JEFO - CIN - Mail Equipment CBOCs - Updated.pdf

Attachment 1: Request for Exception to Fair Opportunity Memo Format

Effective Date: 12/30/2025 Page 1 of 4 Revision: 03 Acquisition ID#: 36C250‑26‑AP‑4380

DEPARTMENT OF VETERANS AFFAIRS

Justification and Approval

For Exception to Fair Opportunity Memo

Acquisition Plan Action ID: 36C250‑26‑AP‑4380

1. Contracting Activity: Department of Veterans Affairs, VISN 10, Cincinnati VA Medical

Center.

Purchase Request 539-26-3-049-0031 Using Activity: Cincinnati Logistics Departmetn Contracting Activity: Network Contracting Office (NCO 10)

2. Description of Action: The VA intends to issue a new firm-fixed-price task order under Contract 36C10X25D0005 (EMM MAC). The order will procure six (6) Pitney Bowes SendPro 360-compatible mini mailing units for Cincinnati VA CBOCs.

These units were not part of the original task order and constitute an out-of-scope expansion, requiring a JEFO under FAR 16.505(b)(2)

• Order Number: TBD

• Contract Type: Firm‑Fixed‑Price (FFP)

• Contractor: Pitney Bowes, Inc.

• Estimated total value: $142,628.40 (12‑month Base + 2 Option Period alignment).

3. Description of Supplies or Services: The VA requires 6 SendPro 360-compatible mini mailing stations, including FedRAMP-authorized cloud software, analytics, installation, multi-carrier shipping capability, and 36-month support.

This order aligns the CBOC requirement with the existing Pitney Bowes deployment at Cincinnati VAMC to allow future re-solicitation of the complete consolidated mailroom requirement.

4. Statutory Authority: The statutory authority permitting an exception to fair opportunity is

Section 41 U.S.C. 4106(c) as implemented by the Federal Acquisition Regulation (FAR) 16.505(b)(2)(i):

( ) FAR 16.505(b)(2)(i)(A): The agency need for the supplies or services is so urgent that providing a fair opportunity would result in unacceptable delays.

(X) FAR 16.505(b)(2)(i)(B): 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.

( ) FAR 16.505(b)(2)(i)(C): The order must be issued on a sole-source basis in the interest of economy and efficiency because it is a logical follow-on to an order already issued under the contract, provided that all awardees were given a fair opportunity to be considered for the original order.

( ) FAR 16.505(b)(2)(i)(D): It is necessary to place an order to satisfy a minimum guarantee.

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( ) FAR 16.505(b)(2)(i)(E): For orders exceeding the simplified acquisition threshold, a statute expressly authorizes or requires that the purchase be made from a specified source”.

The statutory authority permitting an exception to fair opportunity for this action is 38 U.S.C.

8127(c), known as the Veterans First Contracting Program which provides the authority to directly contract with a Service-Disabled Veteran-Owned Small Business (SDVOSB) or a Veteran-Owned Small Business (VOSB).

5. Rationale Supporting Use of Authority Cited Above: The VA’s enterprise mail management system is based on Pitney Bowes SendPro 360, a proprietary, FedRAMP-authorized, VA ATO-approved platform.

Pitney Bowes confirmed:

• SendPro 360 only works with Pitney Bowes hardware.

• Pitney Bowes hardware only operates with Pitney Bowes FedRAMP-authorized software.

• The system is proprietary.

Quadient, although possessing FedRAMP-authorized cloud software, does not manufacture SendPro-compatible hardware. Therefore, Quadient cannot meet the VA’s interoperability or security requirements across CBOC sites.

Only Pitney Bowes can provide SendPro 360-compatible hardware/software solutions.

Awarding to any other vendor would result in:

• System incompatibility

• Failure of integration with VA’s enterprise mail architecture

• Security non-compliance (FedRAMP + ATO)

• Loss of CBOC mailroom functionality

Thus, under FAR 16.505(b)(2)(i)(B), only Pitney Bowes is capable.

