P03 KeySight JA Final signed redacted.pdf

KeySight Hardware Maintenance and Technical Support Control Number: VA-26-00008431

JUSTIFICATION FOR 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 a firm-fixed price delivery order to be issued under National Aeronautics and Space Administration (NASA) Solution for Enterprise-Wide Procurement (SEWP) V Governmentwide Acquisition Contract (GWAC) for brand name KeySight hardware maintenance and technical support.

3. Description of Supplies or Services: The Department of Veterans Affairs (VA), Office of Information & Technology (OIT) Infrastructure Operations (IO), Infrastructure Cybersecurity Management (ICSM) has a requirement for brand name KeySight IXIA hardware maintenance and technical support. Technical support shall be conducted via telephone, e-mail, or internet to troubleshoot malfunctioning equipment/components or provide replacement equipment/components that restore full operation and accessibility to the original redundant component configuration.

Additionally, hardware maintenance will include firmware upgrades and updates to include major, point, service and security releases. These updates will occur on a quarterly basis, and/or within 48 hours in cases where a high-risk vulnerability fix becomes available. The maintenance is required to ensure the hardware remains operational. This action is for VA owned hardware maintenance and technical support services only.

The period of performance is a 12-month Base Period, with two (2) 12-month Option Periods. The total estimated value of the proposed action, inclusive of the Option Periods, is

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 16.505(b)(2)(i)(B), entitled 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 .

5. Rationale Supporting Use of Authority Cited: Based on market research, as described in Section 8 of this document, it was determined that limited competition is available among authorized resellers for this requirement. The current VA IO infrastructure is based on existing proprietary KeySight hardware and VA requires support and maintenance compatible with the existing infrastructure protocols and functionality for continued operational availability. The existing KeySight devices in use across five IO data centers can only interoperate and communicate with other KeySight devices through proprietary source code. Due to this proprietary KeySight code, no other brand of hardware maintenance and technical support will be able to and Technical Support Control Number: VA-26-00008431 deliver compatible and seamlessly interoperable fixes/updates to the current brand name KeySight infrastructure. Specifically, both the administrative control interface, which controls the network visibility fabric, and the physical device interfaces for clustering and load balancing are proprietary to KeySight, allowing for the integration into the existing KeySight infrastructure across the Enterprise. As such, a responsible source for the required hardware maintenance and technical support must have access to the proprietary source code to develop, test and push patches, updates and functionality through the fabric manager that will seamlessly interoperate with this infrastructure. The fabric manager is critical for this infrastructure because it manages and tracks the KeySight firmware in use, allows VA to view firmware versions, and detects issues with KeySight equipment and software. Any push, patch, or update not developed by KeySight or its authorized resellers introduces unacceptable risk to the entire environment. Additionally, without access to the proprietary source code, a vendor cannot test/validate full functionality or how the patch will interact with the rest of the deployed system. For instance, if there was an issue with a patch/update, and it was not seamlessly interoperable, it could create an unknown vulnerability to the entire system that would have otherwise been avoided.

Furthermore, a responsible source must be an authorized reseller of the brand name services to have access to replacement parts that are proprietary to KeySight to meet form, fit, and function of the existing solution.

Due to these proprietary constraints, the use of any alternative vendor maintenance and technical support services will necessitate a complete replacement of the existing VA owned KeySight infrastructure in place.

system with a different product would require multiple costs. Specifically, implementation of a different solution would require replacing all components of the KeySight platform. Replacement of the aforementioned IO infrastructure would cost an estimated $2.3 million in equipment and training costs and would require an estimated two years to transition to the new platform. The estimated duplication of time and costs are based on previous similar procurements. The two-year transition tool the current production KeySight production architecture and retrain VA staff on how to use it. Furthermore, this two-year transition also accounts for the time that would be required for VA employees to secure training to develop behavior analysis configuration to simulate what KeySight offers. Therefore, only brand name KeySight effort.

Failure to acquire KeySight maintenance and technical support would leave VA with inhibited ability to perform its security mission, reducing the agencies capability to monitor and identify potential threats. Only brand name KeySight products will meet the requirements to integrate and interoperate with the existing KeySight-based infrastructure.

