REDACTED JA.pdf

CONTROL NUMBER: VA-26-00071517

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: This proposed action is for a firm-fixed-price, task order issued under the National Aeronautics and Space Administration (NASA) Solutions for Enterprise-Wide Procurement (SEWP) V Government-Wide Acquisition Contract (GWAC) for renewal of the brand name Qualtrics DesignXM Enterprise Software‑as‑a‑Service (SaaS) Platform for Government.

3. Description of the Supplies or Services: The Department of Veterans Affairs (VA), Veterans Health Administration (VHA), Office of Research and Development (ORD) has a requirement to renew the subscription of 1,000 enterprise user seats for the brand name Qualtrics DesignXM Enterprise SaaS Platform for Government, to include 300,000 CoreXM Short Message Service (SMS) Text credits.

This proposed action provides ORD with a secure, commercial-off-the-shelf, Federal Risk and Authorization Management Program (FedRAMP) certified High (Class D) research survey platform delivered entirely via Electronic Software Delivery.

The Government requires 1,000 subscription‑based access to the brand name Qualtrics DesignXM Enterprise Platform hosted in Amazon Web Services (AWS) GovCloud and authorized at the FedRAMP certified High (Rev 5, Class D) security baseline. VA requires a subscription that is capable of protecting the personally identifiable information (PII) and protected health information (PHI) of our Veteran respondents. VA requires a solution that provides longitudinal, respondent-level directory functionality that enables multi-year research tracking; advanced survey logic and branching functions; multi-modal distribution channels including web, email, and SMS within the authorized boundary; real-time analytics and enterprise dashboards; role-based administrative controls; full Section 508 accessibility compliance supported by a current Voluntary Product Accessibility Template or Accessibility Conformance Report. The platform’s integrated configuration, authorization boundary, and established enterprise deployment within VA collectively support ORD’s nationwide research mission by enabling secure collection and analysis of sensitive Veteran feedback and health-related survey data.

The Period of Performance will be a 3-month Base Period, from July 1, 2026 through September 29, 2026 and one 12-month Option Period. The total estimated value is , inclusive of the Option Period, if exercised.

4. Statutory Authority: This 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 Revolutionary Federal Acquisition Regulation (FAR) Overhaul (RFO) VA Deviation 16.507-6(b)(2), entitled “Only one awardee is capable of

Survey-Based Research Platform (Qualtrics SaaS) CONTROL NUMBER VA-26-00071517 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: The brand name Qualtrics DesignXM Enterprise Platform is essential to meeting VA ORD’s requirements as it is the only commercially available SaaS solution that meets VA’s requirements while operating within an existing FedRAMP certified High (Class D) boundary suitable for handling sensitive Veteran data. Qualtrics’ FedRAMP High certification (Rev5, Class D) is confirmed through the FedRAMP Marketplace and enables ORD to comply with federal cybersecurity requirements without undertaking an independent authorization effort.

ORD’s research model depends on a platform capable of longitudinal tracking of individual participants, multi‑modal data collection including SMS, advanced branching and experimental logic, and native text analysis features. Qualtrics’ XM Directory supports multi‑year research programs by maintaining secure, respondent‑level histories that can be used for repeated measures and long‑term outcome tracking.

Qualtrics is the only FedRAMP High solution that meets all of VA’s required elements.

The brand name Qualtrics DesignXM platform’s multi‑channel distribution, real‑time dashboards, analytics, and Section 508 accessibility support further satisfy VA’s technical, accessibility, and regulatory requirements. Additionally, Qualtrics maintains a Voluntary Product Accessibility Template and Accessibility Conformance Report, enabling the VA to comply with Section 508.

Alternatives products either do not possess a FedRAMP certified High (Class D), do not offer secure longitudinal research capabilities, or would require multiple distinct tools stitched together, introducing risk, complexity, and additional cost.

At ORD’s scale, order-of-magnitude transition costs to migrate surveys and panels, re-implement identity/encryption/auditing, and retrain users are estimated at over and is estimated to take 12 to 18 months. These estimates are based on previous acquisition history. The duplicated costs would not be recovered through competition.

Based on these factors, the brand name Qualtrics DesignXM platform is uniquely capable of meeting ORD’s needs.

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 could meet the Government's requirements. However, the undersigned VA technical representative determined that limited competition is available among resellers. In accordance with RFO 5.301, the award notice for this action will be synopsized on Contract Opportunities and the 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: Government technical experts conducted market research in April 2026 by researching FedRAMP Marketplace listings, publicly available vendor capability information, web based research, and NASA SEWP V acquisition readiness to determine whether alternative solutions could meet VA’s requirements. Specifically, the Government’s technical experts reviewed other similar solutions from vendors including Medallia GovCloud, QuestionPro Research GovCloud and SurveyMonkey. It was determined that Medallia GovCloud, although FedRAMP High authorized, does not offer the integrated longitudinal directory capabilities or demonstrated Section 508 accessibility compliance required for ORD’s research workflows. QuestionPro Research GovCloud is authorized only at FedRAMP Moderate (Class C) and unable to meet the required FedRAMP High impact level. In addition, QuestionPro does not provide SMS distribution within an authorized boundary. SurveyMonkey is widely used across federal agencies but does cannot support Veteran PII or PHI at the required impact level.

Additionally, market research was conducted in June 2026 through the use of the NASA SEWP V GWAC Provider Lookup Tool to determine whether brand name Qualtrics, LLC products are available from NASA SEWP V GWAC Contract holders. It was determined there are 38 NASA SEWP V GWAC holders that are approved resellers of Qualtrics, LLC products, with 11 Service-Disabled Veteran-Owned Small Business (SDVOSB) resellers that are approved resellers of Qualtrics, LLC products. Therefore, limited competition is anticipated among current NASA SEWP V GWAC holders that are SDVOSBs, and are approved resellers of brand name Qualtrics, LLC products for this proposed action.

9. Other Facts: None

10. Technical/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.

Date Program Analyst Office of Research and Development Veterans Health Administration Department of Veterans Affairs

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 anticipated competition and discounts among NASA SEWP V GWAC holders.

Additionally, NASA SEWP V GWAC has already determined the prices on contract to be fair and reasonable. Additional price analysis will be performed in accordance with RFO 15.404-1(b).

Contracting Officer Technology Acquisition Center Office of Procurement, Acquisition, and Logistics

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

Contracting Officer Technology Acquisition Center

Advocate for Competition Approval

In my role as procuring activity Advocate for Competition, based on the foregoing justification, I hereby approve the acquisition to renew the subscription of 1,000 enterprise user seats for the brand name Qualtrics DesignXM Enterprise SaaS Platform for Government, to include 300,000 CoreXM Short Message Service Text credits 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.

Advocate for Competition Technology Acquisition Center