JOFOC - DataConnect (Redacted).pdf

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

FOR AN ACTION EXCEEDING THE SIMPLIFIED ACQUISITION THRESHOLD USING SIMPLIFIED

PROCEDURES FOR CERTAIN COMMERCIAL ITEMS IN FAR 13.5

PURCHASE REQUISITION: EDOFSA-24-000935

1. Agency and contracting activity.

Requiring Office: Department of Education (ED), Office of Federal Student Aid (FSA), Technology

Directorate (TD)

Contracting Activity: ED, FSA, Acquisitions Directorate (AD), Enterprise Support Group (ESG)

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

This is a sole-source justification for the renewal of FSA’s DataConnect Integration Manager licenses, under the authority of Federal Acquisition Regulation (FAR) 13.5, Simplified Procedures for Certain Commercial Products and Commercial Services. It is the intention of FSA to award a firm-fixed price purchase order to Actian Corporation, a Division of HCL Software, based on those specific software licenses identified within Section 3.

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

The software licenses to be procured are as follows:

Software Manufacturer: Actian Corporation.

Part Number Part Description Quantity

DC-ONPREM-P-NC-SUB

Includes during the term for production use, v12: software license rights to 1 DataConnect Integration Manager and to deploy an unlimited quantity of runtime engines and Studio IDE; includes during the term Silver Support Services in accordance with Actian's support policy.

DC-ONPREM-NP-NC-SUB

Includes during the term for non-production (i.e., Dev, Test, Standby, DR) use, v12: software license rights to 1 DataConnect Integration Manager and to deploy an unlimited quantity of runtime engines; includes during the term Silver Support Services in accordance with Actian's support policy.

DC-SUB-SLVR-OBS

Actian DataConnect Obsolescence Support for Silver Subscription. Includes during the term: Silver Obsolescence Support Services for a Perpetual License.

DC-SUB-SLVR-EXT

Actian DataConnect Extended Support for Silver Subscription.

Includes during the term: Silver Extended Support Services for a Perpetual License.

REINSTATEMENT FEE-DM Reinstatement Fee for Data Management Products. 1

Period of Performance: May 22, 2024 to May 21, 2025

Estimated Total Value: $440,000.00

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

41 U.S.C. 1901: Simplified Acquisition Procedures

5. A demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited. The Contracting Officer has determined the following circumstances justify the use of a sole source as supported below.

Only one responsible source and no other supplies or services will satisfy agency requirements.

FSA requires the DataConnect Integration Manager software to keep the Debt Management Collection System (DMCS) operational and compliant with White House initiatives regarding collecting debt on student loans.

DataConnect is an Extract, Transfer, and Load (ETL) tool that leverages integration engines to retrieve, edit, and load debtor information into the DMCS database. It ingests, transforms, and automates data pipelines to ensure the data is complete and compliant. DataConnect’s hybrid integration agents are used to securely connect to data endpoints while communicating job configuration and history metadata so safe correspondences to and from debtors, collection agencies, and Treasury are ensured.

DataConnect has been a critical part of Federal Student Aid’s infrastructure since 2014 and is the backbone to DMCS. It helped FSA shift from a manual, labor-intensive collection environment to a more effective management that has allowed FSA to focus on customer relationship management. DataConnect has given FSA the ability to consistently track accounts through the collection process lifecycle allowing for more expeditious collections. This tool has been modified to fit FSA’s Debt Management needs and coded accordingly to manage the Department’s debt collection portfolio and corresponding workflows. It receives data on borrowers from various sources Federal Servicers and feeds it into a user interface database where borrower payment information remains updated in real-time. DataConnect allows FSA to service student loan portfolio which totals over $1 Trillion and more than 48 million borrowers.

With FSA’s current infrastructure, multiple applications are integrated effectively and running almost 200 ETLs with DataConnect. The cost and level of effort would be too great to transition to another system/tool set that may or may not meet the government’s business and technical needs as an organization. Any deviation from pursing another software application that does not meet the unique specifications, would result in putting the systems at great risk and result in a loss of a continuity of operations.

Due to DataConnect software being the only current ETL tool approved by FSA and performing the data transformation and mapping required to meet FSA’s needs. However, the following alternatives were considered:

IBM Infosphere, Informatica, and Microsoft SSIS. The tools either lacked or showed deficiency in the following requirement areas:

• Low-code Data Integration that builds ETL and data integration pipelines nearly automatically, requiring limited input for developers.

• A Hybrid data integration platform that allows on-premise services and solutions to seamlessly and securely integrate with cloud-based applications.

• Ability to ingest data in real time.

• Ability to design, publish and manage user-defined data integration representational state transfer application programming interfaces (REST API).

• Embeddable ETL platform that allows seamless integration with analytical and BI software.

• Easily create custom connectors.

• Allow for segregate accounts using the rules engine, and with strategies, scheduled and on demand jobs, automatic distribution, redistribution, and other workflow options.

• Strong data validation, transformation, and enrichment.

• Increased scalability to process large data sets or volume.

• Not limited on database/data source compatibility.

• Data quality features to include: data profiling, data cleansing, and data standardization.

Due to the business logic in the current set of ETLs and the lack of available conversion tools, switching to different software would require an extensive analysis and rewrite of the 190-200 ETLs. It would take approximately 15 months to remake the ETLs and code accordingly with the DMCS. An Additional 6-12 months would be required to train the current workforce or hire new subject matter experts to properly manage and maintain the new solution. During an implementation of the new solution, the DataConnect licenses would still be required in addition to the new software licenses for the duration of the transition period.

As determined by FSA’s DMCS team, Actian Corporation, the sole provider of DataConnect Integration Manager, is the only software source to meet FSA’s requirements.

6. A description of efforts made to ensure that offers are solicited from as many potential sources as is practicable, including whether a notice was or will be publicized as required by FAR Subpart 5.2 and, if not, which exception under FAR 5.202 applies.

DataConnect Integration Manager subscription license and perpetual support (extended and obsolescence) is only provided by the manufacturer, Actian Corporation. Actian Corporation does not have authorized resellers for these services.

A Notice of Intent was posted to sam.gov on June 25, 2024, with a response date of June 28, 2024. FSA received no responses from responsible parties who expressed interest and capability to satisfy this requirement. In accordance with FAR 13.501(a)(1)(iii), a sole source justification will be posted to sam.gov within 14 days after award.

7. A determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable.

The CO will make a determination that the final cost to the Government is fair and reasonable before task order award. Prior to any determination, a technical representative will review the contractor’s quote to ensure it meets the Government’s requirements. In addition, the CO may use any of the techniques found in FAR 15.404-1 to verify the proposed prices are fair and reasonable.

8. A description of the market research conducted (see FAR Part 10) and the results or a statement of the reason market research was not conducted.

See section 6.

9. Any other facts supporting the use of other than full and open competition.

None.

10. 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.

FSA will continue to research other commercially available brand name or equal to similar services and/or support that are potentially capable of fulfilling future requirements. This research will include, but not limited to, conducting online research, attending technical training, seminars, and conferences surrounding the capabilities of this requirement.

11. 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.

Stacey Jacobs Date FSA Software Asset Manager

12. Contracting Officer’s Certification and Approval.

I certify this justification is accurate and complete to the best of my knowledge and belief. I determine that the circumstances in FAR 13.5 apply to this action.

Michael A. Pigram Date Contracting Officer