JA PALANTIR Final - signed_Redacted.pdf

Palantir Gotham Analytics SaaS Control Number

VA-20-00091051

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 six month 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 the continued use of the brand name Palantir Gotham Software as a Service (SaaS) subscription to continue addressing the Coronavirus Disease 2019 (COVID-19) response of VA. The subscription shall include hosting, operational support, professional services, and maintenance.

3. Description of the Supplies or Services: The Veterans Health Administration (VHA) has a current need for continuation of the Palantir SaaS data management and operational decision support platform to assist with VA’s ongoing COVID-19 response. The current solution enables ingestion and analysis of unstructured and disaggregated data from a wide variety of sources and formats and is actively supporting VHA in its pandemic response and required related activity. The platform has been deployed, is in use by VA management analysts, data analysts, data managers, data engineers, and data scientists. The platform implementation - including user, use case, data protection, interoperability, security and technical configurations is enabling a full operational decision-making capability that VHA relies upon today.

The pandemic-related data management and operational decision-support requirements have led the program office to determine that the Palantir data management and analytics platform is the only viable solution that would maintain the current operational capability, without a degradation in VHA COVID-19 decision-support.

VHA, in partnership with the Office of Enterprise Integration (OEI), is seeking to continue use of this tool primarily to conduct analysis of data as it relates to effective and efficient delivery of VA products and services and assessments of risks and issues that have a current or potential nexus to VA’s COVID-19 planning, preparedness and response.

VA is continuing to develop and refine a more comprehensive data analytics and data management requirements package. This six month extension will allow VA to continue to address its immediate COVID-19 needs while increasing its knowledge base in that area to subsequently further refine and incorporate related requirements into the planned competitive procurement. Data management and operational decision support requirements were identified and developed over the past months of responding to the COVID-19 pandemic and were immediately generalized, enhanced, and validated in partnership with the VA Chief Data Officer, the Data Governance Council, and the Office of Information and Technology (OIT). Further expansion of these requirements will enable OIT to improve its understanding of capability gaps and put in place requisite data infrastructure, data management, and analytic capabilities.

The period of performance for the proposed action shall be six-months from date of award. The total estimated price is

4. 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.”

5. Rationale Supporting Use of Authority Cited Above: The proposed source for this action is i3 Federal LLC. (i3), 12030 Henderson Rd, Clifton, VA 20124. i3 is a Veteran Information Pages verified Service-Disabled Veteran Owned Small Business (SDVOSB). i3 has previously provided supplies and services for VA and has proven that it has the necessary capabilities to meet all the Government's requirements. Palantir has affirmed that i3 is the only authorized reseller of this product. Considering the above, the Government's technical experts have determined that i3 can meet all the Government's requirements and is considered a responsible SDVOSB.

Any interruption to the current cloud-hosted SaaS data integration and analytic platform would jeopardize VHA’s ability to continue tracking and analyzing COVID-19 outbreak areas and make enhanced, timely responses, with further insight into supply chain capacity, hospital inventory, individual-level clinical and caregiver needs and risks, vaccine requirements and distribution, social service utilization, lab diagnostics fraud, waste, and abuse, and operational decision-support requirements.

VA requires continuation of the current solution which is ingesting data from a wide variety of sources and formats and enabling government personnel to analyze unstructured and disaggregated data. The Palantir SaaS solution has been configured and is enabling continued automation of a clear, integrated and near-real time view of VA’s COVID-19 total care capacity. The platform is currently populated with patient-level health record information, hospital capacity data, supply chain data for critical medical supplies and medical equipment, diagnostic testing data, Center for Disease Control and Prevention COVID-19 tracking data, Veterans population data, VA health care enrollee data, and business, financial and budget data associated with the development, production, and delivery of products and services. The single integrated platform enables capture, curation, integration, storage, search, sharing, transfer, deconfliction, analysis, and visualization of large amounts of disparate structured and unstructured data from a wide variety of internal and external sources.

Finally, the single integrated platform supports architectural interoperability with existing VA data and analytics capabilities enabling ease of import and export of data, meta-data and administrative data, and code transformations within the VA data and analytics ecosystem.

A Request for Information (RFI) was issued on September 1, 2020. None of the vendors represented an existing, VA-deployed system that could provide an operational, integrated capability that could immediately replicate the Palantir SaaS platform capabilities. Based on the RFI responses, it was determined that Palantir is the only vendor that can meet the Agency's immediate COVID-19 related requirements. This is due to the urgent nature of the requirement and pandemic response. It is exacerbated by the demonstrated minimum timelines for VA to rapidly integrate, secure and configure SaaS data management and operational decision support capability; and demonstrated VA change management issues with people and processes to support deployment of data management and operational decision support capabilities. However, the Agency determined that several contractors possessed general data management capabilities and should therefore be able to participate in the Agency's plan for a more comprehensive competitive procurement to follow. OIT has substantial momentum towards modernizing data management and operational decision support infrastructures and capabilities and is poised to leverage the same validated and vetted requirements to crystalize and move towards closing capability gaps.

