JEFO_Interim_REDACTED.pdf

JUSTIFICATION FOR EXCEPTION TO FAIR OPPORTUNITY

SECTION 1: IDENTIFICATION OF THE AGENCY AND THE CONTRACTING

ACTIVITY

Department of State Contracting Activity

☒ Acquisition Management

Requiring Activity DT/EA/PTA

SECTION 2: NATURE AND/OR DESCRIPTION OF THE ACTION BEING

APPROVED

Approval is requested to solicit and award a Firm-Fixed-Price Unit (FFP) on NASA SEWP V GWAC with exception to fair opportunity for the supplies and/or services described in Section 3 on behalf of the Requiring Activity.

SECTION 3: DESCRIPTION OF SUPPLIES/SERVICES REQUIRED TO MEET THE

AGENCY’S NEEDS

The Department of State requires the renewal of licensing and the provision of support services for the Centralized Evaluation System (CES), a FedRAMP-authorized SaaS platform powered by Qualtrics. The CES is an enterprise-wide system critical to the Department’s ability to conduct training evaluations, 360-degree feedback, interviews, service feedback, and digital experience analytics.

These services and supplies are essential to ensure continued operation, maintenance, and enhancement of the CES, which supports the Department’s mission-critical activities and strategic goals.

Supplies Services:

Item Qty Part Number Description 1 1 ENT-PLAT Qualtrics Enterprise Platform

ENT-PLAT-NFATC -Enterprise Access for U.S. Department of State -FedRAMP AI-Enabled Platform -Survey Builder, XM Directory & Distributions -Dashboard & Reporting -Workflow Builder & Integration Tools -Platform Admin & User Management Tools

2 1 CX-RES FedRAMP CX & Research Suite Interactions Bundle -10,000 Interactions (1 interaction = 1 survey response) -1M User Session Replays

4 2 GUIDED-SP Guided Success Package Cloud Services -Dedicated Technical Success Manager -Priority Enterprise Support -Automated Distributions Engineering Services O&M.

-10 hrs./wk.

The period of performance for this contract is 8/22/2026 until 9/21/2026

The estimated value for the entire period of performance is XXXXXX

SECTION 4: IDENTIFICATION OF THE EXCEPTION TO FAIR OPPORTUNITY

AND THE SUPPORTING RATIONALE

☐ FAR 16.507-6(b)(3) – 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.

This order is issued sole-source to Carahsoft in the interest of efficiency as a logical follow-on to order the latest solicitation, for which all SEWP awardees received fair opportunity under the latest RFQ which were also evaluated by the TET and currently under the GA award process. The follow-on continues the same Qualtrics XM system, FedRAMP Moderate boundary, ATO, PROD/UAT instances, custom Automated Distribution Tool, and SIS/LMS/HR/SSO integrations, without migration.

Furthermore, DT/EA/PTA/CASD has been actively planning for the recompete of this requirement for over one year in advance of the contract's original expiration date, working in close and continuous coordination with the National Foreign Affairs Training Center's (NFATC) Acquisition (ACQ) office and later with Global Acquisition. This extended planning effort reflects the Government's diligence and good-faith intent to compete this requirement in a manner consistent with fair opportunity principles.

Despite this advance planning, the solicitation was delayed due to a series of unexpected and unscheduled factors outside the direct control of the program office and contracting activity, including:

Department Reorganization – organizational realignments affecting reporting structures, approval chains, and resource allocation for the acquisition;

Diplomatic Technology Restructuring and Consolidation – consolidation of technology, functions and systems that altered requirements definition and stakeholder coordination during the acquisition planning process;

Funding-Related Issues – disruptions or delays in the availability or certainty of funding that affected the Government's ability to finalize and release the solicitation on the originally planned timeline; and

Limited Acquisition Workforce Bandwidth – constrained staffing capacity within the acquisition function, which affected the pace at which required procurement actions could be completed.

As a direct result of these compounding factors, the Government's traditional competitive process could not be completed prior to expiration of the current contract. Without award under this exception, CES customers — including HR, NFATC, and other mission stakeholders

— would be unable to complete time-critical evaluation activities that are essential to their core mission functions and to meeting congressional mandates. An interruption in these services would directly and adversely affect the Department's ability to execute its statutory and mission-critical training and evaluation responsibilities, resulting in unacceptable harm to the Government.

SECTION 5: DETERMINATION BY THE CONTRACTING OFFICER THAT THE

ANTICIPATED COST TO THE GOVERNMENT WILL BE FAIR AND

REASONABLE

The Contracting Officer has determined the anticipated delivery order will represent the best value based on fair opportunity among authorized resellers on the NASA SEWP. NASA SWEP V prices have been established to be fair and reasonable. By signing the justification, the Contracting Officer makes a determination that the price to the Government is expected to be fair and reasonable.

SECTION 6. STATEMENT OF THE ACTIONS, IF ANY, THE AGENCY MAY TAKE

TO REMOVE OR OVERCOME ANY BARRIERS THAT LED TO THE EXCEPTION

TO FAIR OPPORTUNITY BEFORE ANY SUBSEQUENT ACQUISITION FOR THE

SUPPLIES OR SERVICES IS MADE.

Although the requirement is limited to a specific brand-name product due to technical and operational constraints, the Government will maximize competition to the extent practicable by soliciting quotations from all authorized resellers under the NASA SEWP V contract vehicle.

Market research confirms that multiple vendors are capable of providing the required OEM authorized products and services. Accordingly, competition will be obtained at the reseller level, and price reasonableness will be established through comparison of competitive quotations, historical pricing, and commercial benchmarks. The Program Office will continue to conduct market research prior to each renewal to assess whether future changes in technology, licensing models, or interoperability could allow for expanded competition in subsequent acquisitions.