NNG15SD30B 36C10B25F0207 Justification And Approval _Redacted.pdf

JUSTIFICATIONFOR AN EXCEPTION TO FAIR OPPORTUNITY

1. Contracting Activity: Department of Veterans Affairs (VA) Office of Procurement, Acquisition, and Logistics Technology Acquisition Center 23 Christopher Way Eatontown, NJ 07724

2. Description of Action: The proposed action is for award of a firm-fixed price delivery order under the terms and conditions of the National Aeronautics and Space Administration (NASA) Solutions for Enterprise-Wide Procurement (SEWP) V Governmentwide Acquisition Contract (GWAC) for the purchase of brand name NVIDIA subscriptions and associated maintenance.

3. Description of the Supplies or Services: VA Office of Research and Development (ORD) Center for Data & Computational Science (C-DACS) has a requirement for quantity of 3 brand name NVIDIA virtual Graphics Processing Unit (vGPU) RTX virtual Workstation (vWS) concurrent user (CCU) subscription licenses, which includes associated Support Updates and Maintenance Support (SUMS). The included SUMS shall consist of periodic updates, access to all upgrade releases (minor and major), bug fix releases, enhancements, and corrections to the software, and 24X7X365 technical support by e-mail and phone. Technical support shall include telephone coverage during weekdays, weekends, and holidays. Escalation support is provided during standard local business hours of 8:00 a.m. to 5:00 p.m., Monday through Friday.

Additionally, VA requires a quantity of 3 brand name NVIDIA AI Enterprise Essentials subscription-based software licenses, and quantity of 3 Support Services for NVIDIA AI Enterprise Essentials in support of the existing NVIDIA A40 and A100 Data Center (DC) GPU hardware residing at the ORD C-DACS offices in Boston, Massachusetts and Pittsburgh, Pennsylvania. The required brand name requirement hereafter shall be simply referred to as brand name NVIDIA subscriptions and maintenance. All software license keys shall be delivered within 30 days of award.

These subscriptions shall cover a period of performance of one 12-month base period and three subsequent 12-month option periods, if exercised. The total estimated price for this action is

, inclusive of all options.

4. Statutory Authority: Pursuant to Federal Acquisition Regulation (FAR) 16.505(a)(4), the following brand name requirement is being justified and approved as an exception to fair opportunity under the statutory authority of Section 41 U.S.C. 4106(c)(2) as implemented by FAR Subpart 16.505(b)(2)(i)(B), titled “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”.

5. Rationale Supporting Use of Authority Cited Above: Based on market research, as described in section 8 of this justification, the required brand name NVIDIA subscriptions are the only software architecture software capable of integrating into and supporting the internal virtualization of the existing NVIDIA A40 and A100 Data Center (DC) Graphics Processing Unit (GPU) hardware located at the ORD offices in Boston, Massachusetts and Pittsburgh, Pennsylvania.

VA purchased NVIDIA A40 and A100 DC GPU hardware as part of a competitive acquisition in February 2022 to upgrade the ORD C-DACS High-Performance Computing (HPC) environment.

VA-25-00056801 Brand Name NVIDIA virtual Graphics Processing Unit Software

The C-DACS HPC environment consists of the NVIDIA A40 and A100 DC GPU. The NVIDIA A40 and A100 DC GPU environment provides specialized parallel processing capabilities, Tensor Cores for Artificial Intelligence (AI) and Machine Learning (ML) (AI/ML) computations, and robust NVIDIA software libraires (e.g., CUDA, cuDNN, TensorRT). The advanced NVIDIA virtualization and multi-instance GPU (MIG) enables efficient resource sharing in multi-tenant HPC environments while preserving performance of the NVIDIA A40 and A100 GPU.

