I_04 SF1013 JA Sole Source FAR 13.5 VSS_kdp.pdf

DEPARTMENT OF THE TREASURY

SF 1013 - JUSTIFICATION & APPROVAL FOR FAR SUBPART 13.5 SOLE SOURCE

(INCLUDING BRAND NAME) ACQUISITIONS

ACQUISITION TITLE: VANGUARD SECURITY SUITE

Treasury Standard Form – 1013 (Rev 12/24)

Prescribed by Treasury: DTAP 1013.501

Tracking No.

1. Identification of the requiring activity and the contracting activity:

The requiring activity is the Internal Revenue Service Security Operations & Standards Division. The contracting activity is the Strategy Planning & Cyber Section 2, Information Technology Strategy & Modernization Division, Office of the Chief Procurement Officer (OCPO), Internal Revenue Service.

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

The IRS Information Technology organization has an immediate need to establish a firm-fixed-price (FFP) contract award for VANGUARD Security Suite software for the Internal Revenue Service. This requirement period of performance is anticipated to be October 30, 2025 – October 29, 2028, including one 12-month base year and two 12-month option years.

2.b Name of the vendor. Vanguard Integrity Professionals 2.c Requisition No.: 5000220709 2.d Bridge contract: Yes No 2.e Brand name: Yes No 3.a A description of the supplies or services required to meet the agency’s needs:

IRS has a requirement for software and license maintenance and support for the Resource Accent Control Facilities (RACFs) for up to 39,019 Million Instructions Per Second (MIPS) computing performance/processing capacity.

The IRS mainframe environment of already purchased systems and in use, comprise of 23 Logical Partitions (LPARs) and 13 Resource Access Control Facility (RACF) databases. To secure this complex infrastructure, the IRS requires advanced security capabilities tailored specifically to the agency’s unique operational and compliance requirements that work in conjunction with IBM RACF.

These features are critical to Treasury’s Zero Trust and Federal Information Security Modernization Act (FISMA) compliance requirements:

IRS Requirement #1 — AU-12: Audit Record Generation

IRM 10.8.1.4.3.11 (12-13-2022)

Requirement Summary: Continuous and complete audit record generation with real-time reporting.

IRS requires contemporaneous capture or evidentiary integrity; therefore, the system must employ real-time, automated processes to generate, protect, and retain audit records

IRS must ensure that audit records are automatically generated for all defined security-relevant events to provide complete, timely, and verifiable evidence of system activity.

IRS Requirement #2 — AU-06: Audit Review, Analysis, and Reporting

IRM 10.8.1.4.3.5 (09-28-2021)

Requirement Summary: Must detect/respond to audit anomalies in real time with automated integration.

IRS must be capable of reviewing, analyzing, and reporting audit records in an automated, continuous, and timely manner to identify indications of unauthorized, inappropriate, or unusual activity.

IRS Requirement #3 — SI-04: System Monitoring

IRM 10.8.1.4.19.3 (01-28-2025)

Requirement Summary: Continuous system monitoring and real-time event analysis.

IRS requires Continuous, automated system monitoring to detect, analyze, and respond to unauthorized or anomalous activity IRS requires Real-time monitoring and early warning of potential security incidents, to ensure ongoing situational awareness, and supports federal continuous-monitoring and incident-response mandates.

IRS requires Automated detection and correlation of events across all mainframe environments as essential to maintain operational integrity, prevent intrusion escalation, and meet evidentiary standards of authenticity.

Market research was conducted between IBM zSecure and the Vanguard Security Suite. They were evaluated for policy enforcement, compliance automation, MFA support, and software-integrity monitoring. IBM zSecure was not able to provide the integrated delivery governance (MSDS) or real-time policy enforcement (Policy Manager/Enforcer) that Vanguard offers.

Vanguard offers all of the following required IRS integrated capabilities within a single supported suite. Please see detailed comparison, below:

IRS Requirement #1 — AU-12: Audit Record Generation

IRM 10.8.1.4.3.11 (12-13-2022)

Requirement Summary: Continuous and complete audit record generation with real-time reporting.