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 However, it was determined that limited competition is viable among authorized resellers for brand name KeySight Hardware Maintenance and Technical Support. In accordance with FAR 16.505(a)(4)(iii)(A)(1) and Technical Support Control Number: VA-26-00008431 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 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: In June 2025, Government technical subject matter experts

(SMEs) conducted web-based market research to ascertain if any other non-proprietary but fully compatible and functional hardware maintenance and technical support is available. The VA SMEs compared hardware maintenance and technical support from various vendors, such as CommView and Solar Winds Netflow, who have similar offerings and determined that none have access to the proprietary source code required to maintain the existing KeySight infrastructure. No other manufacturer has the capability of developing and issuing hardware maintenance for KeySight to support existing IO requirements. The products researched were unable to meet the functional requirements and integration with existing VA owned installed hardware and no other product other than KeySight Hardware Maintenance and Technical Support are able to meet these requirements. Additionally, hardware maintenance from any other provider except KeySight requirements outlined in Section 5 of this document. Only KeySight Hardware Maintenance and Technical Support

The Contract Specialist conducted additional market research by issuing Request for Information (RFI) No. 361589 from October 9, 2025, through October 20, 2025, on the NASA SEWP V Government-Wide Acquisition Contract (GWAC) website. The RFI sought information regarding brand name Keysight IXIA Hardware Maintenance and Technical Support services.

One (1) Service-Disabled Veteran-Owned Small Business (SDVOSB) response included a Rough Order of Magnitude (ROMs), seven (7) responses indicated interest in submitting proposals. Among these, three (3) respondents were Women-Owned Small Businesses (WOSB), one (1) was a Small Business, one (1) was a Hubzone and two (2) were a Service-Disabled Veteran-Owned Small Business (SDVOSB). The RFI was revised due to questions received. No alternative proposals were received.

To address this issue, the Contract Specialist contacted the customer to resolve the discrepancies between the part numbers and quantities listed in the RFI. The customer and Contract Specialist convened a brief meeting to strategize a path forward. As a result, the Contract Specialist and customer made several revisions to revised PD was finalized on October 15, 2025, and subsequently posted to the RFI on October 16, 2025. The RFI closed on October 20, 2025.

Additionally, a second RFI (Notice ID: 36C1B26Q0034) was posted on SAM.gov from October 9, 2025, through October 20, 2025. Although no ROMs were submitted, and Technical Support Control Number: VA-26-00008431 seven (7) responses were received expressing interest. Of these, two (2) were Small Businesses, two (2) were SDVOSBs, and three (3) respondents did not provide business classification information.

SEWP V GWAC Provider Lookup Tool. The market research was performed in August 2025 utilizing the NASA SEWP V GWAC Provider Lookup tool to determine availability of KeySight Hardware Maintenance and Technical Support, which resulted in the identification of 88 authorized vendors from Groups B, C, and D. Specifically, there are 24 Service-Disabled Veteran-Owned Business (SDVOSB) authorized resellers. As a result, there is a reasonable expectation for limited competition on the

NASA SEWP V GWAC.

9. Other Facts: Not applicable.

and Technical Support Control Number: VA-26-00008431

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.

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 anticipated competition and discounts among multiple value-added resellers of the required brand name description herein. Additionally, pricing products awarded under NASA SEWP V GWAC have already been determined to be fair and reasonable.

Finally, further price analysis of quotes received will be conducted to determine fair and reasonable price.

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

and Technical Support Control Number: VA-26-00008431

Approval

In my role as procuring activity Advocate for Competition, based on the foregoing justification, I hereby approve the acquisition for brand name KeySight Hardware Maintenance and Technical Support on an other than fair opportunity basis pursuant to the authority cited in Section 4 above, subject to availability of funds, and provided that the property and services herein described have otherwise been authorized for acquisition.

Technology Acquisition Center Office of Procurement, Acquisition, and Logistics Department of Veterans Affairs