CONTROL NUMBER VA-26-00078164

Justification Template_FAR 8_(18-JAN-2024)

LIMITED-SOURCES JUSTIFICATION

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 12-month firm fixed-price modification. This effort is being conducted under the authority of the Multiple Award Schedule (MAS) Program. The proposed effort will be a modification awarded under the General Service Administration (GSA) to Task Order 36C10B24F0339 issued under Contract Number GS-35F-0343Y to BruckEdwards INC., 12355 Sunrise Valley Dr Suite 340, Reston, Virginia, 20191.

3. Description of the Supplies or Services: The proposed action is to provide a detailed requirements specification that documents VA’s Personal Identity Verification (PIV) credentialing requirements that will be transmitted to GSA, the agency in charge of USAccess. USAccess is a shared federal program managed by GSA that provides PIV credentialing services, background verification support, and badge issuance for over 100 federal agencies and their contractors. This effort will ensure that VA requirements are delivered (and validated) in the USAccess 2.0 Initial Operating Capability.

Contact/Task Order GS-35F-0343Y 36C10B24F0339 was competitively awarded on September 13, 2024 as a result of a solicitation under GSA MAS 541519ICAM in the total amount of $17,931,561.76. The period of performance for the base period was September 18, 2024 through September 17, 2025 followed by four 1-year option periods. The total estimated value of the proposed modification is $897,913.20, increasing the total to $18,829,474.96 .

4. Authority: This acquisition is conducted under the authority of the Multiple Award Schedule Program. The specific authority for limited source award is Federal Acquisition Regulation 8.401(b), which requires that when placing an order under the Federal Supply Schedule, agencies must follow the ordering procedures established by GSA and found at subpart 538.71 and GSA Acquisition Regulation 538.7104-3(b)(iii), “The order should be issued on a sole source basis in the interest of economy and efficiency because it is a logical follow-on to an FSS order already issued on a competitive basis.”

5. Rationale Supporting Use of Authority Cited Above: VA must deliver comprehensive business requirements to GSA in sufficient time for incorporation into the USAccess 2.0 design and development effort. GSA’s planned cutover to the new system is currently scheduled for March 2027. The window to develop technical data, specifications, and engineering descriptions for the redesigned PIV system is limited. Failure to provide detailed requirements to GSA prior to deployment would result in millions of dollars and significant time being spent to retrofit the system to VA’s needs, which could also endanger VA security and disrupt operations enterprise wide. BruckEdwards knows the current USAccess PIV system as it relates to VA’s unique perspective, the legacy PIV

Justification Template_FAR Part 8_(18-JAN-2024) system, and the current PIV workflows and constraints allowing them to start development of the requirements specification immediately. Another source would require substantial time for onboarding, discovery, and understanding of the broader USAccess system as well as associated costs onboarding and duplicating the knowledge BruckEdwards already possesses. There is limited time for a new team to acquire the necessary system knowledge and then produce the detailed specifications required for a new PIV solution. Attempting to do so would introduce significant risk and would almost certainly lead to failure, which would cost VA millions of dollars and months to tailor the USAccess 2.0 system. The proposed modification would allow VA to efficiently and economically acquire the services needed to develop the requirements specification and minimize risk to VA if GSA proceeds without VA input to USAccess 2.0.

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 could meet the Government’s requirements. There is no competition anticipated for this acquisition. In accordance with FAR 5.301 and 8.405-6(a)(2) the award notice for this action will be synopsized on the Contracting Opportunities website and this 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.

8. Market Research: Market research was conducted by the Office of Operations, Security, & Preparedness (OSP) in July 2026 via internet search and GSA EBuy. Six vendors were reviewed with relevant experience in Homeland Security Presidential Directive 12, which mandates a federal standard for secure and reliable forms of identification, as well as Identity, Credential and Access Management( professional services, requirements analysis, process documentation, stakeholder facilitation, and training: Electrosoft, Inc.; NuAxis LLC; Bruckedwards, Inc.; Dignari, LLC (now part of EY); Deloitte Consulting LLP; and XTec, Inc. These firms were evaluated against the urgent program need to produce a comprehensive VA-specific Business Requirements Document (BRD), use cases, process flows, and supporting training materials for integration with GSA’s USAccess 2.0 modernization

Under the current contract, BruckEdwards performs credential management, card issuance, enrollment, registration, sponsorship, and modernization services across more than 250 VA sites worldwide—directly supporting credentialing for up to 500,000 VA employees, contractors, and affiliates. Bruckedward Inc. possesses current, institutional knowledge of VA’s existing USAccess/PIV workflows, operational pain points, stakeholder landscape, and agency-specific constraints. BruckEdwards is familiar with the issues and problems of the current VA PIV system and has subject matter expertise in management analysis support services for the management of enterprise-level tasks and initiatives undertaken to plan, engineer, and implement information technology infrastructure improvement, and enhancements to support the

Justification Template_FAR Part 8_(18-JAN-2024)

VA’s mission for implementing enterprise-wide solutions for Credential Management

(HSPD-12).

GSA’s USAccess 2.0 prime contractor has been advancing the government-wide platform design since March 2026 and plans a cutover in March 2027. OSP requires BruckEdwards to provide Business Requirements Document (BRD), use cases, process flows, and supporting training materials for integration with GSA’s USAccess 2.0 modernization through September 2027.

Justification Template_FAR Part 8_(18-JAN-2024)

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.

Christopher Layton Date Director HSPD-12 & Credential Management Office of Operations, Security, & Preparedness (OSP)

Best Value Determination

I hereby determine that the proposed contract action will represent the best value to the Government consistent with FAR 8.404(d). GSA has already determined that the prices on the FSS contract are fair and reasonable. Further price analysis, to include an analysis of proposed level of effort and mix of labor, will be conducted and subsequent negotiations held as necessary. Additionally, price discounts will be sought.

Debra Clayton Date Contracting Officer Technology Acquisition Center Office of Procurement, Acquisition, and Logistics Department of Veterans Affairs

Contracting Officer Certification/Approval

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

Debra Clayton Date Contracting Officer Technology Acquisition Center Office of Procurement, Acquisition, and Logistics Department of Veterans Affairs