Vanguard:

o Provides automated, continuous, and real-time audit record generation.

o Meets FISMA (44 U.S.C. § 3554(b)(7)), OMB A-130 § 9(h)(2), and NIST

AU-12(a–e).

o Uses integrated SMF exit processing and centralized configuration management.

o Records are digitally signed and tamper-evident—admissible under FRE

901(b)(9).

o Ensures uniform audit policies and a verifiable compliance posture.

zSecure:

o Batch/post-event processing through CARLa; not real-time.

o Lacks continuous or tamper-evident audit generation.

o Cannot enforce audit policies across LPARs.

o Non-compliant with NIST AU-12 operational intent.

Conclusion: Vanguard fully compliant; zSecure not compliant.

IRS Requirement #2 — AU-06: Audit Review, Analysis, and Reporting

IRM 10.8.1.4.3.5 (09-28-2021)

Requirement Summary: Must detect/respond to audit anomalies in real time with automated integration.

Vanguard:

o Performs automated, continuous, and real-time audit review across RACF, ACF2, and Top Secret.

o Meets FISMA, OMB A-130, and NIST AU-6 (a–d).

o Active Alerts and Configuration Manager provide real-time detection and automated response.

o Records are digitally signed and time-stamped.

o Enables continuous verification and legal defensibility.

zSecure:

o Post-event, batch-driven processing; no real-time analysis or alerts.

o Cannot detect anomalies as they occur.

o No SIEM integration or automated response.

o Fails to meet continuous monitoring standards of AU-6.

Conclusion: Vanguard fully compliant; zSecure partially compliant (retrospective only).

IRS Requirement #3 — SI-04: System Monitoring

IRM 10.8.1.4.19.3 (01-28-2025)

Requirement Summary: Continuous system monitoring and real-time event analysis.

Vanguard:

o Provides continuous, enterprise-wide monitoring across RACF, ACF2, and Top Secret.

o Meets FISMA, OMB A-130, and NIST SI-4 (a–e).

o Real-time detection, analysis, and response via Active Alerts and Configuration

Manager.

o All events are digitally signed and integrity-protected.

o Ensures legal admissibility and continuous situational awareness.

zSecure:

o Batch-mode, post-event utility dependent on SMF dataset collection.

o No real-time detection, alerting, or automated response.

o No continuous SIEM integration.

o Fails to meet the operational intent of NIST SI-4 continuous monitoring.

Conclusion: Vanguard fully compliant; zSecure not compliant for real-time system monitoring.

3.b Includes IT: Yes No NAICS: 513210 – Software Publishers PSC: 7030 – Software Publishers 3.c IGCE/Estimated dollar value (include period of performance breakdown):

The IGCE is in the total amount of $5,414,289.00. This includes the base year and two option years if exercised. Refer to the IGCE for additional details.

4. Identification of the authority being used (Check the box that applies):

41 U.S.C. 1901 – Simplified acquisition procedures.

41 U.S.C. 1903 – Special emergency procurement authority.

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

This requirement will be procured using FAR Subpart 13.5 - Simplified Procedures for Certain Commercial Products and Commercial Services. Vanguard Security Professionals is the only suitable vendor that can provide the brand name products for this requirement. Based on the rationale stated in section 3 of this form, the IRS is seeking a sole source award to Vanguard Professionals.

6. A description of efforts to ensure that offers were 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:

In accordance with FAR 13.501 (iv) - Special documentation requirements: this brand name justification will be made available publicly with the solicitation in accordance with 5.102(a)(6).

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

The Contracting Officer will ensure that the anticipated cost to the Government will be fair and reasonable based on the following methods in accordance with FAR 15.404-1 proposal analysis techniques; FAR 15.404-1(b)(v) Comparison of proposed prices with Independent Government Cost Estimates.

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:

The Government has continued to seek competition for these services for subsequent acquisitions. The results of the market research supported the Government’s determination to obtain the software products under a brand name sole source basis by reviewing catalogs and other generally available product literature published by manufacturers, distributors, and dealers or available on-line (e.g. GSA's Green catalog); and conducted interchange meetings or held pre-solicitation conferences to involve potential offerors early in the acquisition process.

In additional efforts to research resellers or potential dealers of this software, the program office reached out to industry. On May 14, 2025, the Program office obtained a letter provided by the Vice President of Customer Relations and Conference from Vanguard. The letter provided served as notice that Vanguard Integrity Professionals, Inc., is the only United States vendor subject to sign licenses agreements between Vanguard and the licensee. Therefore, Vanguard is the sole provided for the required software for this requirement.

