Justification for an Exception to Fair Opportunity under MAC for Learning Nucleus_Redacted.pdf

JUSTIFICATION FOR AN EXCPETION TO FAIR OPPORTUNITY UNDER

MULTIPLE AWARD CONTRACTS IN ACCORDANCE WITH FEDERAL

ACQUISITION REGULATION (FAR) 16.505

IDENTIFICATION NUMBER (PURCHASE REQUEST/SOLICITATION

NUMBER): 25HC000050

1. Contracting Agency and Activity.

The Department of Energy (DOE), Office of Headquarters Procurement Services (MA-64), located in Washington, DC, proposes to issue an award for services by means of other than full and open competition. This action is in support of the Office of the Chief Human Capital Officer (HC), Office of Talent Management (OTM). This document sets forth the justification and approval for the use of the exception to fair opportunity as authorized under Federal Acquisition Regulation (FAR) 16.505(b)(2)(i)(B), Only one awardee is capable of providing the supplies or services at the level of quality required because the supplies or services ordered are unique or highly specialized.

2. Nature and/or Description of the Action Being Approved.

The action being approved is for a sole-source Firm-Fixed-Price (FFP) Task Order against the multiple award Indefinite Delivery/Indefinite Quantity (IDIQ) Contract No.

NNG15SC62B. The anticipated period of performance will be 12 months, consisting of a six-month base period, and two (2) three-month option periods. The proposed awardee is American Wordata, Inc. dba AWData, Inc.. PowerTrain, Inc. is a small business.

Contractor(s) Name and Address: American Wordata, Inc. , 13916 Monroes Business Park Ste 101, Tampa, FL, 33635 Unique Entity Identifier (UEI): G4L6RJS94VP9

CAGE: 0LBPP3

NASA SEWP V Contract Number: NNG15SC62B NASA SEWP V Category: Group C – Small Business Period of Performance (or new Term): October 1, 2025 – September 30, 2026, Independent Government Cost Estimate (IGCE) Dollar Value of this action:

$949,800.00

3. Description of Supplies and/or Services (Including the Estimated Value).

The Department of Energy (DOE) Learning Nucleus (LN), Learning Management System (LMS) is the Department’s platform for delivering training to its workforce.

DOE users access learning content using an Open Learning Services Architecture (OLSA) cloud content server that integrates with Skillsoft through which delivery and tracking of course content is managed.

The scope of this requirement is to renew the LMS enterprise-level hosting and technical support and provide the following services:

a. Federal Risk and Authorization Management Program (FEDRAMP) authorized enterprise-level hosting for up to 60,000 users. Services include on-site and off-site incremental backups on the server, service infrastructure with redundant internet service providers, a back-up power generator, and 24-hour access and security.

b. Technical Support for LN issue solution to resolve Tier 3 issues identified by the DOE help desk, issued reported by other communication channels (such as email), and issues reported to the DOE LN Tracker.

c. Technical Support for Change Order Implementation to make modifications to the LN following the Change Request Process.

d. Project Management Support that consists of stakeholder meetings, managing issue resolutions and change order implementation, and managing gated releases.

e. Optional Additional Support that may include data extraction, data migration, data mapping, business process documentation, and the development of scripts to support migration of data from LN to the Workday Human Capital Platform LMS.

This work will have an expected period of performance from award date through September 30, 2026, with an expected price of for the initial 6-month period of performance, and overall total of if all option periods are exercised.

PERIOD ESTIMATED VALUE

Base (October 1, 2025 – March 31, 2026)

Option Period 1: Additional 3 months (April 1, 2026 – June 30, 2026)

Option Period 2: additional 3 months from (July 1, 2026 – September 30, 2026)

GRAND TOTAL

4. An identification of the LSJ rationale, and demonstration of the contractor’s unique qualifications to provide the required supply or service.

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 series ordered are unique or highly specialized.

The Department of Energy (DOE) launched its Learning Nucleus (LN) Learning

Management System (LMS) in 2018 to centralize and streamline the administration, documentation, tracking, reporting, and delivery of educational courses and training programs for all DOE federal and contractor employees.

The LN platform was implemented in three phases, enabling rapid deployment, seamless integration, and expanded access across the DOE workforce. LN has since become the core infrastructure supporting DOE’s employee training and development efforts.

To modernize its human capital practices, DOE is transitioning to a new Software-as-a-Service (SaaS) integrated talent management system, which includes an LMS module. This new system is designed to enhance operational efficiency, improve user experience, and provide a unified interface for DOE employees. The LMS module of the new talent management system is scheduled to go live in January 2026. To ensure uninterrupted training operations during this transition, the Office of Talent Management (OTM) must extend access to the existing LMS through January 2026. This extension is critical to maintaining DOE’s learning and development mission requirements while the new system is developed, tested, and deployed.

Since the inception of the Learning Nucleus LMS, DOE has partnered with Powertrain through an interagency agreement with the Office of Personnel Management’s (OPM) USALearning program. Powertrain was responsible for the initial development, customization, and deployment of the LN platform, which is built on an open-source framework and tailored to meet DOE’s specific training needs. Over the years, Powertrain has provided ongoing hosting, programming, and support services, including secure storage of DOE’s training data on their servers.

Powertrain’s extensive involvement in the development and maintenance of the existing LMS has given them a deep understanding of the platform’s architecture, customizations, and integration points. This expertise uniquely positions Powertrain to support the decommissioning of the current LMS and the migration of critical data and records to the new talent management system.

Their intimate knowledge of DOE’s learning environment and technical requirements ensures a seamless transition, minimizing risks to data integrity, system functionality, and operational continuity.

The migration to the new talent management system coincides with the expiration of DOE’s current agreement with Powertrain under the OPM USALearning interagency agreement. This timing creates a unique and urgent need for continuity of service. Any disruption in LMS support during this critical period would jeopardize DOE’s ability to meet its training and development objectives, delay the launch of the new LMS module, and potentially compromise the integrity of the migration process.

Given Powertrain’s unparalleled familiarity with the existing LMS and their proven track record of delivering reliable support, awarding a sole-source contract to Powertrain is the only viable option to ensure a successful transition.

Engaging a new vendor at this stage would require significant time and resources to onboard, familiarize them with the highly customized LMS, and mitigate the risks associated with data migration and system decommissioning. Such delays and inefficiencies would have a detrimental impact on DOE’s mission-critical training operations.

American Wordata, Inc. is Powertrain’s only value-added reseller and is uniquely qualified to support DOE’s LMS transition due to their detailed understanding of the existing platform, their role as the original developer and ongoing service provider, and their ability to ensure continuity during the migration to the new talent management system. Awarding a sole- source contract to Powertrain is essential to maintaining DOE’s training and development mission, safeguarding data integrity, and ensuring the timely and successful deployment of the new LMS module. Failure to do so would result in significant operational risks, delays, and potential disruptions to DOE’s workforce training efforts.

5. A determination by the contracting officer that the anticipated cost to the

Government will be fair and reasonable

The Contracting Officer will determine that the anticipated price will be fair and reasonable based on price analysis and prior acquisition history.

6. Description of the Market Research Conducted Among Schedule Holders and the Results or a Statement of the Reason Market Research was not Conducted.

Market research was not conducted due to the late emergence of the requirement, as well as the significant adverse impacts that would result from delays in securing uninterrupted service for the existing DOE LMS. As a Title 5 Federal Agency, there are statutory requirements for delivering training programs, which necessitate continuous LMS functionality without service gaps. The project delay caused by the unforeseen Workday LMS FedRAMP certification process could not be avoided.

7. Any other facts supporting the justification.

Re-competition of the LMS hosting services is not an efficient option unless DOE’s learning division plans the event several years in advance to allow for the FEDRAMP and Authority to Operate (ATO) approval, and transition ranging from 4 to 6 months, depending on the complexity. DOE has completed the process of selecting the new LMS and merely needs to extend the current provider to mitigate the possibility of any project delays, which would leave DOE without an LMS platform to deliver federally mandated training to 14,000 federal employees. In addition, the primary system and all associated software must be secured in accordance with FedRAMP requirements and the implementation of a new LMS would be impossible while working to also install the new Workday Human Capital Platform and the associated Learning Module. These systems must have an ATO, which is a three-year process to set-up, document, test, and be approved.

8. Actions to Overcome Barriers to Competition.

For the reasons set forth in Paragraph 4, the DOE has no plans at this time to compete future contracts for the types of supplies/services covered by this justification. If another potential source emerges, DOE will assess whether competition for future requirements is feasible.