a sole-source basis. The following rationale is provided in accordance with the requirements of Revolutionary Federal Acquisition Regulation Overhaul

(RFO FAR) 6.103-1.

(1) Identification of the agency and the contracting activity:

Commodity Futures Trading Commission (CFTC), Business Operations Branch (BOB).

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

CFTC seeks to renew the contract with the Washington Metro Area Transit Authority (WMATA) for the usage of the WMATA SmartBenefits transit system to enroll, withdraw, and change employee transit benefits.

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

CFTC’s Business Operations Branch manages the CFTC headquarters transit benefit program and requires the use of WMATA’s SmartBenefits program. The SmartBenefits program allows CFTC to manage and fund transit benefits for CFTC transit benefit participants. CFTC transit benefit participants can use their individual SmarTrip cards to commute to and from work using different modes of public transit, including Metrorail, Metrobus, regional commuter buses, van pools, Amtrak, and local commuter trains. The SmartBenefits program allows CFTC to independently manage the funded values of all SmartTrip cards assigned to CFTC employees. WMATA does not charge a fee for the use of its SmartBenefits program.

CFTC seeks to award a sole-source contract to WMATA for the purpose of continuing to provide transit benefit subsidies to CFTC employees using the WMATA SmartBenefits system.

The estimated value for a five-year contract based on historical billings is $5,000,000.00.

(4) An identification of the statutory authority permitting other than full and open competition.

The statutory authority permitting other than full and open competition for this requirement is 41 U.S.C.3304(a)(1). “Only one responsible source and no other supplies or services will satisfy agency requirements.”

(5) A demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited.

WMATA manages the only subway system in the Greater Washington DC area (Metrorail).

Additionally, the WMATA SmartBenefits program is the only program in the region that offers seamless transition between multiple modes of transportation across multiple jurisdictions while allowing CFTC to independently manage its budget and funding for individual commuter employees.

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

There are no other sources that can provide access to the Metrorail or Metrobus system.

Additionally, there are no other sources that offer an ability to manage funding for multiple modes of transportation through a single interface. In accordance with RFO FAR 5.101, a notice of this action was posted on August 18, 2026. There were two responses received as a result of this posting, neither of which was valid. Details for these response are below:

1. Bloomberg Government – Bloomberg Government responded to CFTC’s presolicitation notification of intent to sole source seeking additional information about the notification, but did not provide a capability statement as required by the notice. The presolicitation notice stated that “Written responses must include sufficient information to establish capability to fulfill the requirement.” The contracting officer responded to this inquiry noticing that there was no capability information included in the response.

2. ADVF Group – the ADVF Group responded to the presolicitation notice and included a capability statement. However, the capability statement was not germane to the requirement. The contracting officer’s response to the ADVF Group stated that the “response must ‘include sufficient information to establish capability to fulfill the requirement.’ The SAM.gov notice indicated that ‘there are no other sources that offer an ability to manage funding for multiple modes of transportation through a single interface.’ The capability statement provided indicates that ADVF group provides services such as conference room booking, catering, event management, and hospitality consulting. The capability statement did not indicate an ability to manage funding for multiple modes of transportation within the WMATA system.”

Both of these responses are included in full as an attachment to this JOFOC.

(7) A determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable.

CFTC anticipates receiving WMATA’s standard offered commercial pricing. CFTC also anticipates no fee for the use of WMATA’s SmartBenefits program. Therefore, CFTC anticipates that the pricing submitted by WMATA will be fair and reasonable.

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

The Business Operations Branch conducted market research and determined that WMATA remains the only entity capable of providing transit services via Metrorail and Metrobus, and the only entity capable of benefit transferal between Metrorail/Metrobus and other local transit systems.

(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, in writing, an interest in the acquisition.

None.

(11) A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition for the supplies or services required

There are no actions the agency could take to remove barriers to competition in this instance.

WMATA is the only organization that manages Metrorail and Metrobus. There is also only one regional travel program that offers benefit transferal between Metrorail/Metrobus and other local transit systems, which is the SmartBenefits program using the SmarTrip card.

CFTC will compete this requirement if another vendor is able to offer a similar service in the future.

Remainder of page intentionally left blank