9.a Any other facts supporting this justification:

Introducing a modification to the governments technical requirement would require reverse engineering the current software and licensing maintenance, interface changes and developing new technical data packages which poses quality risk issues and potential scheduling slips.

Through comprehensive market research conducted through GSA Advantage and an analysis of current government contracts, the government estimates approximately $3 million annually, or $9 million over a three-year period to initiate a technical modification on this requirement.

Currently, the IRS does not have the budget authority to proceed with such efforts.

In accordance with FAR 13.5: Only one source reasonable available. Vanguard is the only United States vendor that can provide the maintenance and support for the Vanguard Software Products and is the sole owner. Vanguard has provided a letter acknowledging that it is the sole source provider. There are no technical requirements available to support competition.

This product is Procurement history: Task Order (PO) 2032H5-23-P-00001, awarded on 10/01/2022 and 2032H5-20-C-00001 which was awarded to Vanguard Integrity Professionals on 09/27/2019 on a non-competitive basis. The total value of the contract is $5,414,289.00 9.b Attachments: Yes No

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

None.

11. A statement of the actions, if any, the Requiring Activity or Contracting Activity may take to remove or overcome any barriers to competition before any subsequent acquisition for the supplies or services required:

Based on the rationale above in section 3, Vanguard Integrity Professionals is the only vendor that could provide the brand name software products for this acquisition. The IRS currently utilizes the products within the mainframe environment in support of tax data information and reports that are compatible within the mainframe environment. This product is essential and supports tax filing operations.

12. Certifications and Approvals:

Prescribed by Treasury: DTAP 1013.501 Tracking No.

12.a Program Office certification (Requiring Activity). I hereby certify that any supporting information and data provided, which form the basis for this justification, are accurate and complete to the best of my knowledge and belief.

Name: Date:

Signature:

12.b Contracting Officer certification and approval. I hereby determine the circumstances of this acquisition support the justification to acquire the item(s) on a sole source (including brand name) basis under the authority of FAR subpart 13.5. I also certify this justification is accurate and complete to the best of my knowledge and belief. Therefore, unless additional approvals are required as prescribed below, as the authorized contracting officer for this acquisition, I hereby approve this justification.

Name: Date:

Signature:

13. Additional Reviews and Approvals (As applicable):

13.a Bureau Chief Information Officer or Authorized Designee (for IT requirements that are over $5 million, but not exceeding $75 million) (Contracting Activity). I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief, and representative of the Government’s need. Therefore, I hereby consent to the approval of this justification. (Note: The Bureau CIO may delegate their authority for proposed contracts over $5 million, but not exceeding $15 million to the Associate Bureau CIO(s).)

Name: Date:

Signature:

13.b Advocate for Competition (if over $750,000, but not exceeding $15 million) (Contracting Activity). I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief. Therefore, unless additional approvals are required as prescribed below, as the Advocate for competition, I hereby approve this justification.

Name: Date:

Signature:

13.c Head of the Procuring Activity or Authorized Designee (if over $15 million, but not exceeding $75 million) (Contracting Activity). I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief. Therefore, unless additional approvals are required as prescribed below, as the head of the procuring activity or authorized designee, I hereby approve this justification.

Name: Date:

Signature:

13.d Treasury Chief Information Officer (for IT requirements that are over $75 million).

I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief, and representative of the Government’s need. Therefore, I hereby consent to the approval of this justification.

Rodney B. Thomas Jr.

Digitally signed by Rodney B.

Thomas Jr.

Date: 2025.10.23 15:58:45 -04'00'

Megan M.

McMullen

Digitally signed by Megan M.

McMullen Date: 2025.10.23 16:10:05 -04'00'

Frederick R.

Thomas

Digitally signed by Frederick R.

Thomas Date: 2025.10.24 08:15:07 -04'00'

Kaschit Pandya, Chief Information Officer, IRS

Name: Date:

Signature:

13.e Senior Procurement Executive (if over $75 million) (Contracting Activity). I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief. Therefore, as the senior procurement official, I hereby approve this justification.

Name: Date:

Signature: