JustificationApproval_Sole-SourceFinal_Redacted.docx

Justification and Approval for Sole Source (J&A) Justification and Approval for Sole Source

“Source Selection Information – see FAR 2.101 and 3.104”

1. Identification of the agency and contracting activity.

2. Nature and/or description of the action being approved.

Acquisition purpose and objectives. Federal statute directs the Office of Educational Technology (OET) to develop a national vision and strategy for how educational technology can be used to transform teaching and learning; promote awareness and effective use of technology by States, districts, and postsecondary institutions; ensure the availability and dissemination of knowledge; and promote the effective uses of technology in existing Federal education programs.

OET requires unique educational technology expertise to meet urgent needs to support students impacted by imminent closure of Institutions of Higher Education (IHE) and to support the Secretary’s goals to ensure continuity of learning for all students.

The MIT contractor has requested a no-cost time extension to the Open Source Standard Wallet Application contract with a proposed new end date of March 28, 2022. The deliverables impacted by this extension are:

· Deliverable for Task 3.2: Deploy and Monitor Reference Implementation

· Deliverables for Task 4: Technical Assistance Plan/Conduct Technical Assistance

· Deliverables for Task 5: Conduct Review of Reference implementation

· Deliverables for Task 6: Dissemination

The purpose of this contract is to develop open source standards for student credential wallets that will describe the technical conditions for credential interoperability. This technology will allow institutions of higher education to address the records management needs of students by providing digital student records in a permanently accessible, verified record of their credits earned.

3. Description of the supplies or services required to meet the agency’s needs (including the estimated value).

Project title. Open Source Standards for Student Wallets Proof of Concept Project

a. Project description. This contract was awarded in September 2020 to MIT to develop open source standards for student credential wallets. So that students can permanently access their credits earned even if their Institution for Higher Learning closes due to COVID-19 related circumstances.

By anchoring digital student records and other demonstrations of achievement to a public ledger such as a blockchain, institutions can provide students with permanently accessible, verifiable records of their credits earned. Thereby, allowing them to smoothly transition to their next postsecondary institution.

The contractor has been working with institutions of higher education for deployment of the Open Source Student (OSS) Wallet. Two of the higher education institutions San Jose City College (SJCC) and College Unbound (CU) are delayed for two reasons: 1) the limited capacity of technological and personnel resources has necessitated the development and implementation of additional technology by the MIT project team in order to enable those institutions to issue digital credentials; and 2) the recent COVID-19 surge redirected already limited partner institutions’ staff capacity toward supporting the urgent needs of their students and academic programs.

This contract was awarded as a sole source firm fixed price contract. The contractor is requesting a no cost time extension modification to extend the period of performance from February 28, 2022, to March 28, 2022. The total price of the contract is $448,850 and remains $448,850 even with the time extension.

4. Identification of the statutory authority permitting other than full and open competition.

This acquisition is conducted under the authority of 41 United States Code (U.S.C.) 253(c)(__) as set forth in Federal Acquisition Regulation (FAR) 6.302-1.

5. Demonstration that the proposed contractor(s) unique qualifications or the nature of the acquisition requires use of the authority cited. This contract was awarded to Massachusetts Institute of Technology (MIT). There is no additional work for any other vendor to complete. The technical assistance that MIT is providing to CU and SJCC is included within the scope of the contract. The process of the technical assistance has been slowed with the issues faced by the small higher education institutions. With the start of the new term in January, COVID delayed the implementation of the technical assistance.

Additional time is required to successfully collaborate between MIT and the two entities. Both CU and SJCC serve diverse student populations including a high percentage of first-generation college students. The partnership with these institutions is extremely valuable for exploring the challenges and opportunities of the use of digital credentials and the leaner credential wallet.

Allowing for this additional time extension will make the final product more accessible for more diverse students, which is a benefit to the government because this is the purpose of this contract.

Having to procure this technical assistance with another firm would end up costing the government additional money. In addition, an outside firm would not be able to complete the work in one month, given the time to procure before the work can be started.

6. Description of the efforts made to ensure that offers are solicited from as many potential sources as practicable. Indicate whether a FedBizOpps notice was or will be publicized as required by FAR Subpart 5.2 and, if not, which exception under FAR 5.202 applies. The contract was solicited as a sole source contract and the Justification for Other than Full and Open Competition was approved on August 25, 2020. This action is not being solicited from any potential sources currently because market research was conducted at time of award. All critical areas and expertise relevant for this contract were reviewed and compared with entities in industry. Only MIT contained all five of the critical key areas. A few firms contained a few of the expertise, however, only MIT contained all of them. A notice of intent with a copy of this JOFOC will be posted on SAM as required by FAR Subpart 5.2.

7. Determination by the Contracting Officer that the anticipated cost/price to the Government will be fair and reasonable. The CO/CS did a thorough cost/and price analysis regarding the fairness and reasonableness of the price of the contract at the time of award. The CO/CS determined at the award time that the total price was fair and reasonable. The price is not changing by reason of this action therefore no additional cost analysis needs to be conducted.

8. Description of the market research conducted (see FAR Part 10) and the results, or a statement of the reasons market research was not conducted. No market research is being conducted for this no cost time extension because market research was conducted at time of award. All critical areas and expertise relevant for this contract were reviewed and compared with entities in industry. Only MIT contained all five of the critical key areas. A few firms contained a few of the expertise, however, only MIT contained all of them. A notice of intent with a copy of this JOFOC will be posted on SAM as required by FAR Subpart 5.2.

9. Any other facts supporting the use of other than full and open competition.

Market research was conducted at time of award. All critical areas and expertise relevant for this contract were reviewed and compared with entities in industry. Only MIT contained all five of the critical key areas. A few firms contained a few of the expertise, however, only MIT contained all of them.

10. A listing of the sources, if any, that expressed, in writing, an interest in the acquisition.

No other vendors have expressed an interest in this requirement.

11. A statement of the actions, if any, the agency will take to remove or overcome any barriers that led to restricted consideration before any subsequent acquisition for supplies and services is made.

The Department will continue to conduct thorough market research to gauge the marketplace capabilities for future requirements. This contract will not be further extended, and any future needs will be dealt with on a competitive basis.

12. The ordering activity Contracting Officer’s certification that the justification is accurate and complete to the best of the Contracting Officer’s (CO) knowledge.

13. Evidence of any supporting data that is the responsibility of technical or requirements personnel.

This is to certify that the data supporting this justification is the responsibility of technical or requirements personnel (e.g., verifying the Government’s minimum needs or schedule requirements or other rationale for other than full and open competition) and which form the basis for the justification have been certified as complete and accurate by the technical or requirements personnel image4.emf image1.emf image2.emf image3.emf