Limited Sources Justification-FAR 8.4 - DAP Software-as-a-Service (SaaS) Web Analytics Subscription (3).pdf

CUI

Limited Sources Justification (FAR 8.4)

Only One Source

Digital Analytics Program (DAP)

Public Experience Portfolio Software-as-a-Service (SaaS) Web Analytics Subscription Support

IAW FAR 8.405-6

Document Format IAW FAR 8.405-6(c)(2) For an FSS order or BPA with an estimated value exceeding the simplified acquisition threshold.

The acquisition is conducted under the authority of the Multiple-Award Schedule Program, limiting sources IAW FAR 8.405-6(a)(1)(B)- Only one source is capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized.

Limited Sources Justification-FAR 8.4 - DAP Software-as-a-Service (SaaS) Web Analytics Subscription version 1.0 dated 08.20.2024

(i) Identification of the Agency and Contracting Activity U.S. General Services Administration (GSA) Federal Acquisition Service (FAS) Technology Transformation Services (TTS) 1800 F Street NW, Room 4400 Washington, DC 20405

(ii) Nature and/or Description of the Action Being Approved Pursuant to Federal Acquisition Regulation (FAR) Part 8.405-6, the General Services Administration (GSA), Technology Transformation Service (TTS), Acquisition Division (Acq-Div) ) is seeking approval to issue a limited source task order to E-Nor LLC , on a Firm Fixed Price basis for Digital Analytics Program (DAP) and Public Experience Portfolio (PX) Software-as-a-Service (SaaS) Web Analytics Subscription Support. This Order replaces the services provided under 47QPCA23F0034 with E-Nor LLC which expires on September 28, 2024. The services associated with this justification is a continuation of the services that were performed under Order 47QPCA23F0034

The original DAP requirement was competed in September 2017 under Federal Supply Schedule 70 (GSH1417AA0263). In September 2022, a logical follow-on Order was issued to E-nor LLC off GSA MAS (47QPCA22F0044) for a period of 12-months to migrate data from Universal Analytics to Google Analytics 4 360. In September 2023, another logical follow-on Order was issued to E-nor LLC off GSA MAS (47QPCA22F0044) for a period of 12-months to complete the unfinished migration for DAP and start and complete the migration for PX. Under this proposed action, the Government will issue another 12 month logical follow-on Order to E-nor LLC off their GSA MAS Contract (GS-35F-0651Y) to continue to provide critical support to DAP and PX.

This effort is necessary to maintain support for TTS. Re-competing this effort among MAS contractors would not provide material cost savings and would introduce significant schedule and performance risk.

(iii) Description of the Supplies/Services Required (including estimated value) TTS seeks two (2) GA4 360 SaaS solutions with the respective functionality as stated in the Statement of Work. to support DAP and PX.

The custom code, developed and maintained by Cardinal Path/Merkle (an addition to the Google Analytics core SaaS license that delivers a standard out-of-the-box solution) is a product of 10+ years of experience creating, adapting, and pivoting the code to new uses, Limited Sources Justification-FAR 8.4 - DAP Software-as-a-Service (SaaS) Web Analytics Subscription version 1.0 dated 08.20.2024

adding new functionality, and assuring best practices.

The custom code delivers a unique JavaScript library, the sophistication and intricacies of which have grown over a dozen years and continue to evolve in response to agency needs, industry changes, and Google updates to its new platform.

The custom code for DAP is unique due to the scope and scale it supports (8000+ government websites and hundreds of agencies), making Google Analytics implementation, updates, and patches possible across thousands of government websites and apps in a centralized, streamlined way. The key features include but not limited to 1) unification of hundreds of disparate measurement needs into a centralized data schema that ensures reporting and public visibility demands are met for all agencies, 2) centralization of proprietary PII redaction/prevention (removes/redacts PII while respecting agencies’ vast array of page and parameter naming conventions), 3) unification of search terms across all agencies, despite each agency’s unique implementations of search on their sites and inclusion of reporting parameters to reduce reporting cardinality, and 4) flexibility for agencies to further expand beyond automatically collected measurements while maintaining established governance over the widely adopted data schema.

The custom code for PX portfolio supports their public-facing websites including USA.gov, USAGov en Español, and vote.gov, which had about 80 million visits in FY2023. In addition, the PX Portfolio is in the process of taking control of the heavily-visited website Benefits.gov from the Department of Labor and integrating its content into the website USA.gov. This update to USA.gov is resulting in interactive web elements with a higher level of complexity in terms of analytics tracking than the Portfolio has completed before, and performing this transition in a quality manner is critical to Americans connecting with the government benefits that they are due.The custom code also supports Search.gov, a search engine used by about 36% of federal domains which has not completed its full transition to GA4 from Universal Analytics.

The estimated value is $ and an anticipated period of performance will include a 12-month base period.

(iv) Statutory Authority/ Supporting Rationale The authority to limit competition for this contract action is FAR 8.405-6(a)(1)(B) - Only one source is capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized, and the rationale for using this authority is outlined in the paragraphs below.

Five key factors have contributed to the need for an additional 12 months extension to

Limited Sources Justification-FAR 8.4 - DAP Software-as-a-Service (SaaS) Web Analytics Subscription version 1.0 dated 08.20.2024

retain Cardinal Path’s services until September 2025: 1) GA4 platform is new and constantly changing, 2) DAP went through a rapid expansion due to M-23-22 bringing hundreds of new websites and new requirements,3) procurement delays for BigQuery led to subsequent delays in obtaining Authorizations to Operate (ATO)s and the move to GSA infrastructure, and 4) understaffed DAP team with only one FTE (program director) and no staff developer having to rely on Cardinal Path’s DAP expertise. 5) PX Portfolio’s transition from UA to GA 4 is not complete.

Factor 1: GA4 Platform is new and evolving, requiring frequent DAP code updates

Less than 30 days ago, on July 1, 2024, Google sunset its legacy Google Analytics Universal Analytics (UA) platform, used by DAP for more than 12 years. As a result, the custom DAP code implemented on more than 8000 government websites across hundreds of U.S. federal government agencies was replaced by a new custom code to support a new Google platform - Google Analytics 4 (GA4).

Because the GA4 platform is still in Beta today, it is constantly undergoing releases of new features, updates, and bug fixes, on a level that was not present in the legacy UA product.

This makes it even more challenging for DAP and Cardinal Path|Merkle to be able to quickly respond to external changes to ensure stability and continuity of operations. The level of responsiveness is often urgent as it affects data and metrics in production on government websites, so it requires quick resolution, which necessitates the unique layers of knowledge, history, and programming mechanics of the team.

GSA did not anticipate this level of code development and enhancement a year ago as the expectation was that Google’s GA4 platform will have become more mature by July 1, 2024.

As a result, GSA continues to rely on Cardinal Path’s constant involvement to support the constant changes and finetune the DAP custom code accordingly. In fact, since the release on June 26, 2024, the new DAP code already has gone through three additional versions, constantly striving to meet complex, varied, and evolving reporting and tracking requirements to maintain current best practice standards in a data reporting landscape subjected to ongoing changes in privacy regulation and technologies.

To ensure DAP code stability and continuity of web metrics collection and reporting across thousands of websites as required by OMB M-23-22, it is critical that Cardinal Path continues to support and enhance the DAP code for 12 months to ensure its stability and maturity and prevent data integrity issues.

Factor 2: DAP grew by 30% in less than a year leading to new requirements and more

Limited Sources Justification-FAR 8.4 - DAP Software-as-a-Service (SaaS) Web Analytics Subscription version 1.0 dated 08.20.2024

support

As a result of the OMB M-23-22, which requires federal executive agencies to use DAP, the program experienced significant growth (700+ new government websites joined DAP) in the last few months. As a result, new additional use cases had to be accommodated and added as new requirements for DAP code changes as agencies have different missions and requirements when it comes to their websites. In fact, since September 2023, DAP received and solved more than 2000 helpdesk tickets, resulting in the majority of Cardinal Path’s support hours spent on ad-hoc requests for code modifications and enhancements. As more agencies and websites continue to join DAP even to date, DAP must remain steady and ready to continue to support and iterate through the releases.

To ensure DAP code stability and continuity of web metrics collection and reporting across thousands of websites as required by OMB M-23-22, it is critical that Cardinal Path continues to support and enhance the DAP code for 12 months to ensure its stability and maturity and prevent data integrity issues.

Factor 3: DAP BigQuery and Looker Studio Pro Procurement delays led to ATO delays

As a result of the Universal Analytics platform sunset, nearly 12 years of historical DAP gov-wide data was going to be discarded. To ensure that the historical data was saved for future use, GSA had to acquire a BigQuery data warehouse before July 1, 2024. The original target for the data migration was March 2024, however, there were significant delays in procuring the tool (nearly 3 months) due to the complexity of the product and GSA’s requirements. As a result, the DAP BigQuery project was not set up until the end of May 2024, giving just one month for Cardinal Path to transfer the historical data to BigQuery (vs.

a planned 12 week migration). This also led to re-prioritizing the setup of the data warehouse to first migrate the data before the deadline, which resulted in further delays for ATO (Authority to Operate) activities, documentation, delta assessment etc.

GSA CISO requires that DAP goes through multiple delta assessments before BigQuery can be transitioned to GSA’s ownership as part of the ATO. At this time, DAP BQ and Looker Studio Pro (the new visualization tool) are hosted in the Cardinal Path development environment as the GSA is working toward the delta assessments for their ATO before it can move to GSA’s Google Cloud Platform (GCP) infrastructure. Due to the 3 month delay in procuring BigQuery and further complications related to the UA sunset deadline, the original target for the ATO - February 2025 - has been pushed to the end of May 2025.

While the ATOs are being pursued for the DAP BigQuery and Looker Studio Pro platforms, any disruption to the billing structure and contractor support could affect the success of DAP. ATO support and documentation for BQ and Looker is currently being drafted by

Limited Sources Justification-FAR 8.4 - DAP Software-as-a-Service (SaaS) Web Analytics Subscription version 1.0 dated 08.20.2024

Cardinal Path, so changing inputs for this documentation mid-process would be costly in both timeliness and dollars spent in compiling the first go-round. Additionally, the bespoke nature of the DAP implementation directly correlates to how the implementations of both BQ and Looker should be approached and put in place when GSA transfers the data warehouse to be under the GSA infrastructure. The current state safeguards against any delays that could occur with receiving the ATOs (if any extension of hosting and reporting of the historical data is required, M|CP is uniquely positioned to maintain the continuity of services with no risk of data loss until the ATOs are in place and the GSA stands up its own BigQuery environment.

Factor 4: DAPs lack of federal staff and in-house GA4 expertise led to an over reliance on the contractor's custom development.

Historically, the DAP team did not have staff developers and only one FTE (DAP program manager), so it relied heavily on Cardinal Path javascript developers to do 100% of all development of the custom DAP code. The DAP legacy Google Analytics platform (Universal Analytics), after the costume code was built in 2013-14, was stable and well known, requiring few releases (e.g. there was only one code release between 2019 and 2023).

However, a migration to a brand new platform (GA4) in 2023 necessitated a complete redesign of the original DAP custom code and reporting through continuous iterations, needing unique GA4 expertise at the DAP scale and on-going development and monitoring (e.g. there were nine DAP code releases just in the last 10 months). Not having a federal staff developer on DAP to understand the custom code and the intricacies and nuances to make it work across more than 8000 websites gov-wide on GA4 resulted in an over reliance of DAP on the Cardinal Path’s development and GA4 expertise.

Factor 5: PX Portfolios transition from UA to GA 4 is not complete.

The PX Portfolio and Cardinal Path have made progress on transitioning websites to GA4, however the transition is still not complete. Search.gov in particular requires extensive support to finish their transition. Furthermore, none of our programs have completed their important integrations between GA4 and other services which add crucial functionality to PX’s web analytics programs. These in-process integrations provide permanent back-up capabilities to PX’s data in order to avoid unacceptable data loss. They also allow for more complex analysis of PX data and access to a greater breadth of data than GA4 by itself.

Finally, the integrations allow for a more efficient creation and maintenance of data visualizations for the consumers of our data, such as product managers and content creators. These consumers rely on the insights that PX’s data provides and require it in a

Limited Sources Justification-FAR 8.4 - DAP Software-as-a-Service (SaaS) Web Analytics Subscription version 1.0 dated 08.20.2024

timely manner, so the ability to minimize time and effort spent creating the visualizations is critical.

Path Forward

By the end of the 12-month extension, the DAP team supported by Cardinal Path and GSA’s Information Security teams, will have stabilized DAP GA4 custom code, automated releases via GSA’s Github actions, and transferred and ATO’d the DAP BigQuery and Studio Looker Pro in GSA’s Google Cloud Platform infrastructure. Meeting these critical milestones in the next 12 months will make the DAP ecosystem more stable and secure, supported by the GSA federal resources and infrastructure and an incoming new federal DAP developer with GA4 expertise to make the DAP team significantly less dependent on Cardinal Path unique historical knowledge and expertise and ready for open market competition. Furthermore the transition from UA to GA4 for PX will be complete.

As a result, the contract action associated with this justification seeks to allow critical support to be provided to DAP and PX while allowing the Government sufficient time to solicit, evaluate, negotiate and award a new contract mechanism for GA4 360 Web analytics subscription support services on a full and open basis. Given the current circumstances, E-Nor LLC is the only capable source to provide the required web analytics subscription support services for this Order under GSA MAS contract GS-35F-0651Y.

If this action is not approved, it will have the following detrimental effects to DAP:

1. DAP will no longer be able to provide web analytics real time and historical data and reports to 8,000+ federal executive branch agency websites resulting in agency non-compliance with OMB M-23-22 that states “Agencies are required to participate in GSA’s government-wide Digital Analytics Program (DAP)” (M-23-22, Section III-A, Subsection 6).

2. GSA will be out of compliance with the OMB M-23-22 where agencies must participate in DAP to collect public-facing website agency data as part of the government-wide web analytics account.

3. Hundreds of agencies and more than 4000 DAP federal registered users will experience irretrievable data loss from the only web analytics tool they have and will no longer be able to determine the effectiveness of their digital services to the public.

4. The public will lose the only window into the government-wide web traffic data transparency via analytics.usa.gov.

If this action is not approved, it will have the following detrimental effects to PX:

● Irretrievable data loss affecting all of its websites, which would impact the public

Limited Sources Justification-FAR 8.4 - DAP Software-as-a-Service (SaaS) Web Analytics Subscription version 1.0 dated 08.20.2024

experience and the Portfolio’s ability to track trends that are often relied upon when responding to requests from stakeholders such as OMB.

● Lack of actionable data to help monitor and improve vote.gov. This would be deleterious at any time, but particularly following the launch of a new site in July 2024 and during a presidential election year.

● Lack of actionable data to help monitor and improve USA.gov and USAGov en Español.

This would be deleterious at any time, but particularly as PX plans to launch new benefits-related content in August 2024. This work was requested in the Executive Order on Transforming Federal Customer Experience and Service Delivery to Rebuild Trust in Government. Through this EO, the PX Portfolio had been asked to “serve as a centralized, digital ‘Federal Front Door’ from which customers may navigate to all Government benefits, services, and programs, and features streamlined content, processes, and technologies that use human-centered design to meet customer needs, including consolidating content currently appearing on Benefits.gov, Grants.gov, and other appropriate websites.” The Department of Labor-run Benefits.gov will be decommissioned in September 2024 with redirects to USA.gov and USAGov en Español.

The PX Portfolio is expected to report data surrounding these transition efforts to OMB, the Department of Labor, and other federal agencies.

● USA.gov’s publicly shared analytics dashboard would no longer be functioning if there is an interruption to our GA4 360 account. As mandated by the Department of Homeland Security (DHS), USAGov is identified as the primary source of information delivery for timely and urgent Government information to the public. USAGov supports the Emergency Support Function 15 of the National Response Framework, where DHS has the authority to coordinate all Government communications during incidents of national significance and GSA's Continuity of Operations Planning. Lack of actionable data to help monitor and improve USA.gov and USAGov en Español during times of emergency would be unacceptable.

(v) Contracting Officer Determination that orders represents the best value In accordance with FAR 8.404(d), GSA has already determined the prices of supplies, fixed-price services, and rates for services offered at hourly rates under schedule contracts to be fair and reasonable. Prior to award, the Contracting Officer will make the determination that the Order represents the best value to the Government by comparing the overall price to the IGCE and published schedule prices. Additionally, the Contracting Officer will also request discounts to the GSA Contract pricing in accordance with FAR 8.405-4.

(vi) Description of Market Research and the Results Limited Sources Justification-FAR 8.4 - DAP Software-as-a-Service (SaaS) Web Analytics Subscription version 1.0 dated 08.20.2024

market research was not conducted In accordance with FAR 10.002(b)(2), market research was conducted for the current acquisition from May to June 2023. This market research is within 18 months of this effort and is therefore considered current and acceptable. In this market research, schedule holders were considered as part of the market research effort. The full details of the market research effort and resulting conclusions for this procurement can be found in the Market Research Report.

(vii) Any Other Supporting Facts No other facts have been identified to support this justification.

(viii) Actions taken to remove or overcome barriers to competition The Government will seek a fully competitive award to be in place upon expiration of this one year GSA MAS task order. Additionally, TTS will continue to revisit software subscriptions being used and review other manufacturer’s products that will be compatible in future procurements as technology evolves. As alternatives are identified, TTS may choose to submit them to GSA IT for approval, increasing the available ecosystem of tools. TTS project teams will continue to perform market research on available alternatives, whether in terms of a reseller for GA4 360 on IT 70 or an alternative technology stack, aiming to increase competition in accordance with the ordering procedures outlined in FAR 8.4.

Certifications

(ix) Contracting Officer certification In accordance with FAR 8.405-6(c)(2)(ix), I certify that the justification is accurate and complete to the best of my knowledge and belief.

Jennifer Gherardini Date Contracting Officer GSA/TTS/Acquisition Division

Limited Sources Justification-FAR 8.4 - DAP Software-as-a-Service (SaaS) Web Analytics Subscription version 1.0 dated 08.20.2024

(x) Technical/requirements certification In accordance with FAR 8.405-6(c)(2)(x), I certify that the supporting data provided, which form the basis for this justification, are complete and accurate to the best of my knowledge and belief.

(xi) Approvals In accordance with FAR 8.405-6(d), the following approvals are hereby documented in this Limited Source Justification.

Jackie Xu Date Competition Advocate

Ann Lewis Date TTS Director Head of Contracting Activity

Limited Sources Justification-FAR 8.4 - DAP Software-as-a-Service (SaaS) Web Analytics Subscription version 1.0 dated 08.20.2024