Justification for an Exception to Fair Opportunity FAR Part 16 Final_Redacted.pdf

CUI//SP-PROCURE//FEDCON

Control Number:

JUNE 2025

JUSTIFICATION REVIEW DOCUMENT

FAR Part 16 Justification for an Exception to Fair Opportunity

Program/Equipment: The Department of the Army Criminal Investigation Command (DADACID) requires procurement of information technology services (IT) in support of the OnBase software application. The IT services will provide mission critical operational services and ensure mission functionality for Special Agents/Military Police worldwide to include deployed environments.

Authority: Title 10 United States Code (U.S.C.) §3406(c)(2) as implemented in Federal Acquisition Regulation (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.

Amount:

Prepared by: Phone:

Contract Specialist Date:

Contracting Officer: Phone:

Contracting Officer Date:

Technical: Phone:

Program Manager Date:

Requirements: Phone:

Program Manager Date:

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

Justification for an Exception to Fair Opportunity Under FAR 16.505(b)(2)

1. Requiring Activity: Department of Army Criminal Investigation Division (DADACID)

2. Contracting Activity: U.S. Army Contracting Command – New Jersey (ACC-NJ)

3. Description of Action: ACC-NJ, on behalf of the DADACID has a requirement to award a new Firm Fixed Price (FFP) Task Order under the General Service Administration (GSA) Advantage Multiple Award Schedule (MAS) contract for the procurement of OnBase software application and maintenance services. The place of performance is Quantico, VA and .

is currently the only contractor that can provide the OnBase (Electronic Imaging) software application to meet the needs of this requirement. The anticipated award date is September 26, 2025 and Operations and Maintenance, Army funds will be used. The period of performance will be 9 months after the contract award.

4. Description of Supplies/Services: The services being procured will support mission critical software and will ensure mission functionality for DADACID Special Agents and Military Police worldwide. The contractor will provide operations and maintenance support for the existing OnBase software application. The required support services include software applications, databases, information assurance, system testing and maintenance, enhancements, upgrades, training support for the Army Law enforcement community, and the Department of Defense (DoD) mandate to transition to electronic recordkeeping. The estimated total value of this requirement is

5. Authority Cited: Title 10 U.S.C. §3406(c)(2) as implemented in 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.

6. Reason for Authority Cited: Section 3101 of title 44, United States Code, states that “the head of each Federal agency shall make and preserve records containing adequate and proper documentation of the organization, functions, policies, decisions, procedures, and essential transactions of the agency and designed to furnish the information necessary to protect the legal and financial rights of the Government and of persons directly affected by the agency’s activities”. Additionally, DoD Records Strategy Memorandum DOPSR 23-S-2095 mandates a transition from paper to electronic records. As such the DoD uses electronic recordkeeping systems (ERS) to manage digital records, utilizing metadata to capture, organize, and store records. The OnBase software platform enables DACID to maintain compliance with ERS standards through its digital filing, workflow automation, and secure storage capabilities. Continued maintenance of OnBase is critical to preserving the integrity of DACID’s official records and law enforcement case files within its authoritative electronic database.

a. Background: OnBase is a unique Commercial-off-the-Shelf (COTS) software application utilized by DADACID and Military Police forces for law enforcement electronic imaging (EI) and recordkeeping. OnBase is a proprietary content services platform designed to manage documents, processes, and store electronic law enforcement (LE) cases and their associated attachments in one place. It provides digital filing; workflow automation and secure storage capabilities; features a sophisticated workflow module for routing documents to users to complete tasks;

enables users to store, retrieve, and organize documents efficiently. OnBase is a low-code platform allowing information technology (IT) and business departments to accelerate solution delivery across the enterprise. EI system serves as the Army’s authoritative source for current and historical law enforcement records. Currently, EI houses approximately 3.5 million law enforcement case files dating back to 1964.

OnBase is designed to integrate with the Army Reporting and Tracking System (ALERTS) LE case management system. OnBase employs uniquely configured interface scripts to automatically transfer LE cases, including associated attachments, from the ALERTS to designated file locations within OnBase. OnBase is customized to create dynamic, customizable, role-based functionality in preservation of LE documentation. OnBase’s role-based configuration assigns user permissions based on their specific role and job function, restricting user access to data required for their specific job function.

