Qualtrax JA_Redacted.pdf

J&A-Qualtrax Compliance Software

UNCLASSIFED

JUSTIFICATION AND APPROVAL

FOR OTHER THAN FULL AND OPEN COMPETITION

Contracting Agency: U.S. Army Corps of Engineers (USACE), Rock Island District, Rock Island, IL.

Description of Action: This action will result in a follow-on, firm fixed price commercial contract for the procurement of Qualtrax Compliance Software Licenses and Subscriptions.

Award will be made to Qualtrax Incorporated of Blacksburg, Virginia, in Fiscal Year (FY) 2021 utilizing Enterprise Reimbursable Cost (ERC) funding. The estimated dollar value is with the inclusion of four (4) one year option periods.

Description of the Supplies: Qualtrax is a complete quality and compliance software system used to manage and control documentation, automate business processes, manage customizable workflows, streamline training management, manage internal and external audits and ensure implementation of critical regulations in real-time. The procurement of Qualtrax Compliance Software Licenses and Subscriptions will allow the US Army Corps of Engineers (USACE) the ability to synchronize publications with Regional and District procedures, align lessons learned, after action reviews, and provide opportunities for improvement in a e stop automated information system. This system will enable USACE the ability to track standard business processes with metrics linked to strategic initiatives.

Authority Cited: As stated in 41 United States Code 1901 as implemented in Federal Acquisition Regulation 13.501, only one responsible source and no other supplies or services will satisfy agency requirements.

Reason for Authority Cited: In accordance with FAR 13.5 Simplified Procedures for Certain Commercial Items, Qualtrax Compliance Software Licenses and Subscriptions has been determined to be a commercial product that is offered and sold competitively in substantial quantities, under similar terms and conditions, to both the public and private sector. Accordingly, FAR 13.5 Simplified Acquisition will be utilized as the procurement of Qualtrax Compliance Software Licenses and Subscriptions will not exceed $7.5M

USACE is entering the final phase of the implementation process in which Qualtrax document repository.

a. Background: During the 4th quarter of fiscal year (FY) 2018, the USACE Management Action Group (UMAG) approved the replacement of the current USACE Enterprise Quality Management System (eQMS) SharePoint Site to a more robust software management tool, Qualtrax Automated Information System (AIS) in accordance with Army Regulation (AR) 702-11, with an effective date of 25 March 2014.

In November 2018, Army Regulation (AR) 702-11 was updated to prescribe Department of the Army policy and responsibilities for Army quality programs. This regulation sets forth policy and responsibilities in development, implementation, and sustainment of an Army Quality Program as an integral component of acquisition, logistics, and technology business areas. This regulation applies to all Army activities that acquire, provide, and produce products and services in support of acquisition, logistics, and technology missions.

Due to the updates in the Army Regulation (AR) 702-11, the Engineering Regulation 5-1- 14, was updated to reflect Qualtrax as the new USACE quality standard compliance tool which will provide procedural standardization across the Enterprise. It was determined the replacement of the current eQMS system allowed for greater quality and compliance for integrating, synchronizing, maintaining, and streamlining all USACE publications, regulations, policies and guidance.

The Enterprise Implementation Project Delivery Team (IPDT), which includes multiple Headquarters and Mission Center Quality Management Representatives (QMR) and Knowledge Management Representatives (KMR), have populated the Qualtrax software by linking all HQUSACE publications along with reviewing and migrating retained procedures to the new Enterprise Quality Management System.

In November 2018, the Rock Island District, in support of HQUSACE, procured Qualtrax Compliance Software Licenses and Subscriptions as part of Phase I of implementation, as directed by the applicable OPORD. This phase included the population of the Qualtrax software while linking all HQUSACE publications with an established milestone compliance date of 30 September 2019.

For compliance purposes, he Mississippi Valley Division reviewed and migrated the entire division to Qualtrax. This allowed for the strict focus on eliminating redundancy of eQMS documents and supplementing current HQ publications. Once completed, the remaining USACE Divisions and Districts proceeded with review and migration of all eQMS documents to Qualtrax. This included Great Lakes and Ohio River Division (LRD), Pacific Ocean Division (POD) and the Northwestern Division (NWK), which had to maintain contact with the National Quality Program Manager to migrate eQMS documents to Qualtrax to ensure no interference with current ISO 9001: 2015 certification for quality.

b. Justification: The previous QMS lacked the ability to view processes holistically, had poor search capabilities, and was difficult to use and maintain. The new Enterprise Qualtrax Management System has the ability to synchronize HQUSACE publications with Regional and District procedures, align Lessons Learned (LL), After Action Reviews information system. The new enterprise system will become the enabler to track USACE standard business processes with metrics linked to strategic initiatives. The Qualtrax software maintains documents, handles nonconformities, helps with risk avoidance and mitigation actions, maintains training records, and prepares the user for audits.

Qualtrax has served USACE for over 16 years, with current integration of Qualtrax Automated Information System in the Great Lakes and Ohio River Division. This integration is being pushed through all levels of USACE, at the direction of the Chief of Engineers and USACE Commanding General and will be known on all levels of the enterprise as the new Enterprise Quality Management System (QMS). Qualtrax software is exclusively produced, supported, and distributed by Qualtrax Incorporated and is only available for purchase directly from Qualtrax Incorporated in Blacksburg, Virginia.

The enterprise implementation is currently in phase II, which aligns all of the retained procedures, with milestone completion of 30 September 2020. Phase III will commence upon the completion of phase II and requires the Enterprise to reach full operational capability. This includes identifying metrics associated with the procedures, and the ability to determine where gaps, non-conformances, and improvement opportunities, which has expected milestone completion of 30 April 2021.