Currently, the data systems supporting the VHA are fragmented, having evolved over decades with different semantics and data definitions in various instances and systems. In many cases, these systems also rely on manual entry of information outside of normal technology support for established business (i.e., tracking consumables). Further, current data systems are organized around transactions (e.g., admissions, hospital bed use) and not around Veterans, making person-centered and population health management labor-intensive and difficult. With the onset of the COVID-19 pandemic, these gaps have acuminated and become critical. To keep Veterans safe and fulfill VA’s 4th Mission obligations to the Nation, the enterprise must move with optimal agility and accuracy.

Data management and curation by VHA’s expert analysts, at scale, with interoperability, is vital to current operations and will necessarily underpin any future technology. With that management and curation, Department-wide engagement, and ability for existing VHA staff to onboard and use the capabilities of the Palantir platform, VHA has realized the ability to address the aforementioned gaps: link disparate data silos to generate meaningful personalized and cohorted information for rapid decision cycles amidst the pandemic.

VHA intends, with Department partners, to proceed to competitive acquisition in alignment with the VA Data Strategy and Roadmap in the near term, but cannot afford a break in service and a loss of current capability. As far as VHA is aware, there is no existing alternative, or set of alternatives, to meet VA requirements at this time.

Although a large number of data analytics environments and tools exist within the VA enterprise, OIT has confirmed that current capabilities are not positioned to meet stated requirements within the immediate period of performance. The Palantir SaaS solution represents a fully integrated, commercial capability.

OIT has agreed to a thorough review of current and organically in-flight data management and operational decision support capabilities to better understand required capabilities, identify gaps and more fully support VHA and enterprise-level requirements to publicize the competitive acquisition across industry. This includes early and primary focus on interoperability requirements.

VHA and OEI, as a by-product of the initial effort, developed an important understanding of VHA data management operational decision support requirements. This understanding will allow for continued refinement, development and validation of VHA and VA enterprise requirements, including strengthening integration of OIT into the way forward. The way forward includes scaling data management and operational decision support in the anticipated period of performance, which is in flight now, further strengthening requirements;

integrating the VA enterprise perspective beyond VHA; and putting these capability requirements in context to a systematic and strategy-driven view of data and analytics at VA including current capabilities and approach to rationalizing the Data and Analytics product line and investments.

The use of any other SaaS solution would require any other source to deploy, install, configure, and test; and, government personnel will require training to develop proficiency. Moreover, VA OIT will be required to identify data connection location, methodology for connecting data sources and securing data.

In the previous effort, the Department’s fragmented Information Technology infrastructure, data stove-piping, and relative data management immaturity presented a series of challenges that complicated this objective: (a) OIT determination and decision on the location of data connector and virtual machine took two months; (b) data and operations were not centralized, identifying data sources and sifting thru the myriad of data source options, with an incomplete inventory of data systems and data sets available, their provenance and lineage, and underlying data transformation methods being applied significantly delayed a full operational capability; (c) process and technology change management resistance delayed active resolution of data connection and data transfers and

(d) VA’s security approval protocols and processes for SaaS were in a state of transformation, further exacerbating the timeliness of achieving capability deployment. Additionally, currently produced COVID-19 reports, analytics, and visualizations will have to be developed and configured in the alternative platform. Together, the instantiation of an alternate solution would take several months following contract award during which time the VA leadership would be without a decision-support platform and will be unable to use data and analytics to inform the response to COVID-19.

Any interruption in the availability of the cloud-hosted SaaS data integration and analytic platform would jeopardize VHA’s ability to track and analyze COVID-19 outbreak areas and make timely decisions with insight into supply chain capacity, hospital inventory, social service utilization, and lab diagnostics. The Palantir SaaS capability is currently deployed and in use, it offers a unique and immediate ability for VHA to automate a clearer, integrated, immediate sense of VA’s COVID-19 total care capacity: supply and demand for relevant equipment and supplies on-hand at hospitals, national COVID-19 case data, and projected national and regional COVID-19 demand. Without the Palantir SaaS capability, VHA would have delayed access to information and analysis of COVID-19 demand and would be unable to continue to proactively manage the shifts in care capacity and medical supplies as the regional effects of the outbreak manifest heterogeneously. The results will be untimely coordination of care; shortage of medical supplies and personal protective equipment, and insufficient availability of service providers at the right facility at the right time to manage the geographical shift in COVID-19 outbreaks that could significantly impact patient safety.

Any interruption in the operational decision support capability that has been developed will have detrimental effects on VA, Veterans, the patients VA serves, and the US population as a whole due to VA’s inability (or prevention of VA’s ability) to detect, treat, track detection and recovery rates, and make decisions that can decrease the coronavirus and COVID-19 infection rate of the United States population.