OnBase technology provides the records processing technician the ability to add pages or revise existing LE cases with additional exhibits or supplemental pages without resubmitting the entire case. It provides the ability to review cases for accuracy, accept correct cases, or return cases for correction. OnBase provides the technician with a discrepancy tracker to monitor cases returned to field offices for correction.

EI is the repository and authoritative source for all LE case files. It provides the means for all DADACID and Military Police offices to electronically submit case documents to the EI mission system for records retention. With the introduction of OnBase and the electronic upload capability, postal costs were significantly reduced and case submission rates increased. OnBase has enabled DADACID to transition to a fully electronic case management and electronic record keeping system. Only OnBase has the capability to successfully interface EI with ALERTS and other components of OnBase. The benefit of this SW functionality is that it will leverage existing and future Army LE enterprise assets and other external data sources.

b. Alternatives: There are currently no alternatives to satisfy this requirement.

OnBase was developed for Government content management and electronic recordkeeping, and it is the only software that provides standardization across DADACID. The Government does not have technical data rights to OnBase application modifications, as it is Commercial off the Shelf (COTS) software. The Government has made a significant investment in the current Commercial Off-The-Shelf (COTS) architecture. DADACID has invested over in the initial development of the

OnBase application and has incurred approximately annual in maintenance fees since its implementation in 2017. Replacing this established software platform would not be financially prudent. As OnBase is a COTS product developed by

. retains the rights and has authorized to modify code for OnBase integration and further development to meet Government requirements.

c. Impact if not approved: Disapproving of this justification would negatively impact DADACID’s core mission of conducting criminal investigations. Sourcing and implementing a new software application from an alternative vendor would be prohibitively expensive, encompassing costs for software licensing, configuration, data migration, and stakeholder training. Furthermore, the Government would incur significant personnel costs to redevelop training materials, revise standard operating procedures, modify data interfaces, and reconfigure software workflows.

7. Actions to Increase Competition: As this is considered a non-developmental item/ services, developed exclusively at private expense, the Government does not have the proprietary software/data rights and does not foresee procuring data rights in the future.

DACID will continue to conduct market research for future requirements on existing and new technologies as it becomes available. In the absence of a transfer of the intellectual property underlying the OnBase software application to another vendor, future competition for this requirement is unlikely.

8. Market Research: In accordance with AFARS Part 5139.101, Army Regulation 25-1 and Department of the Army Policy memorandum dated 04 May 2009, CHESS is the primary source for commercial information technology hardware, software and associated items. Purchasers of commercial information technology hardware, software and associated items. Purchasers of commercial hardware and software must satisfy their information technology requirements by utilizing CHESS contracts and DoD Enterprise Software Initiative agreements first, regardless of dollar value.

Market research was conducted by DACID to identify potential alternative solutions.

DACID posted a sources sought notice to the CHESS ITES-3S contract vehicle. The CHESS sources sought notice resulted in no responses, and as a result DADACID issued a Statement of Non Availability. DADACID contacted the manufactures of OnBase software and in a letter from

, they stated that there’s multiple authorized resellers of the OnBase software application; however, is the only authorized reseller allowed to perform software installation, enhancements, and maintenance. Additionally, DADACID queried the following Government databases: Federal Procurement Data System, GSA, Electronic Document Access, and Small Business Administration’s Dynamic Small Business Search Engine. Lastly, DADACID used internet tools to perform Web searches and reviewed results of recent market research on similar requirements.

In conclusion, the required OnBase IT operations and maintenance services are only provided by . The services provided by Naviant Inc are available through the

GSA Advantage Multiple Award Schedule (MAS) 54151 contract vehicle. As such it is recommended that this requirement be solicited sole source to under the GSA MAS contract vehicle utilizing 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.

9. Other Facts:

a. Procurement history. N/A

b. Other facts. N/A

CUI//SP-PROCURE//FEDCON

JUNE 2025

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

Contracting Officer

Approval

Based on the foregoing justification, I hereby approve the procurement of OnBase software IT application services to in the amount of on an other than full and open competition basis pursuant to the authority of 10 United States Code 3406(c)(2) as implemented by FAR Part 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, subject to availability of funds, and provided that the services and property herein described have otherwise been authorized for acquisition.

Contracting Officer