JA_Adobe License_Signed_Redacted.pdf

Adobe Licenses with Maintenance and Support, VA-26-00039778

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 Adobe Acrobat Studio software licenses and renewal of Adobe Experience Manager (AEM) Forms software licenses, including maintenance and support.

Further, this action will also include optional tasks to purchase additional quantities of both Adobe Acrobat Studio and AEM Forms software licenses and support services to address anticipated growth.

3. Description of the Supplies or Services: VA, Office of Information and Technology, Information Technology Operations and Services, has a requirement to upgrade the 135,000 Adobe Acrobat Pro licenses with its new version of 135,000 Adobe Acrobat Studio software license subscriptions, as well as renew 12 AEM Forms software license subscriptions. This proposed action will also provide maintenance and technical support to these Adobe software products.

The two software products are used by forms management staff across all

Veterans Health Administration (VHA), Veterans Benefits Administration (VBA), and National Cemetery Administration (NCA) program offices rely daily on the technical cohesion of capabilities collectively delivered by several Adobe software products (i.e., Adobe Acrobat Studio desktop application, as well as the Adobe Forms Designer and Adobe Acrobat Reader Extensions component which are now bundled in the AEM

Administrations. These customizable workflows allow Forms Managers to internally design, manage, and publish Agency-specific standardized forms for Veterans and VA staff to electronically access, complete, and download via the One VA Forms portal.

Information subsequently submitted in these standardized forms streamlines VA data

AEM Forms generated portable document format (PDF) files have also provided VA a method to publish agency-specific standardized forms. This allows Veterans to electronically access and complete required forms via the freeware version of the Adobe Acrobat Reader product without burdening Veterans with an additional software cost to collaborate electronically with VA. The VA requires the product to natively handle XFA forms, apply reader extensions, and integrate the CommonLook accessibility plug in.

Adobe Acrobat Studio software provides the ability to create and edit PDF documents utilized among VA staff across the enterprise as a method of informing Veterans of services and employees of VA policy, guidance and procedures. AEM Forms simplifies the management and delivery of VA websites' content and assets and reduces the

The required maintenance and technical support includes updates, bug fixes and upgrades to existing Adobe products as well as technical support services by Adobe certified technicians.

Optional tasks are included to procure additional Adobe Acrobat Studio and AEM Forms subscription-based software licenses with maintenance and support to meet the lifecycle of the contract.

The period of performance for this proposed action will consist of a 12-month base period and optional tasks. The total estimated cost of the proposed action, including all optional quantities, is

4. Statutory Authority: Pursuant to Revolutionary Federal Acquisition Regulation Overhaul (RFO) VA Deviation 16.507-7(b), 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 RFO VA Deviation 16.507- 6(b)(2), required at the level of quality required because the supplies or services ordered are

5. Rationale Supporting Use of Authority Cited Above: Based on market research, as described in Section 8 of this document, it was determined that limited competition is anticipated among authorized resellers for this procurement. VA currently utilizes Adobe Acrobat Studio desktop subscription-based software licenses and AEM Forms core server software licenses throughout VA to continually update and design forms.

The current inventory of VA PDF forms includes forms created using the predecessor Adobe forms designer tool (i.e., Adobe LiveCycle was replaced by AEM Forms). These

Language (XML) Forms Architecture (XFA) as they were designed to work specifically current AEM Forms Designer component within the AEM Forms software suite is designed to edit existing XFA forms and convert XFA forms into hypertext markup to continue to edit their existing inventory of XFA-based forms is required to ensure ess operations support for VA program offices delivering

Administrations and can only be done with Adobe AEM Forms.

VA Forms Managers have used the Adobe Acrobat Reader Extensions component, now bundled within the AEM Forms product suite, to share hundreds of PDF documents with Veterans and VA staff by extending the functionality of Acrobat Reader with additional usage rights. The additional usage rights activate features that are not usually available when a PDF document is opened using Adobe Acrobat Reader. Users do not require additional software or plug-ins to work with these rights-enabled documents. VA requires the continuation of Adobe AEM Forms to do the following: fill in form fields and save files locally including importing and exporting form data as Forms Data Format and XML;

addi, update or delete PDF Form fields and their properties; create pages in a PDF form from template pages; digitally sign and save PDF documents; remove digital signatures;

and create, modify and save document annotations and comments to and from a file and modify embedded file objects associated with the PDF document.

Additionally, only Adobe Acrobat Studio and all AEM Forms desktop software components are supported by third-party providers to extend their capabilities via plug-

Office and Acrobat Studio (previously Adobe

Acrobat Pro) software interfacing with the CommonLook (by Allyant) PDF component documents to current Web Content Access Guideline s 2.1 specifications, which are required to address regulations mandated by Section 508 (29 U.S.C. 794d) of the Rehabilitation Act. Specifically, these functionalities that are unique to Adobe allow for the creation of PDF documents that are fully accessible to assist Veterans and employees with disabilities such as mobility impairments, blindness, and low vision.

Adobe Acrobat Studio is an application that can create and edit a PDF document to make it accessible. It has a number of tools for evaluating and repairing the accessibility of PDF files, including access to the structure root through the tags panel, the ability to directly manipulate the reading order through the order panel, a built-in accessibility checker, and the Touch Up Reading Order tool which provides a graphical mechanism for assessing and repairing the accessibility of a PDF document.

