CourseAve LSJ - 508 eLearning Tools 8.405-6b (SAM.gov).pdf

LIMITED SOURCES JUSTIFICATION

FOR LIMITING SOURCES ON THE FEDERAL SUPPLY SCHEDULE PROGRAM

FAR Part 8.4

1. The Office of Acquisition Management is conducting this acquisition for the development of 508 compliant Distance Learning tools to be accessible through the existing platform on behalf of the Bureau of the Comptroller and Global Financial

Services, International Cooperative Administrative Support Services Service Center

(CGFS/ICASS). In addition, to maintain the Learning Management System (LMS) for its courses, enabling tracking, testing and providing certificates of completion to employees, CGFS requires access to the licenses from Course Avenue to enable this feature. The estimated cost is $69,000/year over the period of 5 years ($345K total).

2. Nature and/or description of the action being approved. This is a continuing acquisition activity related to the development of distance learning (DL) materials for the

Department of State’s International Cooperative Administrative Support Services program for delivering shared services at embassies and consulates overseas. The DL deliverables must be compatible with the “Instructional Shell” procured previously, as described in para 3 below. In addition, the materials must meet Section 508 compliance requirements under the Rehabilitation Act of 1973. Market research has not revealed any firms who offer a comparable service. Please see attached documentation from market research.

3. A description of the supplies or services required to meet the Department’s needs.

On an annual basis develop and put in place the following materials which will be

Section 508-compliant and be placed in the “Instructional Shell” which has been created previously by Course Avenue specifically for this purpose;

-one 508 compliant “On-Line Instruction” to include self-paced instruction materials, self-examination capabilities and accompanying resources materials

-eight 508 compliant Distance Learning Tools – approx. 10-30 minute close captioned instruction videos.

-licenses for LMS as described in item 1 above.

4. An identification of the LSJ rationale, and if applicable, a demonstration of the contractor’s unique qualifications to provide the required supply or service. FAR

8.405-6(b) Items peculiar to one manufacturer.

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

Course Avenue was recommended by the Department of State IRM IMPACT Office that oversees the Department’s adherence to 508 Compliance. Based upon that recommendation we entered into a contract with Course Avenue to develop our library of

Distance Learning Tools and Distance Learning On-Line Instruction under the previous sole source designation. Subsequently, we contracted directly with Course Avenue to set up and configure a platform for making those tools available to our customers and for tracking participation. To keep the uniform look of our tools and On-Line Instruction and to continue to leverage the investment in our existing library/platform, we need to make use of the services offered by Course Avenue since they have developed a functioning “shell” specifically designed and branded for use by the ICASS Service

Center. To select another vendor would require this whole platform and existing materials to be redeveloped.

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

Previous efforts to develop 508 compliant training tools with other vendors were not successful when the Department’s IRM IMPACT office advised us that these tools were not 508 compliant and recommended that we engage with Course Avenue, a recognized

508 compliant leader with independent third party validation of its 508 compliancy.

CGFS/ICASS has updated its market research to determine if alternative vendors exist who could supply comparable materials. There are vendors who offer subscriptions to monitor websites to identify non-compliant content, and vendors who will use assistive technology to test documents for compliance, but we have not been able to identify any vendors that produce certifiably compliant materials. The

Department’s IMPACT office has recently confirmed their original assessment that

Course Avenue products are compliant and could not advise on the existence of other vendors known to produce comparable materials.

7. A determination by the ordering activity Contracting Officer that the order represents the best value consistent with FAR 8.404(d) and FAR 8.405-2(d). As GSA has already determined the unit prices under FSS contracts to be fair and reasonable, and the contracting officer will evaluate the reasonableness of the labor mix and overall level of effort the contractor’s quote reflects.

8. A description of the market research conducted among schedule holders, and the results of the research, or a statement why market research was not conducted. A statement must be made that the supplies and services are available from the FSS.

Please see the response to item #6 for a description of past efforts to acquire training materials that achieved 508 compliance. The identified items are available on Course

Avenue’s Federal Supply Schedule.

9. Any other facts supporting the limited sources justification.

Engaging with another vendor to begin from the start to develop 508 compliant training materials, and to acquire the means to monitor and track their usage by customers means that we will lose the investment in the Course Avenue training materials developed to date and raises the risk that other vendors will fail to pass the IRM IMPACT office’s tests of 508 compliance.

10. A listing of sources, if any, that expressed, in writing, an interest in the acquisition.

N/A

11. A statement of the actions, if any, the agency will take to remove or overcome any barriers that led to restricted consideration before any subsequent acquisition for supplies and services is made.

Please see the response to item #6 above, regarding recent effort to identify alternative sources.