FY25-CI00034_FE_LACES.pdf

Page 1 of 2 SPO Form 101 Standard Work (Rev 10.17.23)

Standard Work

Owner State Procurement Office, Compliance Unit

Form Number SPO Form 101 - Competition Impracticable Authorization Version Revised 10/17/23

Process Standard Work/Instructions for completion and submittal of the SPO 101 form. The form is available on the SPO website: For Agencies > Resources > Standard Forms and Documents.

Form Completion Process

No. Action Action Detail/Key Points

Sections I through III to be completed by the requesting State Governmental Unit:

SECTION I - State Governmental Unit Request

1 State Governmental Unit Name of the requesting State Governmental Unit (SGU; agency, board, or commission)

2 Requestor Name of the requestor 3 Email Email of the requestor 4 Title Job title of the requestor 5 Telephone Telephone number of the requestor

SECTION II - Background 6 Service(s)/Material(s) Description of service(s)/material(s) or Contract title (eProcurement Label) 7 Supplier Name of supplier(s) 8 Contract ID eProcurement contract number (if available)

9 CI Type Select applicable option:

- Authorization Request for a new CI

- Modification pursuant to R2-7-E303(E) for a CI modification

Page 2 of 2 SPO Form 101 Standard Work (Rev 10.17.23)

10 Requesting Term Specify contract term or extension period, as applicable, based on the CI 11 Estimated Cost Forecasted expenditures for the duration of the CI term

SECTION III - Justification

12 Rationale

Select applicable option in accordance with A.A.C R2-7-E303(A):

- Compliance with A.R.S. §§ 41-2533, 41-2534, 41-2538, or 41-2578 is impracticable

- Compliance with A.R.S. §§ 41-2533, 41-2534, 41-2538, or 41-2578 is unnecessary

- Compliance with A.R.S. §§ 41-2533, 41-2534, 41-2538, or 41-2578 is contrary to public interest

- Documented lack of suppliers

- Procurement requires an open and continuous availability of offerors

Provide details of the procurement need, reason for the competition impracticable, and how the proposed procurement is advantageous to the State

Detail information regarding the rationale selected in the previous section;

State Governmental Unit use of the material(s) or service(s); if mandatory state contracts were explored; the limitation which led to the competition impracticable, and how the State would benefit from the procurement. If there is previous contract which requires modification pursuant to R2-7-E303(E) or contract that reached beyond the maximum 5-year term, provide the contract number and copy of that CI.

Describe the procurement process, strategy to promote competition, and determination that the price is fair and reasonable

Detail strategy for the proposed procurement, considered competition, reason for selecting specific supplier, and negotiations strategy.

I have conducted research and determined that no mandatory state contract is available for the service(s)/material(s)

Check the box confirming research was conducted. If the CI pertains to a modification pursuant to R2-7-E303(E), leave field empty.

If needed, I have attached additional documents/clarifications/explanations to the request

Check the box to indicate that there are additional documents attached to the request. Either as separate documents in the original email request or attached directly to the PDF submitted.

17 Signature Signature of the authorized requestor 18 Date of Request Specify the date of request

Section IV to be completed by the Procurement Authority:

SECTION IV - Approval

19 Determination

Select applicable option in accordance with A.A.C. R2-7-E303(D):

- Request Authorized Pursuant to R2-7-E303

- Request Authorized with Conditions/Restrictions R2-7-E303

- Request Returned for Additional Information

- Request Denied

20 Approved Expiration Date Specify the date or term of expiration

21 Comments, conditions, or restrictions (as applicable) Complete as needed

22 Print Name Printed name of the approver 23 Title Job title of the approver 24 Signature Signature of the approving authority 25 Date of Approval Specify the date of approval

"STATE GOVERNMENTAL UNIT NOTICE: This is an official written determination in response to a procurement authorization request.

A copy of the form shall be maintained by the State Governmental Unit and the State Procurement Office.

Upon completion, Requestor shall forward the signed form to the Contract Owner.

Contract Owner shall upload the signed approval version of this form in the eProcurement system.

If anticipated expenditure is above State Governmental Unit's delegation, forward document to SPOCompliance@azdoa.gov."

Use section as necessary (or attach additional information and check box 16)

Used by any party in case the fields within the form were insufficient mailto:SPOCompliance@azdoa.gov

Page 1 of 5 SPO Form 101 - Competition Impracticable Procurement Authorization (Rev 10.17.23)

Procurement Determination:

Competition Impracticable Authorization A.A.C. R2-7-E303

SECTION I - State Governmental Unit Request

1. State Governmental Unit

Arizona Department of Education

2. Requestor 3. Email

Beverly Wilson beverly.wison@azed.gov

4. Title 5. Telephone

Deputy Associate Superintendent 602-364-2707

SECTION II - Background

6. Service(s)/Material(s)

Per the federal Workforce Innovation and Opportunity Act (WIOA) Title II, adult education is responsible for securing and providing a comprehensive Data Management System for the state adult education system and contracted adult education providers for data reporting and statute requirements. The Arizona Department of Education will be procuring a data management system

7. Supplier

Genius SIS, Inc. dba Genius LACES (A.P.P. supplier TBD) https://geniuslearning.com/laces-solutions/

8. Contract ID

N/A

9. CI Type

- Authorization Request for a new CI

10. Requesting Term 11. Estimated Cost

6/30/2025-6/30/2030 Not to exceed $700,000

SECTIONS I THROUGH III MUST BE COMPLETED BY THE REQUESTOR

USE ADDITIONAL PAGE AS NECESSARY

mailto:beverly.wison@azed.gov

Page 2 of 5 SPO Form 101 - Competition Impracticable Procurement Authorization (Rev 10.17.23)

13. Provide details of the procurement need, reason for the competition impracticable, and how the proposed procurement is advantageous to the State

Currently, the Arizona Department of Education has a contract with the vendor, Benchmark ITS, as the Database Management System for Adult Education-since 2015. The contract ends on June 30, 2025. Despite ADE's continued efforts to address areas of concern with Benchmark ITS and a formal Demand for Assurance issued by ADE Procurement in June 2023, Benchmark ITS has not fulfilled their scope of work, has provided unsatisfactory customer service throughout the contract, to the state and to external customers, and does not address resolve issues and identified problems on a timely basis. Additionally, the state office has ongoing issues with the validity and reliability of the data in the data management system.

ADE had to request an extension from the Department of Education-Office of Career, Technical, and Adult Education for a 30-day extension in September 2025 to submit the final state data for FY2023, after conducting an internal data analysis and finding inaccurate data reporting. This extension put ADE at risk of being sanctioned and a potential loss of Federal funds. Benchmark ITS’ failure to meet the expectations as outlined in the 2015 and 2020 Scope of Work and the Demand For Assurance issued in June 2023, as well as the other issues cited excludes this vendor from consideration as a vendor for the data management system for adult education.

ADE staff conducted research on the database management systems used by states for adult education. There were three other options used by other states, excluding Benchmark ITS. 1. State data systems that had been developed internally; 2. TOPSpro Enterprise by CASAS, a data management system developed for use with the standardized assessment, CASAS. ADE adult education does not use this standardized assessment; and 3. Literacy, Adult and Community Education System (LACES) by LiteracyPro Systems, Inc.

The vendor, LACES, is the most common data management system used for adult education in other states.

SECTION III - Justification

12. Rationale

- Compliance with A.R.S. §§ 41-2533, 41-2534, 41-2538, or 41-2578 is impracticable

Page 3 of 5 SPO Form 101 - Competition Impracticable Procurement Authorization (Rev 10.17.23)

16. If needed, I have attached additional documents/clarifications/explanations to the request

15. I have conducted research and determined that no mandatory state contract is available for the service(s)/material(s)

14. Describe the procurement process, strategy to promote competition, and determination that the price is fair and reasonable

The ADE-Adult Education Services staff performed a thorough audit of the publicly available data regarding state and territory usage of various data management systems for adult education. Source: https://nrsweb.org/policy-data/state-snapshots.

Upon review, 17 states/territories use an internally developed system, 29 states/territories use Literacy, Adult and Community Education System (LACES) by LiteracyPro Systems, Inc.

and 6 states/territories use TOPSpro Enterprise by CASAS. All states/territories that use TOPSpro Enterprise by CASAS use the CASAS assessment vendor. One other state, besides Arizona, currently have a contract with Benchmark ITS.

The current data management system houses around 20,000 unique student records each year in the existing system. Historical student record counts from the last three years are included below.

2023- 20,577 unique student records 2022- 19,820 unique student records 2021- 17,125 unique student records

Based on the review of the proposed pricing, the total cost of $700,000 for a five year term has been determined to be fair and reasonable. This determination is supported by the attached price comparison of current service rates. Additional costs for LACES are due to the available features and services not available from Benchmark.

In accordance with the Procurement Rules, the Arizona Uniform Terms and Conditions must be made a part of all Contracts. If you will be required to sign a software licensing agreement or sign any other agreement containing terms and conditions, these will need additional review to ensure that the terms and conditions do not invalidate the Arizona Uniform Terms and Conditions. Approval of this request does not allow for agencies to exceed their dollar acquisition amount of delegated authority.

Jun 27, 2025

Page 4 of 5 SPO Form 101 - Competition Impracticable Procurement Authorization (Rev 10.17.23)

STATE GOVERNMENTAL UNIT NOTICE: This is an official written determination in response to a procurement authorization request.

A copy of the form shall be maintained by the State Governmental Unit and the State Procurement Office.

Upon completion, Requestor shall forward the signed form to the Contract Owner.

Contract Owner shall upload the signed approval version of this form in the eProcurement system.

If anticipated expenditure is above State Governmental Unit's delegation, forward document to SPOCompliance@azdoa.gov.

SECTION IV - Approval

19. Determination

20. Approved Expiration Date

21. Comments, conditions, or restrictions (as applicable)

22. Print Name 23. Title

24. Signature 25. Date of Approval

TO BE COMPLETED BY PROCUREMENT AUTHORITY

David Steuber (Jun 27, 2025 14:25 PDT)

6/30/2030

David Steuber State Procurement Administrator

06/27/2025

- Request Authorized Pursuant to R2-7-E303 mailto:SPOCompliance@azdoa.gov https://na1.documents.adobe.com/verifier?tx=CBJCHBCAABAA-vUYSg4m5sNBKuTFYhL2nxTSQfnpy876

Page 5 of 5 SPO Form 101 - Competition Impracticable Procurement Authorization (Rev 10.17.23)

26. Use section as necessary (or attach additional information and check box 16)

Cost Comparison of Literacy Pro/LACES vs. Benchmark

Summary:

The available vendors for Arizona’s adult education data management system are ProLiteracy/LACES and Benchmark. Additional information has been provided in the Sole Source form.

Benchmark has held the ADE contract from 2015 through the present time. As stated in the submitted Sole Source form, Benchmark has a history of repeated instances of invalid data and poor performance. ADE Procurement has communicated this unsatisfactory performance with Benchmark via memos of concern and other communications multiple times over the last two years. (Documentation is attached to the email). The systemic failures in the Benchmark data management system, including low confidence in data integrity and not adhering to the required Federal reporting data measures, resulted in a corrective action plan being issued to the AZ Department of Education-Adult Education, by the Department of Education (DOE)- OCTAE, in March 2024.

When comparing the pricing of Benchmark and LACES, the Base Prices are similar. The additional costs for LACES are due to the available features and services, not available via Benchmark. ADE has contracts with curriculum vendors, Essential Education and Burlington English. These curriculum vendors track student attendance hours, and these attendance hours must currently be entered manually into the Benchmark data system by adult education program staff around the state that can result in inaccurate reporting. Additionally, LACES offers ongoing professional development for ADE staff and adult education providers. The Student Intake Portal will enable adult education program staff to complete an online record for each registered adult education student, thereby eliminating the need to manually enter registration information from a paper form.

These features and services are not available in Benchmark.

There is an initial cost with LACES to migrate the data to a new platform, at a maximum of $40,000.

This migration will include the transfer of student and user data from 2016 to the present time, approximately 15,000-20,000 student records from each year. These records include test data, demographic data, transcript and credential attachments, and data required for federal reporting.

LACES is currently used by at least 28 other states for their adult education data management system. Although the annual costs are slightly higher for LACES, ADE will have access to important services and features that are not currently in the Benchmark data management. Most importantly, due to the ongoing data integrity and service issues with Benchmark, they are not qualified to be selected as the vendor for the adult education data management system.

Pricing chart is below.

Price Comparison - Part 1

Benchmark Services & Pricing LACES Services & Pricing

Base Price Included Base Price (year one) $88,400 GED Integration Included GED Integration $2,500 TABE Integration Included TABE Integration $2,500 Student Intake Portal Not available Student Intake Portal $5,000 Professional development (webinar and onsite training)

Not available Professional development (webinar and onsite training)

$8,000

Training videos Not available Training videos (9 for year one, decreasing in future years)

$7,500

Essential Education Integration

Not available Essential Education Integration

$2,500

Burlington English Integration

Not available Burlington English Integration

$2,500

Total for Year One *Migration costs may not exceed.

$118,900 + $40,000 (*data migration)

$158,900 Total Cost per Year-per the current ADE Contract

$70,000 Total Cost-Year 2-5 $122,725.80

Price Comparison - Part 2