JA ORM IT Support PORTAL MODERNIZATION AND SYSTEM ENHANCEMENTS- Redacted -CS.pdf

PORTAL MODERNIZATION AND SYSTEM ENHANCEMENTS

CONTROL NUMBER VA-25-00059439

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 modification to Task Order (TO) Number 36C10B23N10340007 under Transformation Twenty-One Total Technology Next Generation (T4NG) Indefinite Delivery Indefinite Quantity Contract 36C10B21D1034 is a firm-fixed-price (FFP) action with Dexteritech Solutions LLC, intended to fully implement at a modern, Artificial Intelligence (AI)-enabled customer engagement portal, as well as substantive enhancements to the existing Equal Employment Opportunity (EEO) Ecosystem (E2).

3. Description of the Supplies or Services: The scope of the original order included maintenance, enhancements, and some automation within the existing E2 environment.

The total original TO value of $14,590,576.59 includes a 12-month base period, and four 12-month option periods. The contract is currently in Option Period 1. However, at the time of award, there was no specific provision to design or implement a public-facing portal for external complainants to electronically initiate contact or file complaints.

As part of ORM’s modernization strategy and in alignment with federal mandates to improve digital services and customer experience (e.g., Executive Order 14058), we are now seeking to modify the order to support additional developments to meet the mandates of the Executive Order. The justification for this addition is grounded in operational need, alignment with federal mandates for digital service delivery, and ORM’s ongoing commitment to improving the user experience for all stakeholders. The services provided under this modification involve the full development, integration, and deployment of mission-critical systems, by December 21, 2025, that directly support ORM’s operations and outreach to Veterans and employees. At the core of this effort is the delivery of a secure, scalable, and user-friendly customer portal that allows individuals to engage with ORM’s EEO and reasonable accommodation processes in a seamless digital environment. This portal will be equipped with AI features that include natural language processing, automated case categorization, and intelligent routing to streamline administrative processes, reduce response times, and improve user outcomes.

Simultaneously, the contractor will undertake significant enhancements to the existing RAMS and E2 platforms. While some foundational work related to RAMS and E2 was included under the original order such as routine maintenance, minor enhancements, and system sustainment the current need represents a shift toward deeper, more complex modernization efforts that were not previously scoped.

What was initially envisioned as maintenance and incremental updates has evolved due to increased demand, evolving federal mandates, and growing internal user expectations. To meet the requirements of the Executive Order requires greater technical depth, more specialized configurations, and sustained development support to

Page 1 of conjunction with the current support being provided by Dexteritech without any system degradation. Awarding this work to a different contractor would introduce unnecessary delays, increase the risk of non-compliance, and make it highly unlikely that ORM could meet the mandated deadline set by the Deputy Secretary. This modification is critical to completing the added work within the required timeframe.

ORM has conducted thorough market research, which is detailed in Section 8 below, reviewed comparable federal IT modernization efforts, and held strategic consultations with Dexteritech Solutions LLC to validate their capacity for their ability to handle this modification. Moreover, the inclusion of AI and high-sensitivity case data requires that all development remain under the control of a team with validated VA security credentials, proven experience in secure cloud applications, and real-time access to ORM’s case management infrastructure. The expertise Dexteritech Solutions LLC is needed because of the historical knowledge that they have in ORM’s eco-system. Their deep institutional knowledge and current familiarity with ORM’s systems uniquely qualify them to continue this work without disruption.

An extended transition to a new vendor would introduce a steep learning curve, redundant discovery efforts, and a high probability of failure to deliver within the timeline required by the Deputy Secretary. This delay would directly undermine ORM’s ability to deploy the external complaints portal and complete critical enhancements to the E2 and RAMS platforms in a timely manner. Transitioning to a new contractor would require extensive onboarding efforts, including gaining system-level access, conducting in-depth discovery of ORM’s unique workflows, and re-establishing stakeholder relationships. Additionally, the incoming team would need to obtain the necessary security clearances, complete VA-specific training, and undergo Authority to Operate (ATO) reviews. Dexteritech has already completed these steps and is actively maintaining them under the current active order.

These transition barriers are not just administrative—they introduce substantial operational risk. The E2 platform is an enterprise case management system used nationally for EEO complaints and reasonable accommodation cases, many of which involve ongoing or pending litigation. Any disruption, data mismanagement, or system downtime during a transition could compromise case integrity, violate federal records management and privacy laws, and expose the agency to legal liability.

Dexteritech’s continued support is the only viable path forward to ensure uninterrupted service, compliance with legal obligations, and timely delivery of the modernization efforts tied to ORM’s strategic priorities.

Dexiteritech is the only vendor that can support this urgent requirement immediately as they are in place and already working under this order. This will allow ORM to maintain architectural and operational continuity while preserving security and compliance standards. It also allows for uninterrupted development and delivery of modernization outcomes that support VA’s broader mission.

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6. Efforts to Obtain Competition: Market research was conducted, details of which are in the market research section of this document. This effort did not yield any additional sources that can meet the Government’s requirements. There is no competition anticipated for this acquisition that can meet VA’s requirement within the mandated timeline. In accordance with FAR 5.301 and 16.505(b)(2)(ii)(D), the award notice for this action will be synopsized on the Federal Business Opportunities Page (FBO) and the 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 marketplace that would enable future actions to be competed. The original current order was competed when it was awarded.

The Government fully intends to compete the follow-on contract at the conclusion of the current order. Additionally, the Government will continue to conduct ongoing market research to monitor changes in the vendor landscape and ensure that future actions are structured to encourage full and open competition wherever possible.

8. Market Research

The Government technical Subject Matter Experts (SMEs) conducted targeted market research in June 2025 through web-based research and industry outreach to identify similar vendors that offer services in federal IT modernization, case management platforms, and digital intake solutions. As part of this research, vendors such as KGS, ManTech, and Prosphere were reviewed to assess their potential ability to meet ORM’s evolving needs.

While these vendors demonstrated technical competence and offered relevant tools, none could satisfy the full scope of interoperability, obtaining security clearance and transitioning to a new vendor in the middle of the active work being performed under the current order, within the required timeline. The time required to onboard a new contractor, familiarize them with ORM’s highly customized E2 and RAMS infrastructure, and ensure full alignment with internal governance, security, and business process standards would result in significant delays—estimated at several months. These delays would cause ORM to fail to meet the timeline mandated by recent Executive Orders and leadership priorities.

While the current order includes a standard transition-out clause intended to support continuity at the conclusion of the contract, it does not include any provisions for a midstream transition to a new vendor during ongoing development.

Establishing a new vendor relationship at this stage would involve reinitiating multiple foundational activities—such as gaining access to sensitive VA systems, obtaining security clearances, and replicating institutional knowledge—that Dexteritech has already acquired. Without this continuity, the agency would risk service disruptions, failed delivery of the external portal, and potential non-compliance with the requirements set forth by executive leadership. Such a delay would place the VA at operational and reputational risk, potentially affecting service continuity, compliance obligations, and the Department’s broader digital modernization goals.

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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 proposed prices from the Independent Government Cost Estimate (IGCE) and Market Research provided by the customer. Further price analysis will be conducted, and subsequent negotiations held as necessary.

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

Advocate for Competition Approval In my role as procuring activity Advocate for Competition, based on the foregoing justification, I hereby approve the modification to order # 36C10B23N10340007 on 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.