In addition, Adobe Experience Manager (AEM) Forms is required to meet Section 508

AEM Forms provides native capabilities for generating properly structured, tagged, and keyboard-navigable form fields, ensuring that form content can be read, completed, and submitted by users with disabilities. AEM Forms is also the only platform capable of

XML Forms Architecture (XFA), which cannot be fully preserved, rendered, or remediated to Section 508 standards by non-Adobe tools. These capabilities are essential for ensuring that all VA-issued digital forms remain accessible to Veterans and employees with disabilities and compliant with WCAG 2.1 and Section 508 requirements.

s the ability to open, edit, and maintain also maintain the ability to apply Reader enabled usage rights so that Veterans and staff using the free Acrobat Reader application can fill forms, digitally sign them, comment, save completed forms, and exchange form data in XML or FDF (Forms Data Format) formats. These capabilities are fundament facing forms workflows and are made possible only through Adobe technologies. No other product available on the commercial market can natively edit or regenerate XFA based form templates, nor can any non Adobe product legally or technically apply Reader Extensions usage rights, as this functionality depends on Adobe controlled cryptographic mechanisms.

The Government also needs to manage (i.e., view, create, edit, review, comment, sign, send, print) and collaborate using PDF documents on any device. VA requires Adobe Acrobat Studio to be capable of being installed on both Windows-based and Mac-based devices, as well as Android, iPhone and iPad devices. Some alternative can come close to meeting our requirements from a PDF perspective. However, it is the ability to work

Additionally, only Adobe or its authorized resellers can provide the necessary maintenance and technical support of Adobe products as they are the only suppliers of Adobe software updates (including all version updates and bug fixes) and technical to requirements of ensuring the software remains operational. These services require of which are available to any third-party provider. No other source can legally or technically maintain these products in an operational and secure state. Renewal of the current software maintenance and support is required to ensure continuity of maintenance and support for the existing Adobe software products. Failure to acquire these maintenance administrative, clinical, and operational functions that rely on Adobe products which would ultimately impact the timely delivery of services and information to Veterans who depend on accessible, accurate, and fully functional digital documents and forms.

6. Efforts to Obtain Competition: Market research was conducted, details of which are in Section 8 of this document. This effort did not yield any additional sources that could meet the Government s requirements. However, the undersigned VA technical representative determined that limited competition is available among authorized resellers for brand name Adobe Acrobat Studio and AEM Forms licenses, as well as software maintenance and support. In accordance with RFO VA Deviation 16.507- 7(c)(ii) this justification shall be posted with the solicitation to all appropriate NASA SEWP GWAC holders.

7. Actions to Increase Competition: In order to remove or overcome any barriers to competition in future acquisitions for this requirement, VA will continue to conduct market research to identify other PDF applications that are capable of meeting all of the and consider these products for future requirements. Furthermore, VA will continue to monitor software recommendations/approvals issued by the Section 508 Program Office.

8. Market Research:

2025 and 2026 to determine whether any other brand name products could meet the full research existing form lifecycle environment, accessibility and Section 508 remediation workflows, enterprise PDF indexing capabilities, and the specialized form technologies already in production across VHA, VBA, and NCA. The review was conducted with the objective of ensuring continuity of operations, preserving existing form inventories, and meeting accessibility obligations without loss of functionality.

VA evaluated several named alternative vendors as part of this research, including Foxit PDF Editor, Nitro PDF Pro, Bluebeam Revu, and PDF XChange Editor. None were

Studio requirements.

These products were unable to natively handle XFA forms, lacked any ability to apply Reader Extensions, and could not host or replicate the CommonLook accessibility plug in. Competitors typically convert XFA forms to flattened or standard PDF formats, The research also found that VA relies on Acrobat Studio to support PDF editing, accessibility remediation, structural tag correction, reading order repair, and Section toolset, which functions as a plug in that operates exclusively within Adobe Acrobat Studio. The plug in cannot run in any other PDF editor, and alternative editors cannot replicate the combined functionality of Acrobat and CommonLook that VA uses to produce compliant documents.

To validate market availability, a Request for Information was posted on NASA SEWP V from March 16, 2026 through April 1, 2026. Six SEWP contract holders responded with quotes demonstrating their ability to provide Adobe Acrobat Studio and AEM Forms licenses and maintenance and support. The responses confirmed that multiple authorized resellers exist for limited competitive sourcing of Adobe products.

These vendors were also reviewed to determine their ability to provide the maintenance and support portion of the requirement but due to the proprietary data or code, they do not have access to provide the maintenance and support required. Adobe and their authorized resellers are the only ones with access to the proprietary data and code and therefore no other vendor is able to provide the maintenance and support.

In conclusion, the market research demonstrated that Adobe and/or its authorized resellers are the only vendors and Acrobat Studio, including XFA form editing, Reader enabled form distribution and Section 508 remediation using CommonLook. Adequate competition exists among authorized NASA SEWP resellers for brand name Adobe software license subscriptions with maintenance and support.

9. Other Facts: N/A

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.

Barry Ausmus Date Project Manager End User Services

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 limited competition. Additionally, NASA SEWP V has already determined prices on contract to be fair and reasonable and more competitive pricing may result from competition. Finally, the successful quote will be compared with the Independent Government Cost Estimate.

Kathryn Pantages Date Contracting Officer

Contracting Officer Certification

I certify that this justification is accurate and complete to the best of my knowledge and belief.

Kathryn Pantages Date Contracting Officer

Office of General Counsel (OGC) Review I have reviewed this document and find it legally sufficient, based on the representations set forth in the documents and, if any, attachments. The approval is an independently supported decision not wholly reliant on the legal sufficiency determination.

Tara Nash Date Office of General Counsel

Advocate for Competition Approval In my role as procuring activity Advocate for Competition, based on the foregoing justification, I hereby approve the acquisition of brand name Adobe Acrobat Studio software licenses and renewal of Adobe Experience Manager (AEM) Forms software licenses, including maintenance and support on an other than fair opportunity basis pursuant to the authority cited in Section 4 above, subject to availability of funds, and provide that the property and services herein described have otherwise been authorized for acquisition.

Jason Bullen Date

Advocate for Competition Technology Acquisition Center