During fiscal year 2025, VA identified a requirement to allocate and segment resources virtually within the NVIDIA A40 and A 100 DC GPU environment. VA has determined that an internally virtualized environment would accelerate tasks such as Artificial Intelligence modeling, large-scale data analytics, and high-performance computing without the need for multiple specialized hardware clusters. By moving the processing tasks from the Central Processing Unit (CPU) and segmenting the tasks on the NVIDIA A40 and A100 DC GPUs, this would create a virtualization environment that increases processing speed for single-precision floating point (FP32) format, increased throughput, improved efficiency in graphics and computer workflows all while providing the ability to concurrently run ray tracing, AI/Machine Learning, and data science modeling. The NVIDIA hardware and included firmware that VA seeks to internally virtualize operate on a proprietary source code, exclusive to NVIDIA. As such, any internal virtualization software must be able to seamlessly interoperate with that underlying code and the components thereof. Therefore, in order to appropriately virtualize and segment off the vGPU resources, access to NVIDIA’s proprietary source code is required. While similar like virtualization software solutions exist, primarily for external solutions, no other solution, other than the proposed brand name NVIDIA virtual vGPU RTX vWS, AI Enterprise Essentials and AI Enterprise Essentials Support Services can provide the required functionality required for this procurement.

Further, any maintenance support updates, maintenance support, periodic updates, upgrade releases (minor and major), bug fix releases, enhancements, corrections to the software must be seamlessly interoperable with the existing NVIDIA hardware. Code generated by any other source introduces risk that the entire solution would be affected and thereby create unacceptable vulnerabilities. As such, this effort must be executed as proposed.

6. Efforts to Obtain Competition: Market research was conducted, details of which are in section 8 of this justification. This effort did not yield any additional sources that can meet the Government’s requirements. However, the undersigned VA technical representative determined that limited competition is available among authorized resellers for brand name NVIDIA vGPU RTX vWS software CCU licenses with associated SUMS, AI Enterprise Essentials, and AI Enterprise Essentials Support Services as required by this action. It was determined that limited competition exists between Veteran-Owned Service-Disabled Small Businesses (SDVOSBs). In accordance with FAR 16.505(a)(4)(iii)(A)(1), this justification will be provided with the solicitation to all appropriate NASA SEWP V GWAC holders. Furthermore, in accordance with FAR 5.301, 16.505(b)(2)(ii)(D), and 16.505(a)(4)(iii), the award notice for this action will be synopsized on the Contract Opportunities website and this justification will be made publicly available within 14 days of award.

7. Actions to Increase Competition: The Government will continue to conduct market research to ascertain if there are changes in the marketplace that would enable future actions to be competed.

8. Market Research: The Government’s technical experts conducted web-based market January 2025 through April of 2025 by reviewing similar virtualization software, support upgrades and maintenance support from competing software companies, including Advanced

Micro Devices (AMD), Intel Corporation (Intel), and GPU providers, to ascertain if any other source could meet VA’s requirements for an internal virtualization solution. The Government’s technical experts determined that the aforementioned sources do not meet the requirements described in paragraph 5 above.

Additional market research was performed in March 2025 by reviewing sources on the NASA SEWP Market Research Report for authorized NVIDIA resellers. The report resulted 21 Service- Disabled Veteran Owned Small Business (SDVOSB) authorized resellers. As a result, there is a reasonable expectation for two or more VetCert SDVOSB vendors can provide the brand name NVIDIA licenses, warranty, and support. As such, this action will be set aside to SDVOSBs Certified under VetCert in Groups B1, B2, C and D under NASA SEWP V GWAC.

9. Other Facts: None

10. Technical and Requirements Certification: I certify that the supporting data under my cognizance, which are included in this justification, are accurate and complete to the best of my knowledge and belief.

11. Fair and Reasonable Cost Determination: I hereby determine that the anticipated price to the Government for this contract action will be fair and reasonable based on the comparison of proposed prices received in response to the solicitation from responsive, acceptable offerors. Additionally, the successful quote will be compared to the NASA SEWP V GWAC published pricelist of the Offeror. NASA V SEWP GWAC prices already being determined to be fair and reasonable. Finally, the successful quote may be compared to the Independent Government Cost Estimate.

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