Furthermore, costs associated with front end expenses would not be anticipated with a follow-on contract, but these costs would be duplicated in a competitive award to a new contractor. The costs associated with front end expenses include preparation of the following:

IT certifications Software procurement Training Proposal discounts Loss of Lakes & Rivers Division ISO 9001:2015 Certification

Duplication of Cost-IT Certifications-

Department of Defense Instruction (DoDI) 8500.01, Cybersecurity, and DoDI 8510.01, Risk Management Framework (RMF) for DoD Information Technology (IT), incorporates a Platform IT (PIT) that is both IT hardware and software that is physically part of, dedicated to, or essential in real time to the mission performance of special purpose systems. Prior to initiating any processes, the Network Enterprise Technology Command (NETCOM) has to make a determination if the risk to organizational operations, organizational assets, individuals, other organizations, or the Nation is acceptable. Upon approval, NETCOM issues a, Interim Authority to Test (IATT). Upon a system review, the Approval Official will determine if the process is acceptable or unacceptable. Thus allowing for testing and trials.

Upon the IATT approval, the Enterprise Implementation Project Delivery Team began conducting trials and training on the Qualtrax Software three (3) years prior to the operational order to initiate the implementation phase. During this phase, the Project Delivery Team obtained a statement of non-availability from the Computer Hardware, Enterprise Software and Solutions (CHESS) office for contracted supplies/services in accordance with the Secretary of the Army Waiver Process for Commercial-Off-the-Shelf Information Technology (COTS-IT) Procurement outside the CHESS Program.

In February 2017, a Statement of Non-Availability (SoNA) was requested an obtained from CHESS for the continued support of the Qualtrax software within the Louisville District of the Great Lake and Ohio River Division. This waiver set the stage for continued system integration while providing a continued software access for Louisville to maintain the required ISO 9001:2015 Certification as required by the applicable Army and Engineering Regulations.

This included obtaining the proper software certifications and applicable waiver from the Army Chief Information Office, CIO/G6. This validated the subject requirement and provided the official approval known as the IT Approval System Waiver in March 2017.

All together this process took almost three (3) years.

Duplication of Cost- Initial Training & Subscription (Phase I & Phase II)-

In December 2018, the Rock Island District procured access for 150 dedicated users, 80 concurrent users and 12,000 basic users. This also included all subscription fees, initial training fees, refresher training fees and 10 additional user passes during the training conferences. This access was obtained on a standard volume discount as implemented by phase I and phase II, which required across the board point access.

Duplication of cost- USACE Partner Discount- :

The current requirement entails the honoring of 2020 Enterprise Platform pricing which entails 151 dedicated users, 80 concurrent users and the entire enterprise access, which is approximately 32,000 users. This access includes up to 14 passes at the user conference, 4 hours of monthly project management access during operational years of 2020/2021, along with 25 hours, per month, of remote training and consultant during the years of 2020/2021. USACE partner discount of is applied to all years with an additional . This discount was pre-established based on the number of years in which Qualtrax and USACE have been in partnership of this implementation.

c. Alternatives: There are no alternatives as the implementation of Qualtrax as the U.S.

Army Corps of Engineers Quality Management program as directed in Engineering Regulation 5-1-14 USACE Quality Management System and Army Regulation 702-11 Army Quality Program by order of the Secretary of the Army.

d. Impact: It has been concluded that it is in the best interest of the Government to pursue a follow-on contract to negate the duplication of cost in excess of , as contained in the breakout cost, if the requirement were to start from the beginning.

Delaying the follow-on contract will result in reduced functionality and possible loss of the Louisville District ISO 9001:2015 certification.

6. Efforts to Obtain Competition: In accordance with FAR 5.203, Publicizing and Response Time, an intent to sole source notification was posted to the Government Point of Entry, Federal Business Opportunities, on 29 May 2020 with a response date of 19 June 2020. No responses and no capabilities were received in response to this notice.

7. Actions to Increase Competition: This justification supports a proprietary requirement that is in the final stages of obtaining a three (3) year Authority to Operate certification from ACE-IT.

This certificate allows for the implementation of an Automated Information System (AIS) within the Corps network. As such, this certificate is reviewed annually and re-certified every three (3) years which may allow for a cost benefit analysis to overcome any barrier of competition in future requirements. To keep with this, the Qualtrax system has a sunset date of 2030 which allows for additional actions to determine whether the benefit of competition outweighs the cost of overcoming any barrier or replacing the entire system.

8. Market Research: Market research was performed prior to the initial solicitation and approval of the Qualtrax software and is considered appropriate to the circumstances. The Enterprise Implementation Project Delivery Team conducted test trials and training of the Qualtrax Software for an extended period and continues to compare initial performance to other compliance software. Although there are other quality management software programs, the implementation of an already established system with other USACE Divisions is the most advantageous approach as directed by Army Regulations and Engineering Regulations.

Interested Sources: To date, no other sources have written to express interest.

Other Factors:

Approval

Based on the foregoing justification, I hereby approve the procurement of the Qualtrax Compliance Software Licenses and Subscriptions on an other than full and open competition basis pursuant to the authority of 10 U.S.C.2304(c) FAR 13.501 subject to availability of funds, and provided that the services and property herein described have otherwise been authorized for acquisition.

Date: ______________________ Signature:

Name:

Alternate Advocate for Competition-Atlanta US Army Corps of Engineers