CUI//SP-PROCURE//FEDCON

Control Number:

Rustici Content Controller Software Support

June 2025

JUSTIFICATION REVIEW DOCUMENT

FAR Part 6 Justification and Approval for Other than Full and Open Competition

Program/Equipment: PEO Enterprise, Product Manager (PdM) Army Training Information System (ATIS)/ Rustici Content Controller Software Support Business Application Software (Perpetual License Software)

Authority: Title 10 United States Code (U.S.C.) §3204(a)(1) as implemented in Federal Acquisition Regulation (FAR) 6.302-1(a)(2)(iii)(A), Substantial duplication of cost to the Government that is not expected to be recovered through competition.

Amount:

Prepared by: Michelle J. Goodson Phone: 520-687-6493 ALCMC Lead Date: 5 December 2025 Michelle.j.goodson2.civ@army.mil

Contracting Officer: Leslie M. Dickson Phone: 520-693-1333

Contracting Officer Date: 5 January 2026 E-mail: leslie.m.dickson2.civ@army.mil

Technical:

Requirements:

Controlled by: United States Army Controlled by: ACC-RI CUI Category: PROCURE Distribution Statement or LDC: FEDCON POC: Kevin MacLuskie, kevin.r.macluskie.civ@army.mil

Control Number: JA-26-Rock Island/EIS-0117

June 2025

Reviews: I have reviewed this justification and find it adequate to support other than full and open competition.

Program Manager/Program Executive Officer:

Legal Counsel:

CUI//SP-PROCURE//FEDCON

b. Alternatives: There are currently no other alternatives to the Rustici Content Control. There are no SCORM content controllers besides Rustici Content Controller that are available on the market as an addon or plugin to Moodle to support the SCORM 2004 playability requirement.

c. Impact if not approved: The Rustici Content Controller is deeply integrated into the ATIS Learning environment, which is the system of record for delivering mandatory training content. A transition to an alternative solution would cause significant disruption and unacceptable delays in mission-critical training for the entire force. Any new tool would require a lengthy period for procurement, integration, testing, and migration of thousands of hours of existing SCORM 2004-compliant courses.

These circumstances are not the result of a lack of planning but are due to the existing and continuous requirement to provide uninterrupted access to essential training materials for all Army personnel.

Replacing this single-product solution with multiple products would require re-engineering of ATIS and would create a gap in access to key systems that provide mandatory training to and impact mission ntified as the only solution on the market that could meet our needs without negative impact on the mission.

7. Efforts to Obtain Competition:

a. Effective competition: Request for Quote 544815 Request for Information 542312 was placed on CHESS 08/18/2025. No pricing received from vendors. The Statement of Non-Availability (SONA) number was approved on 1 ACC-RI released a Sources Sought notice on SAM.gov between January 27 and January 29, 2026 but received no responses from industry.

8. Actions to Increase Competition:

Market Research was conducted in accordance with (IAW) Federal Acquisition Regulation (FAR) Part 10 During the period of .

The market research included refinement of the requirement using industry standard terminology, assessment of potential commercial solutions, and an evaluation of opportunities to increase competition and small business participation. The results of the market research confirmed that Rustici Content Controller is the only commercially available solution capable of meeting the A SCORM 2004 Content Management and playability requirements within the existing ATIS learning technical environment.

The mandatory CHESS ITES-SW2 contract vehicle was evaluated as part of the market research process and determined not to be suitable for fulfilling this requirement.

PDM ATIS has identified and will pursue actions intended to increase competition for future acquisitions of learning content management capabilities. These actions are focused on removing structural and policy-based barriers that currently limit competition and are outside the control of the requiring activity for the instant procurement.

PdM ATIS will continue to conduct ongoing market research in accordance with FAR Part 10 to monitor advancements in learning management technologies, content interoperability standards, and commercial solutions that may reduce dependency on proprietary content controllers. Market research efforts will include engagement with industry, assessment of emerging standards, and evaluation of solutions that may integrate with or replace existing ATIS learning architecture without disruption to mission critical training delivery.

10. Interested Sources: To date, no other sources have written to express an interest in this requirement.

11. Other Facts:

a. Procurement history.

b. Other facts. There are not any other vendors or partners that can meet this requirement. ATIS has been using Rustici Content Controllers under the Army Learning Management System (ALMS), which transitioned to ATIS in January of 2024.

12. Technical Certification: I certify that the supporting data under my cognizance, which are included in the justification, are accurate and complete to the best of my knowledge and belief.

13. Requirements Certification: I certify that the supporting data under my cognizance, which are included in the justification, are accurate and complete to the best of my knowledge and belief.

June 2025

Approval

Based on the foregoing justification, I hereby approve the procurement of Rustici Content Controller on an other than full and open competition basis pursuant to the authority of Title 10 U.S.C. §3204(a)(1) as implemented in FAR 6.302-1(a)(2)(iii)(A), Substantial duplication of cost to the Government that is not expected to be recovered through competition. The estimated value of the new contract is for a

The approval is subject to availability of funds, and provided that the supplies and/or services herein described have otherwise been authorized for this acquisition.