6. Efforts to Obtain Competition: Market research was conducted, details of which are in section 8 of this justification. The Palantir data management and analytics platform is the only viable solution that would maintain the current operational capability, without a degradation in VHA COVID-19 decision-support.

7. Actions to Increase Competition: The Government anticipates issuance of a Request for Proposal in support of long-term comprehensive SaaS-based data management, decision support, and analytics effort. Market research and solution evaluation methods are being considered. The government anticipates a mid FY21 award(s) for a comprehensive long-term SaaS effort.

8. Market Research: The Government’s technical experts conducted market research in March 2020 through August 2020 to determine products that met VA’s current COVID-19 response efforts. Over several months the Government identified significant challenges with the VA data management and operational decision support infrastructure and capabilities that negatively impacted the timeframe for the establishment of a fully operational decision-support capability.

The Palantir Gotham SaaS solution is necessary for the continuation of analytic and decision support for VA’s medical response to the pandemic. To that end, VA examined the 26 RFI responses for data analytics tools and services submitted in response to the RFI that was issued on September 1, 2020 and closed on September 11, 2020. Submissions were received from Accenture, Microsoft, C3, Databricks, Praescient, Cloudera, MicroStrategy, SAS, Booz- Allen, Deloitte, Intersystems, Inquisient, CloudLeap, Esri, Semantic AI, Perspecta, Solix, Snowflake, Cambridge, Software AG, Guidehouse, Stardog, Three Wire, Spica Systems, Culmen, and RV Global.

Additionally, VA is also considering the capabilities currently available in the VA environment. VA has identified 43 current data and analytics platforms and over 500 products that are being evaluated in addition to the COTS products put forward through the RFI that was issued for the current requirements. It is VA’s intention to deliberately review its’ requirements and develop a phased acquisition strategy to most effectively and efficiently satisfy the strategic, operational and technical data and analytics requirements. A platform shift now would result in a delay in the assessment and impose significant risk to meeting operational requirements associated with VA’s COVID-19 planning, preparedness and response.

In the course of this review, and based upon prior experience, the Government determined that none of the competitor products could provide a COTS solution that could maintain, without interruption, the ability for VA analysts to capture, curate, integrate, store, search, share, transfer, perform deconfliction, analyze, and visualize large amounts of disparate structured and unstructured data from a wide variety of internal and external sources. The COVID-19 pandemic does not have a concrete end date, so VA’s requirements related to the pandemic are extremely fluid. At the time the current SaaS solution order was awarded, VA was unsure that it would require the Palantir’s solution functionality past the period of performance end date of November 7, 2020. As the pandemic continued, and it was clear the functionality would be required past the November 7, 2020 completion date, VA began to draft long term requirements to allow for a competitive SaaS solution. Based on the identified VA data management and data analytics challenges, the government will pursue solutions that support the enterprise data management and data analytics requirements, in addition to the potential need for continued pandemic-type decision-support. As of today, the long-term requirements are being developed and refined and VA plans to issue an RFI in the late 2020 timeframe. A platform shift at this time would eliminate VA’s COVID-19 analytic and decision support capability for an unacceptable delay and increase VA’s operational risk in addressing the COVID- 19 pandemic needs.

In conclusion, VA intends on issuing a competitive solicitation for a long-term SaaS solution prior to expiration of the Palantir SaaS solution contract. The solicitation will be based on a full review of data and analytics capability requirements, through the lens of VA’s operational needs.

Additional market research conducted in September 2020 indicates that there are three small business resellers currently listed on the NASA SEWP GWAC that offer the required Palantir products and services. However, a letter from the OEM confirms that except for ordering from Palantir directly, only i3 is authorized to sell their products and services. A Search of the Veteran Information Pages in September 2020 confirmed that i3 is a verified Service-Disabled Veteran-Owned Small Business. Also, a search of the System for Award Management confirmed that i3 is approved for award with no active exclusions. The Government determined that in the interests of putting this order in place to continue assisting VA in responding to the COVID-19 pandemic, as well as maximizing the utilization of SDVOSBs, VA intends to award the order to i3 under its NASA

SEWP GWAC.

9. Other Facts: none

10. Technical and 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.

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11. Determination of Best Value: I hereby determine that the anticipated price to the Government for this contract action will be fair and reasonable based on catalog prices for products awarded on NASA SEWP V GWAC contracts which have already been determined to be fair and reasonable. Additionally, price competition is expected among resellers for this action. Finally, the quote shall be compared to the Independent Government Cost Estimate to assist in ensuring price reasonableness.

Date: ____________ Signature:

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

Date: ____________ Signature:

110326

Paul 3342631

Approval

In my role as procuring activity Advocate for Competition, based on the foregoing justification, I hereby approve the acquisition of brand name Palantir Gotham SaaS solution on an other than fair opportunity basis pursuant to the authority cited in paragraph 4 above, subject to availability of funds, and provided that the services herein described have otherwise been authorized for acquisition.

Date: ____________ Signatur

JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY

Coordination Matrix