Entrust JA Redacted.pdf

CONTROL NUMBER VA-25-00009898

JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY

1. Contracting Activity: Department of Veterans Affairs (VA) Office of Procurement, Acquisition, and Logistics Technology Acquisition Center 23 Christopher Way Eatontown, NJ 07724

2. Description of Action: The proposed action is for a firm-fixed-price delivery order issued under the National Aeronautics and Space Administration (NASA) Solutions for Enterprise-Wide Procurement (SEWP) V Government-Wide Acquisition Contract (GWAC) for brand name Entrust license subscription and Platinum Support.

3. Description of the Supplies or Services: VA, Office of Information and Technology, Support Systems, Public Key Infrastructure (PKI) has a requirement for brand name Entrust license subscriptions and platinum support for the current 1,550,000 subscriptions to support an Interagency Transaction with the Department of the Treasury (Treasury) to provide PKI services for VA in support of a Shared Service Provider (SSP). As an SSP for PKI services, the Department of Treasury, Bureau of the Fiscal Service (BFS), currently provides PKI support services to VA. VA provides these licenses to BFS as Government Furnished Property. Since Fiscal Year 2013, VA has held agreements with BFS to install, operate, and maintain a PKI enrollment server which provides VA with the ability to issue web and device based PKI and encryption certificates to users across the VA enterprise. The current Interagency Transaction was entered into on July 17, 2024 and expires on July 16, 2025, at which time the Interagency Transaction will be renewed each year as required. These licenses allow VA a limited web based PKI administration platform for the issuance and management of 1,550,000 end entity certificates within the VA enterprise. The required certificate authority administration software includes capabilities for auto enrollment, user management and user registration and enrollment server for the web management of encryption certificates. VA must provide these licenses and associated platinum support as Government Furnished Property to the BFS as an SSP for PKI services to VA. The Platinum Support shall include 24 hours per day, 7 days per week, 365 days per year support tool access and expedited requests with technical phone support. The period of performance shall be December 05, 2024 through December 04, 2025, and includes two 12-month option periods and two optional tasks within each period for up to an additional 400,000 Entrust license subscriptions and associated Platinum Support which may be required for the expansion of end entity certificates within the VA enterprise The total estimated price of the proposed action, inclusive of the option periods and optional tasks is

4. Statutory Authority: Pursuant to Federal Acquisition Regulation (FAR) 16.505(a)(4), the following brand name requirement is being justified and approved as an exception to fair opportunity under the statutory authority of Section 41 U.S.C. 4106(c)(2) as implemented by FAR 16.505(b)(2)(i)(B), entitled “Only one awardee is capable of providing the supplies or services required at the level of quality required because the supplies or services ordered are unique or highly specialized”.

Entrust License Subscriptions and Platinum CONTROL NUMBER VA-25-00009898 Support

5. Rationale Supporting Use of Authority Cited Above: Based on market research, as described in Section 8 of this justification, it was determined that limited competition is viable among resellers of the required brand name Entrust subscriptions and platinum support. VA has a critical need for subscription based licensing for certificates and platinum support. Entrust is the current software that the BFS uses for its entire customer base, which includes VA. VA utilizes BFS as an SSP for its PKI services and Entrust is the only software that is interoperable and compatible with the BFS hardware currently installed in its PKI management environment. The current infrastructure used by the BFS utilizes Entrust and VA needs to communicate with that infrastructure and can only use Entrust software due to the proprietary code that only allows Entrust certificates to be issued from the Entrust software that BFS hosts. The infrastructure for which the VA PKI resides on is a shared infrastructure with the rest of the Treasury PKI SSP program. Any other product, other than Entrust, would not communicate and work with the Treasury’s infrastructure. VA requires Entrust for continued operational availability. Therefore, software from other providers would not be supported by the BFS infrastructure.

Platinum support is required for software updates and patches which provides new feature sets, address program errors in prior software versions, and security enhancements. Only Entrust or reseller, can provide the necessary software upgrades and patches because of the proprietary source code required to develop and implement software updates. Since the software is proprietary, a legal restriction is placed on access to the software code that is required in order to develop upgrades and patches to the software. Without this access it is impossible for another source to modify the software code as necessary to provide the required patches and upgrades. No other source other than an Entrust reseller can provide the required platinum support requirements described herein, such as assistance via phone and email, as well as all software upgrades and patches.

