A.3 Determination Only One Source is Reasonably Available – Commercial Acquisitions OverSAT - JROTC Insignias - Redacted.docx

Navy Marine Corps Acquisition Regulation Supplement FEBRUARY 2026 (Change 26-02)

J&A Number: M00264-26-JA-011

ANNEX 1 – JUSTIFICATION AND APPROVAL

UNITED STATES MARINE CORPS

MARINE CORPS INSTALLATIONS NATIONAL CAPITAL REGION

MARINE CORPS BASE QUANTICO

3250 CATLIN AVENUE

QUANTICO VIRGINIA 22134 5001

J&A Number: M00264-26-JA-011

JUSTIFICATION AND APPROVAL

FOR USE OF OTHER THAN FULL AND OPEN COMPETITION

1. Contracting Activity.

The Contracting Activity is the Marine Corps Installations National Capital Region – Regional Contracting Office (MCINCR-RCO), located at 2010 Henderson Road, MCB Quantico, VA. The requiring activity is Marine Corps Junior Reserve Officers’ Training Corps (MCJROTC) Program, Training and Education Command (TECOM) located at, MCB Quantico, VA 22134.

2. Description of Action Being Approved.

The action being approved is an exception to fair opportunity to fulfill a brand‑name requirement for the Marine Corps Junior Reserve Officers’ Training Corps (MCJROTC) Program. The requirement consists of a follow‑on procurement for approximately 481,250 Vanguard‑manufactured items, including rank insignias, MCJROTC‑specific rank devices, marksmanship badges, ribbon bars, and mounts. These uniform components directly support MCJROTC curriculum execution for nearly 37,000 cadets across 248 schools located within the continental United States (CONUS) and outside the continental United States (OCONUS).

This action is intended to result in a brand‑name award for Vanguard products to ensure standardization, curriculum compliance, and uniform accuracy across all MCJROTC units.

3. Description of Supplies/Services.

The Marine Corps Junior Reserve Officers’ Training Corps (MCJROTC) Program, under Training and Education Command (TECOM), requires the continued procurement of MCJROTC‑specific rank devices, marksmanship badges, ribbon bars, and mounts. These items must fully comply with MCJROTC curriculum standards, which include instruction on the proper wear of the cadet uniform and the correct placement of rank, ribbons, and awards. Uniform accuracy is also a graded component during Drill and Ceremony competitions, where cadets are evaluated on proper wear and placement of insignia.

Vanguard Insignias supports these requirements by producing uniform items that meet Marine Corps specifications for quality, accuracy, and durability. Their products align with established MCJROTC uniform regulations and ensure consistency across all participating units.

The Government intends to issue a Firm Fixed Price (FFP) award with fixed-price CLINS. This requirement requires delivery within 120 days after date of award.

The total estimated value for this procurement is $.00 inclusive of all option periods. Appropriate Operations and Maintenance (O&M) funds will be used to fund this requirement as outlined in the table below:

4. Statutory Authority Permitting Other Than Full and Open Competition.

This acquisition is conducted under the commercial procedures of FAR 12.102(b) Restricting Competition, and limiting competition is authorized under 10 U.S.C. 3204(a)(1), Use of procedures other than competitive procedures.

5. Rationale Justifying Use of Cited Statutory Authority.

The MCJROTC program requires uniform items that must match existing standardized components worn by nearly 37,000 cadets across 248 CONUS and OCONUS schools. These items including rank insignias, MCJROTC‑specific rank devices, marksmanship badges, ribbon bars, and mounts must be identical in color, material weight, stitching, sizing, and appearance to maintain compliance with Marine Corps uniform regulations. Uniformity is not a preference; it is a core training requirement. Cadets are evaluated on proper wear of the uniform during inspections and Drill and Ceremony competitions, and inconsistent insignia would directly affect grading, fairness, and program credibility.

Vanguard is the only responsible source capable of meeting these minimum needs. Vanguard maintains proprietary tooling, dye lots, embroidery patterns, and quality‑control processes that produce items identical to those currently fielded across all MCJROTC units. These production methods are not commercially replicable without reverse‑engineering, which introduces variation. The Government does not possess technical data packages that would allow other vendors to reproduce these items to the required standard. As a result, only Vanguard can ensure exact matches to existing inventory and maintain program‑wide standardization.

Alternative vendors cannot guarantee the level of precision required. Even minor deviations in color shade, stitching pattern, material weight, or sizing—differences acceptable in commercial retail markets—would be immediately noticeable in a military training environment. Such inconsistencies would undermine uniformity, create inequity during graded inspections, and result in non‑compliance with Marine Corps uniform standards. These risks directly affect mission execution and the program’s ability to maintain a professional, standardized appearance across all units.

Market research and past performance identified two commercial vendors Mil‑Bar and LA Speedy that manufacture insignia or embroidered uniform items. Both vendors produce general‑purpose insignia suitable for commercial or organizational use; however, neither demonstrated the ability to meet the strict uniformity, repeatability, and compliance requirements of the MCJROTC program. Their production methods rely on commercial dye lots, non‑military stitching patterns, and batch‑based manufacturing that introduce variations unacceptable for Marine Corps uniform standards.

The following table summarizes the results of the market research and highlights the specific areas where these vendors were unable to meet the Government’s minimum needs.

Past performance further demonstrates the risk of using non‑incumbent vendors. A previous supplier shipped incorrect items, resulting in substantial additional labor, delays, and unplanned costs to correct the error. This incident shows that the risk of receiving non‑conforming items is not hypothetical. Ensuring accuracy and avoiding repeat disruptions requires reliance on a vendor with a proven record of delivering compliant items without excessive oversight.

Transitioning to a new vendor introduces significant administrative and operational burdens. Instructors would be required to conduct additional quality‑control checks, manage mixed inventories, and identify non‑compliant items. Across 248 schools, this equates to thousands of labor hours diverted from instruction and cadet development. If deviations are discovered after distribution, the program would be forced to conduct a full reissue of compliant items, effectively doubling procurement costs and generating additional logistical expenses for redistribution, collection, and disposal. This represents an inefficient use of taxpayer funds and would disrupt program continuity.

Based on mission requirements, regulatory compliance obligations, market research, and documented performance risks, only Vanguard can meet the Government’s minimum needs without introducing unacceptable cost, schedule, and compliance risks. For these reasons, limiting competition is justified under FAR 12.102 and the statutory authority at 10 U.S.C. 3204(a)(1). Awarding to an authorized reseller of Vanguard products ensures continuity, compliance, and preservation of Marine Corps standards across the MCJROTC program.

6. Description of Efforts Made to Solicit Offers From As Many Offerors as Practicable.

Over the past two years, the Government conducted extensive outreach to identify potential sources capable of producing MCJROTC uniform insignia that meet the program’s strict requirements for standardized appearance, repeatability, and compliance with Marine Corps uniform specifications. The Government engaged with multiple commercial manufacturers, including BHPE, Mil-Bar, Glendale Paradestore, and Vanguard and requested information on their production methods, quality‑control processes, and ability to replicate existing MCJROTC insignia.

As part of this effort, the Government reviewed commercial vendor databases, searched publicly available market information, and evaluated sample items provided by interested firms. These samples consistently demonstrated unacceptable variation in color consistency, fabric weight, embroidery precision, and sizing tolerances. No vendor was able to demonstrate the capability to reproduce the precise, repeatable characteristics required to maintain uniformity across approximately 37,000 cadets in 248 MCJROTC units.

Based on this market research, the Government determined that the brand-name Vanguard products for uniform items possess the specific, repeatable characteristics required to maintain standardized appearance across all units. The proprietary patterns, dye lots, embroidery specifications, and manufacturing controls associated with the brand‑name items are essential to meeting the Government’s minimum needs. Although multiple vendors expressed interest, none demonstrated the capability to produce items that match the required brand‑name characteristics. Accordingly, the Government concludes that specifying the brand‑name product is necessary to ensure uniformity, consistency, and compliance with MCJROTC standards.

7. Determination of Fair and Reasonable Cost.

The Contracting Officer will determine the anticipated price under this brand‑name, sole‑source action to be fair and reasonable by comparing the contractor’s quoted pricing to published commercial price lists, historical prices paid by the Government for the same items, and other commercially available market information. Market research indicates that the contractor’s pricing is consistent with standard commercial practices for these proprietary items and reflects the contractor’s established catalog pricing. Based on this analysis, the Contracting Officer concludes that the anticipated cost is fair and reasonable.

8. Actions to Remove Barriers to Future Competition.

TECOM will continue to evaluate opportunities to reduce barriers to competition while maintaining MCJROTC uniform standardization. These actions include documenting detailed technical specifications for all insignia and uniform components, identifying proprietary design elements, and assessing whether equivalent products can be qualified through testing or certification. The Government will also review whether future requirements can be structured to allow multiple vendors to meet MCJROTC uniform standards without compromising consistency, accuracy, or compliance with Marine Corps regulations. Prior to any subsequent acquisition, the contracting office will reassess these barriers to determine whether competition can be increased or whether a brand‑name requirement remains necessary.

CERTIFICATIONS AND APPROVAL

TECHNICAL/REQUIREMENTS CERTIFICATION

I certify that the facts and representations under my cognizance which are included in this Justification and its supporting acquisition planning documents, except as noted herein are complete and accurate to the best of my knowledge and belief.

Technical/Requirements Cognizance:

LEGAL SUFFICIENCY REVIEW

I have determined that this Justification is legally sufficient.

CONTRACTING OFFICER CERTIFICATION

I certify that this Justification is accurate and complete to the best of my knowledge and belief.

DISTRIBUTION: DoD COMMUNITY ONLY

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