Redacted JA- CCAT.pdf

Determination that Only One Source is Reasonably Available (Including Brand Name) – FAR Part 13 Acquisitions under the SAT

V 1.6 (20 December 2023)

MEMORANDUM TO THE FILE

Subj: DETERMINATION THAT ONLY ONE SOURCE IS REASONABLY AVAILABLE FOR

A FAR PART 13 ACQUISITION UNDER THE SIMPLIFIED ACQUISITION THRESHOLD

I. BACKGROUND:

1. FAR 13.106-1(b)(1)(i) states for purchases not exceeding the simplified acquisition threshold, Contracting Officers may solicit from one source if the Contracting Officer determines that the circumstances of the contract action deem only one source reasonably available (e.g., urgency, exclusive licensing agreements, brand-name, or industrial mobilization).

2. As required by FAR 13.106-3(b)(3)(i), this memorandum explains the absence of competition for this acquisition, as only one source will be solicited for this requirement (or for a portion of the requirement) and the requirement (or portion of the requirement to be sole-sourced) is not expected to exceed the simplified acquisition threshold.

II. DESCRIPTION OF ITEM OR SERVICE:

Manpower and Reserve Affairs (MRA), Manpower Plans Division, Studies, and Analysis Branch (MPA) is requiring Renewal on Criteria Corporation Cognitive Aptitude Test (CCAT) Subscription. The CCAT software is required because it will give MRA an MPA the ability to test officers’ aptitude and intelligence markers. The CCAT was created by Criteria Corp., which is a private company that provides applicant screening and talent management solutions for civilian business of varying size.

This is a follow-on-effort on contract M0026420P0023.

Source or Brand Name: Criteria Corporation.

The period of performance is for one (1) Base Year of 12 months and four (4) 12-month option years. Support Coverage for this requirement starts on 14 January 2025.

Base Year: 14 January 2025 – 13 January 2026

CLIN

Number

Brand Name /

Manufacturer

Item / Description Manufacturer

Part Number

Quantity

0001 Criteria Corp. Cognitive Aptitude Testing Subscription

Coverage Period: 14 January 2025 – 13 January

N/A 1

Option Year 1: 14 January 2026 – 13 January 2027

Number

Brand Name /

Manufacturer

Item / Description Manufacturer

Part Number

1001 Criteria Corp. Cognitive Aptitude Testing Subscription

Coverage Period: 14 January 2026 – 13 January

Determination that Only One Source is Reasonably Available (Including Brand Name) – FAR Part 13 Acquisitions under the SAT

Option Year 2: 14 January 2027 – 13 January 2028

Number

Brand Name /

Manufacturer

Item / Description Manufacturer

Part Number

2001 Criteria Corp. Cognitive Aptitude Testing Subscription

Coverage Period: 14 January 2027 – 13 January

Option Year 3: 14 January 2028 – 13 January 2029

Number

Brand Name /

Manufacturer

Item / Description Manufacturer

Part Number

3001 Criteria Corp. Cognitive Aptitude Testing Subscription

Coverage Period: 14 January 2028 – 13 January

Option Year 4: 14 January 2029 – 13 January 2030

Number

Brand Name /

Manufacturer

Item / Description Manufacturer

Part Number

4001 Criteria Corp. Cognitive Aptitude Testing Subscription

Coverage Period: 14 January 2029 – 13 January

III. THE DETERMINATION FOR USE OF OTHER THAN FULL AND OPEN COMPETITION IS

BASED ON THE FOLLOWING (select all that apply):

A. _X ONLY ONE RESPONSIBLE SOURCE (select all that apply):

1. _X_ RESTRICTIVE RIGHTS. The source has established proprietary rights, limited rights in data, patent rights, copyrights or secret processes in the item or service required.

This is a follow-on-effort on contract M0026420P0023 issued by the Regional Contracting

Office. This effort was awarded to Criteria Corp. on 10 January 2020 as a Firm-Fixed Price

(FFP), Sole Source, with a Base plus four option year for a period of performance 14 January

2020 thru 13 January 2025. This effort was 100% Small Business set-aside.

The Criteria Corporation Cognitive Aptitude Test (CCAT) is a proprietary test to Criteria

Corporation. Other tests were compared to other standard measures of generical intelligence

(“g”), the magnitude of disparate impacted on protected subgroups exhibited by the CCAT is at or below that exhibited by most of assessment of its kind. Criteria Corp. is registered in the System for Award Management (SAM) as a small business under NAICS 541612.