Failure to obtain the Entrust subscription licenses and platinum support will cause negative impact on Veterans Affairs. The licenses are required for issuance of PIV cards for new and existing employees. Without the licenses no new PIV cards could be issued. This would cause issues with employee onboarding, user access issues and authentication to VA applications that use the certificates issued to the PIV cards. Furthermore, failure to obtain the licenses and support would cause issues with encrypted shared mailboxes and end user software certificates used for secure business communication throughout VA. Additionally, an active support contract is a requirement by Department of Treasury for Certificate Authority hosting services. The VA is responsible for maintaining a support contracting and licensing as part of the interagency agreement.

6. Efforts to Obtain Competition: Market research was conducted, details of which are in Section 8 of this justification. This effort did not yield any additional sources that can meet the Government’s requirements. It was determined, however, by the undersigned VA technical representative that limited competition is available among authorized resellers for brand name Entrust License Subscription and Platinum Support . In accordance with FAR 16.505(a)(4)(iii)(A)(1), this justification will be provided with the solicitation to all appropriate NASA SEWP V GWAC holders. Furthermore, in accordance with FAR 5.301, 16.505(b)(2)(ii)(D), and 16.505(a)(4)(iii), the award notice for this action will be synopsized on the Contract Opportunities website and this justification will be made publicly available within 14 days of award.

7. Actions to Increase Competition: The Government will continue to conduct market research to ascertain if there are changes in the market place that would enable future actions to be competed. VA technical Subject Matter Experts regularly review industry trade publications and conduct internet research to ascertain if any other software is available to meet the requirements described herein.

8. Market Research: The Government technical experts conducted market research in September 2024 by researching other similar subscriptions and support from other vendors. Specifically, the Government’s technical experts conducted web-based research from Verisign, Inc., Verizon Communications, DigiCert, and SafeNet, Inc. as other PKI providers. VA reviewed each of the possible sources’ product information and it was determined that only Entrust meets VA’s requirements. Through our interagency agreement, BFS PKI provides VA with all PKI support services and host a certificate authority configured with Entrust software. Other vendor products are not compatible to be used with Security Manager CA software, only Entrust licenses would meet the requirement. All other PKI providers use a different PKI vendor suite that is incompatible with the current BFS infrastructure. In addition, VA’s technical experts concluded that no other sources could provide the support without access to the proprietary source code for the Entrust subscription licenses. Unauthorized software providers do not have access to the proprietary source code of the Entrust subscription licenses and are not able to provide troubleshooting, updates, bug fixes, software patches and version upgrades.

Further market research was conducted by the Contract Specialist in September 2024 utilizing the Provider Look Up Tool on the NASA SEWP V GWAC website, which identified multiple Service-Disable Veteran-Owned Small Businesses (SDVOSBs) Value Added Reseller GWAC holders that provide brand name Entrust products.

Therefore, limited competition is expected among SDVOSBs for this proposed action.

9. Other Facts: None.

10. Technical/Requirements Certification I certify that the supporting data under my cognizance, which are included in this justification, are accurate and complete to the best of my knowledge and belief.

11. Fair and Reasonable Cost Determination I hereby determine that the anticipated price to the Government for this contract action will be fair and reasonable based on anticipated competition and discounts among Multiple value added resellers of the required brand name Entrust subscription license and platinum support. Additionally, further price analysis of quotes received will be conducted to determine fair and reasonable price. Finally, pricing of products awarded under NASA SEWP V GWAC have already been determined to be fair and reasonable.

12. Contracting Officer Certification/Approval I certify that this justification is accurate and complete to the best of my knowledge and belief.

Approval In my role as procuring activity Advocate for Competition, based on the foregoing justification, I hereby approve the acquisition of Entrust subscription license and platinum support on an other than fair opportunity basis pursuant to the authority cited in Section 4 above, subject to availability of funds, and provided that the property and services herein described have otherwise been authorized for acquisition.