JA - VA Police Records Management System _Redacted.pdf

VA Police Cloud Record Management System (RMS) Implementation Control Number VA-23-00071616 currently utilizes Axon’s DEMS SaaS suite which includes body worn cameras, unlimited data storage and user licenses. Moveover, Axon’s DEMS solution includes a FedRAMP high assurance level cloud platform, storage solution, and software licenses for a customized RMS solution to support the body worn camera hardware.

As such, under this effort, VA only requires professional services to build the forms, dashboards, and user features of the RMS in the existing platform. Axon Cloud Suite is a closed system, and third-party contractors or vendors cannot perform any tasks within the environment. Any other proposed RMS solution that is engineered and designed outside of the current Axon DEMS platform would require Axon personnel to perform the engineering and implementation which would greatly increase the costs since Axon’s software is proprietary, and can only be deployed and maintained by Axon personnel. Axon does not authorize third parties to access the Axon RMS system. The implementation to include configuration and customization of the RMS must be completed by Axon personnel, and cannot be contracted to another vendor because Axon does not permit third party access to the platform.

VHA Police currently utilize a stand-alone police reporting system contracted by the VA Law Enforcement Training Center; however, the product is not FedRAMP complaint. Cloud-based storage requires FedRamp certification and a VA Provisional or Full Authority to Operate (P-ATO/ATO) to accept/store/transmit VA data. VA currently utlizes Axon for a complete cloud-based solution which includes evidence.com (video and evidence storage), standards (Internal Affairs metrics and reporting), and RMS. The RMS portion will include all VA Police reporting on daily police activities, crimes, and incidents, and National Incident-Based Reporting System (NIBRS) compliance. NIBRS compliance is essential, and the data must be transmitted and reported to the Department of Justice. In October 2022, Axon was approved for a P-ATO at the high assurance level from VA. Axon already acquired a Joint Authorization Board (JAB) ATO for FedRAMP, a process that can take a considerable amount of time, often 12 to 24 months. If another vendor was selected that needed to acquire FedRAMP Provisional/Authority to operate, the delay to VA would result in not having records services when the current RMS contract expires in September 2023.

If VA were to purchase another solution, it would require the purchase of additional user licenses and storage, duplicating the cost to VA of these items. The storage and licenses costs that would normally be required for this action are already included in another contract that where VA initially acquired the DEMS solution and body worn camera hardware. The procurement of another solution would require another purchase of product licenses, configuration, and storage. An off-the-shelf police software solution without customization would not capture VA’s unique data requirements which include wellness check/rescues, Veterans Response Team use, and other situations unique to VA and its mission. The RMS design is critical to public safety in VA facilities, and linking the existing components such as video and evidence storage as well as Internal Affairs metrics and reporting creates critical links in data within the Axon system that ensures high reliability in law enforcement and security services. There is no other solution that will allow VA to fully realize the benefits of the existing platform. Based on market research it was determined that only Axon can configure and deploy the Axon RMS that integrates fully and completely with the body worn camera solution which captures all evidence and video footage from police incidents and packages and integrates all data relevant to an incident in one file on the Axon FedRAMP cloud, providing a single point of entry and access for VA Police Officers to their incidents.

Axon’s RMS solution includes the ability to securely send one link to VA’s federal partners (OIG, US Attorney’s Office, FBI) that contains all relevant case information. It also allows VA to receive evidence from outside parties electronically (videos, documents, pictures) through Axon Citizen, automatically including the items in the existing case file. Any other vendor solution would require engineering, mapping and production outside of the environment and therefore, greatly increase the time and cost of implementing an RMS that meets VA’s requirements. VHA has been using evidence.com and standards since October 2022, and the RMS portion is necessary to ensure that complete and accurate data related to security and safety is integrated and easily accessible. If another police reporting system is used, there will be unacceptable gaps in data aggregation that creates delays in identifying real and credible risk to VA’s people and resources.

6. Efforts to Obtain Competition: Market research was conducted, details of which are in Section 8 of this justification. This effort did not yield any additional sources that can meet the Government's requirements. There is no competition anticipated for this acquisition. Additionally, the proposed action will be synopsized on the Contracting Opportunities Page in accordance with FAR 5.201. Any proposals that are received shall be evaluated.

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. VHA Police will continue to research and monitor whether there are emerging products that enter the marketplace that are interoperable and compatible with the Axon platform.

8. Market Research: Market research was conducted by VA technical experts between March 2023 and July 2023, by researching similar products via internet catalog research and reviews such as those from NicheRM365 and Mark 43 On Scene. Based on this analysis, the VA technical experts determined that no other software would be able to integrate with the currently fielded systems licenses due to proprietary constraints within the software and its integration with the current RMS.

Additionally, no other vendors can provide the required software required to interface with Axon suite of cloud-based services. VA technical experts reviewed similar products from alternative vendors including those from NicheRM365 and Mark 43 On Scene, SOMA Records Management, and Capers North America to determine whether any other sources can provide RMS within the VA existing cloud infrastructure. After review, it was determined that no other vendor can provide the required services to fully implement the single point of entry police record solution.

Any other solution would require multiple applications the officer would have to log into, in order to access all data, evidence, and documentation associated with the case, including body worn camera video.

In addition, on July 10, 2023, Request of Information (RFI) 36C10B23Q0421 was issued and published on Contract Opportunities to conduct further market research.

The RFI closed on July 14, 2023, with responses received from eight vendors. The RFI provided a description of the work required for the project, and requested information to include company contact information, size, FedRAMP status, business size and clarity of the proposed draft PWS. The technical team reviewed the described capabilities, FedRAMP status, and whether the respondent indicated it could meet the subcontracting limitations required for a small business or SDVOSB set-aside and provided a technical analysis of each RFI response on July 24, 2023.

None of the respondents demonstrated FedRAMP certification, or an ability to work with VA’s existing proprietary platform, except for Axon Enterprises Inc. All vendor capabilities and discussed solutions require engineering, mapping and production outside of the current environment. These approaches increase the time and cost of implementing an RMS that meets VA’s requirements of single-entry point RMS and FedRAMP high assurance. There would be no anticipated competition among small businesses that would meet all of the requirements.

Following the evaluation of RFI responses, all respondents were notified of the areas in which their response did not meet VA’s technical requirements. To date, no respondent has objected to VA’s technical assessment.

Based on this market research, only Axon can meet VA technical requirements.

Therefore, no alternative vendor can avoid the duplication of effort and time as detailed in Section 5 of this justification.

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.

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 a price analysis performed by comparing the successful quote to the Independent Government Cost Estimate.

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

Approval

In my role as procuring activity Advocate for Competition, based on the foregoing justification, I hereby approve the acquisition of Record Management System Implementation, on an other than full and open competition basis pursuant to the statutory 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.