6. This acquisition is not a brand-name justification.

It is a JEFO under FAR 16.505(b)(2)(i)(B) because only one MAC awardee can satisfy VA’s interoperability and security requirements. Although the requirement operates within a proprietary Pitney Bowes environment, the limitation is due to awardee capability within the MAC, not a brand-name specification in the open market; therefore, FAR 11.105 does not apply.

Efforts to Obtain Competition: A description of efforts made to ensure that offers are solicited from as many potential sources as is practicable. Market research was conducted among both MAC awardees: Pitney Bowes and Quadient. Pitney Bowes confirmed SendPro 360’s proprietary and FedRAMP-authorized nature and its hardware compatibility restrictions. Quadient confirmed that while FedRAMP-authorized software exists,

• Quadient does not manufacture hardware compatible with Pitney Bowes systems.

Therefore, fair opportunities are not practicable. This JEFO will be posted publicly in accordance with FAR 16.505(b)(2)(ii)(D).

Effective Date: 12/30/2025 Page 3 of 4 Revision: 03 Acquisition ID#: 36C250‑26‑AP‑4380

7. Actions to Increase Competition: Describe actions taken, or that will be taken, to remove or overcome any barriers to competition before initiating any subsequent acquisitions for the supplies or services required, including challenges to restrictive data markings, data rights, preparation of a performance-based work statement, and etc.

The Government will continue monitoring the enterprise mail management market to determine if other MAC awardees or vendors develop:

• FedRAMP‑authorized

• VA‑approved

• SendPro‑compatible hardware or cloud software

Future requirements will be competed amongst all approved VA EMM MAC vendors which will allow the ability to quote services for the entire Cincinnati VA Mailroom hardware, software, and security needs. This consists of the CBOC requirement and the requirement that is already in place at the VAMC.

9. Market Research: Market research consisted of the following activities:

• Reviewing the capabilities of both MAC awardees.

• Obtaining proprietary and compatibility statements from Pitney Bowes confirming

SendPro 360 hardware/software exclusivity.

• Reviewing Quadient’s FedRAMP-authorized software capabilities.

• Evaluating Government interoperability requirements for SendPro 360 deployment across Cincinnati VA CBOCs.

• Confirming VA security requirements, including FedRAMP authorization and adherence to VA’s Authority to Operate (ATO).

Results show:

• Pitney Bowes: Provides proprietary SendPro 360 hardware and FedRAMP-authorized cloud software with a VA ATO, meeting all integration and compatibility requirements of the VA’s enterprise mail management architecture.

• Quadient: Offers FedRAMP-authorized cloud software but does not manufacture hardware compatible with Pitney Bowes SendPro 360. Quadient cannot supply equipment capable of integrating with the existing VA mail management system.

Therefore, only Pitney Bowes can meet the Government’s technical, interoperability, and security requirements.

10. Other Facts:

The Cincinnati VA’s enterprise mail management architecture uses Pitney Bowes SendPro 360, which is proprietary and not compatible with third-party hardware.

Quadient does not manufacture hardware compatible with SendPro 360. Because the Government must maintain full interoperability and security compliance (FedRAMP + ATO) across all CBOCs, specifications cannot be broadened without causing system failure, degraded performance, or security violations.

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As a result, competition cannot be increased for this action, and only Pitney Bowes can meet the Government’s requirements.

11. 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.

Scott Burkhart Date Acquisition Utilization Specialist

Cincinnati VA Medical Center

12. Determination that Anticipated Cost is Fair and Reasonable: The cost of $142,628.40 is fair and reasonable because Contract 36C10X25D0005 was competitively awarded and determined fair and reasonable at the time of MAC award.

The CLINs used (0004 and 0006) follow pre-negotiated MAC ceiling pricing and align with historical pricing for similar services and hardware already deployed at Cincinnati VA. No additional price analysis is required.

13. Contracting Officer's Certification (required): I certify that the foregoing justification is accurate and complete to the best of my knowledge and belief.

Josh Kovar Date Contracting Officer NCO-10 Kettering