JA_PIV_Redacted 02.docx

Control Number: VA-22-00014325 PIV Card Readers and Installation Services Control Number: VA-22-00014325

JUSTIFICATION FOR EXCEPTION TO FAIR OPPORTUNITY

2. Description of Action: The proposed action is for a Firm-Fixed-Price (FFP) Delivery Order (DO) issued as a small business set-aside under the General Services Administration (GSA) Multiple Award Schedule (MAS) category 541519PIV, “Homeland Security Presidential Directive 12 Product and Service Components,” for brand name Lenel 4220 Door Equipment, Physical Access Control System (PACS) installation services, and HID RPK40 card readers.

3. Description of Supplies or Services: The Department of Veterans Affairs (VA), Office of Information and Technology Resource Management (ITRM) has a brand name requirement to procure and install nine (9) PIV card readers that are network compatible to provide easy access to the nine communication closets located at 801 Eye Street NW, Washington, District of Columbia. The server room and communication closets provide network connectivity to employees and require 24/7 access. The VA National Capital Region (NCR) Veterans Affairs Central Office (VACO) campus crosses four (4) different state jurisdictions including Washington D.C., Maryland, Virginia, and West Virginia. The VACO campus consists of eleven (11) buildings, and these buildings all have active access control systems. Through renovations, the security functions within the overall system are currently being expanded to cover newly renovated spaces. To maintain compatibility with the existing security system requires that all newly procured communication closets be interoperable with the current security/maintenance requirements. Overall, the PIV card readers will eliminate the need to have a separate means to access closets while also providing all employees with easy access, system compatibility, and interoperability. The Period of Performance (PoP) shall be 12 months from date of award. The total estimated value of the proposed action is $____________.

4. Statutory Authority: This acquisition is conducted under the authority of the Multiple-Award Schedule Program. The specific authority providing for a limited source award is Federal Acquisition Regulation (FAR) 8.405-6(b), “Items peculiar to one manufacturer. An item peculiar to one manufacturer can be a particular brand name, product, or a feature of a product, peculiar to one manufacturer). A brand name item, whether available on one or more schedule contracts, is an item peculiar to one manufacturer.”

5. Rationale Supporting Use of Authority Cited Above: Based on the market research, as described in Section 8 of this document, it has been determined that limited competition is available among resellers for the required Lenel 4220 Door Equipment hardware, PACS installation services, and HID RPK40 card readers. ITRM requires all security hardware to integrate into a seamless interface. Additionally, only the Lenel Door Equipment, PACS installation services, and HID RPK40 brand name items and hardware meet all of VA’s requirements, specifically in terms of compatibility and interoperability with VA’s existing security infrastructure systems. Without access to these specific brand name hardware and installation services, the card readers would not be properly configured to the existing VA infrastructure and would render the hardware inoperable and unmaintainable. Procuring a new product, rather than acquiring additional Lenel Door Equipment, HID RPK40 card readers, and installation services, would result in duplicated costs required to implement integration across multiple buildings. VA requires security hardware and systems to be immediately interoperable and compatible with the current infrastructure protocols and functionality for continued security. Other commercial off-the-shelf card reader products are not designed to integrate into a seamless interface with Lenel Door Equipment and HID RPK40 card readers. If the Lenel 4220 Door Equipment and HID RPK40 card readers were abandoned in favor of a different product, VA would need to purchase additional hardware, installation software, and create a new infrastructure to support the new products across numerous buildings.

In reference to the installation services requirement, PACS is a proprietary system that requires a Value-Added Reseller (VAR) to be assigned by the original equipment manufacturer (OEM) to be eligible for technical support access, software licenses, and OEM component/hardware. The VAR is also required to be listed by the client as an authorized reseller, and it is recommended by the OEM that only one VAR be responsible for licenses per organization and/or agency. Based on reviews of the procurement history for this requirement, most companies that offer the required products were not listed by the OEM as authorized resellers. As a result, certain security projects were delayed while the incumbent contractor sought to obtain products and services from a third-party which postponed deadlines and created additional cost increases.

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, and there is no competition anticipated for this acquisition. In accordance with FAR 6.302-1(c)(1)(ii)(c) and 5.102, this justification shall be made publicly available on the Contract Opportunities website at beta.sam.gov 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 fully competed.

8. Market Research: Market research was conducted in December 2021 to ascertain if any other source could satisfy VA’s requirements. Specifically, VA’s ITRM technical experts looked at hardware and installation support services from other providers such as Paxton Inc. and Computech International. The market research confirmed that none of the other products could provide the compatibility and interoperability standards necessary to maintain the required support and configuration to the existing security infrastructure. Therefore, only brand name Lenel hardware and PACS installation services can meet VA’s requirements.

In November 2021, the Contract Specialist (CS) conducted market research by using the GSA eLibrary Market Research Tool to determine what vendors were capable of the requirement. Based on this market research, the CS did not find any Service-Disabled Veteran-Owned Small Businesses (SDVOSBs) or Veteran-Owned Small Businesses (VOSBs) listed as authorized resellers capable of meeting the full requirement; however, there were 28 small business contractors listed under GSA MAS category 541519PIV which greatly align with the requirements and include the contractor who previously completed the PACS installation services. Therefore, to promote award opportunity for small business concerns, VA intends to issue this effort under GSA MAS category 541519PIV, “Homeland Security Presidential Directive 12 Product and Service Components,” as a total small business set-aside.

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.

Date: ________________________________

Program Manager Signature: ____________________________

11. Fair and Reasonable Cost 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.

Date: ________________________________

Procuring Contracting Officer Signature: ____________________________

12. Procuring Contracting Officer Certification: I certify that this justification is accurate and complete to the best of my knowledge and belief. As this contract action exceeds the simplified acquisition threshold, but does not exceed $750,000, the certification 8.405-6(d)(1) serves as approval.

Date: ________________________________

Procuring Contracting Officer Signature: ____________________________