Determination that Only One Source is Reasonably Available (Including Brand Name) – FAR Part 13 Acquisitions under the SAT

CCAT is considered a SaaS (Software as Service Platform), specifically designed for pre-employment assessment and talent evaluation, allowing companies to access and administer cognitive ability tests like the CCAT (Criteria Cognitive Aptitude test) online through a subscription model. Key point s about CCART and Criteria Corp as SaaS platform:

Accessibility:

- User can access the platform online, allowing them to administer tests to candidates anytime, anywhere.

Subscription based:

- Company typically pays a subscription fee to access the platform and administer tests to their candidates.

Data Analysis:

- The platform provides detailed reports and insights on candidate’s performance, enabling employees to make informed hiring decisions.

CCAT scores are the primary metric for measuring Marine Officer’s cognitive (intellectual) abilities. CCAT scores are used as data for officer assignment and classification tools to facilitate

Marine Officer Talent Management. The Marine Corps adopted the CCAT in December 2019 to replace the General Classification Test (GCT) as the sole in-service aptitude test for Marine

Officers. Since its adoption 7,076 Marine Officers have taken the CCAT. The CCAT scores from these 7,076 are a useful dataset for developing supervised machine learning models to predict outcomes at various professional milestones in a Marine Officer’s career.

CCAT, its test items, scoring system, and user interface are proprietary to the Criteria

Corporation. No other vendor provides the CCAT. Although other online cognitive testing services are available, the scores from these services are not directly comparable to the overall percentile, Math & Logic, Spatial Reasoning, and Verbal Ability scores provided by CCAT

Furthermore, CCAT’s test items (questions) and scoring system have been standardized against a large sample of America’s college educated civilian population to ensure normalcy within the data and prevent the test from exhibiting bias or unfairness against demographic minorities.

Documentation of the proprietary nature of CCAT can be found in the following reference:

Criteria Corp (2020) Criteria Cognitive Aptitude Test Validity and Standardization Information

Report, Criteria Corp, West Hollywood, CA.

Continued use of CCAT as the sole means of new officer cognitive testing, is important because it ensures continuity of scoring systems. In addition, continuity of scores is important because these scores are used as inputs to supervise machine learning models which require data with minimal changes in their underlying distributions. Put more simply, transitioning from one scoring system to another greatly complicates or nullifies the usefulness of that score data in predictive analytics.

In 2019 MPA conducted a study to identify a new cognitive test to replace the GCT as the means of measuring newly commissioned Marine Officer’s cognitive ability. Although freely available, the GCT was created in 1949 and is severally outdated and burdensome to administer to lieutenants at the Basic Officer Course. Some of the primary goals of the Marine Corps’ search for a replacement to the GCT was that the selected test should more accurately depict Marine

Determination that Only One Source is Reasonably Available (Including Brand Name) – FAR Part 13 Acquisitions under the SAT

Officer mental aptitude, decrease the race/gender bias, be appropriate to a college educated civilian population, and have multiple independent indicators of aptitude (i.e. Math, Verbal, etc.).

MPA also evaluated other tests for these features and found that only CCAT satisfied our service’s unique requirements without significant additional burdens or costs. The points below summarize other options that were explored to satisfy this requirement:

COA 1: GRE. The GRE does not provide quantitative measures of specific cognitive abilities

(i.e. mathematical vs. verbal ability) and cannot be administered at TBS without extensive logistic planning.

COA 2: LSAT. Cannot administered at TBS without extensive logistic planning. The LSAT also requires excessive time to administer. MPA examined multiple post-undergraduate tests with little resolve as they almost strictly predict performance in graduate school. Additionally, post-graduate.

The Government will continue to monitor the market and conduct market research to identify any emerging solutions that may satisfy future similar requirements. Should such solutions become available during the lifecycle of the current requirement, the Government will consider whether switching to and installing new systems is in the Government’s best interest, and regarding future similar requirements, seek competition to the maximum extent practicable

2. ___ EXCLUSIVE LICENSING AGREEMENTS. The item or service is only available from the Original Equipment Manufacturer (OEM), or there is only one authorized distributor or technical representative for the OEM.

3. ___ OTHER REASONS.

B. ___ BRAND NAME

Item required must be a brand name, product, or feature of a product, particular to one manufacturer.

C. ___URGENT AND COMPELLING. The supplies or services are of such unusual and compelling urgency that the Government would be seriously injured unless the agency is permitted to limit the number of sources from which it solicits bids or proposals. Urgent requirements are supplies or services that will result in a work stoppage or are mission critical and the routine processing time would result in injury to the Government. The determination that the procurement for the above item/service is an urgent and compelling requirement is based on the following:

1. Date on which the requirement was first identified:

2. Required delivery date/period of performance:

3. Explanation of why delivery/commencement of services by the date mentioned above is required: