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FY25 IBM-PPA Software License & Maintenance Control Number : VA-25-00000488 as the method by which file transfers between VA and these other government agencies will take place. Each ISA/MOU must be negotiated individually with the other government agency and before another vendor’s software could be used, all four agencies would also have to agree to switch to another vendor and coordinate projects to test and switch to that other vendor. This would be a massive undertaking that would need to be an addition to each agency’s roadmap and coordinated and implemented as a long-term project.

The use of Connect: Direct to send and receive files with the other government agencies is essential. The ISA/MOU with Department of the Treasury specifies that Connect: Direct will be used to transfer benefit payment data to processes monthly compensation and pension Veteran’s benefits payments in excess of $13 billion to approximately 7 million Veterans. In Fiscal Year 2023, over $150 billion in compensation and pension benefits were paid. The payment files were transferred to the Department of the Treasury using Connect: Direct. Furthermore, with the implementation of the Sergeant First Class Heath Robinson Honoring our Promise to Address Comprehensive Toxics Act of 2022 (PACT Act), this major change initiative that led to VA expanding benefits to Veterans of different eras impacted by military environmental exposures led to a surge in additional benefits claims that resulted in additional payments needing to be sent to Treasury for payment using Connect: Direct.

VA also uses Connect: Direct to send and receive files containing Federal Tax Information (FTI) to the IRS several times a week. These Connect: Direct files containing FTI updates are crucial for making pension benefits determinations. VA has begun conversations with the IRS to eliminate the Connect: Direct file transfer process in favor of a redesigned process in which VA would make Application Programming Interface (API) calls directly to the IRS. However, this project is not currently funded.

Once funding is approved, development, testing, and implementation is estimated to take at least three years. IBM Sterling Connect: Direct is the only product that can meet VA requirements without the need for significant rework and cost expenditure. Only IBM or an authorized reseller can provide the IBM Sterling Connect: Direct Premium edition software subscription licenses and maintenace required to perform seamless and integrated file transfer. No other manufacturer’s software licenses are compatible, or interoperable with the existing VA infrastructure. VA has researched other products and an acquisition of a different product requires a full migration requiring dedicated release cycles, a full regression and performance test across more than 20 different VA applications and Product Teams which will put Veteran benefits payments at risk. In addition, VA requires a seamless and integrated enterprise solution that is compatible with and runs on Linux, Solaris UNIX, and IBM z/OS Operating Systems.

Lastly, only IBM or an authorized reseller has access to the IBM Sterling Connect:

Direct Premium Edition SW subscription proprietary code and therefore can provide the subscription and support services to develop and implement software upgrades and updates to that code. This access is required for the provisioning of the software as well as maintenance support inclusive of; troubleshooting, updates, fixes, patches, and upgrades. This software and maintenance is vital to VA for continued sustainment of VA’s ability to perform file transfers between agencies.

serves. The new tool is anticipated to be ready for national release at the beginning of Calendar year 2027 after thorough testing and incremental deployment.

Only one year of IBM GKLM is required, as the EBU team has entered the final stages of a full platform replacement. Once fully implemented the GKLM keys will be obsolete through the attrition of stored data. The data attrition will occur with combination of the new EBU platform providing data protection for current VA government data and the retention expiration of the retention for data protected with GKLM keys.

No other manufacturer’s software licenses are compatible, or interoperable with the existing VA infrastructure. Additionally, these vendors only offer software maintenance and technical support for their own proprietary product.

The Government contacted IBM in July 2024 to confirm that the software contains proprietary elements and can only be provided by IBM or its resellers. IBM confirmed in July 2024 that their software contains proprietary source code and only IBM and its resellers can access the source code to provide the required software maintenance support.

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

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. Additionally, pricing for products awarded on NASA SEWP V GWAC have already been determined to be fair and reasonable and more competitive pricing may result from competition. Finally, if necessary, the proposed pricing will be compared to the Independent Government Cost Estimate.

12. Contracting Officer Certification/Approval I certify that this justification is accurate and complete to the best of my knowledge and belief. This contract action exceeds the simplified acquisition threshold, but does not exceed $750,000, therefore, the certification required by FAR 16.505(b)(2)(ii)(A) serves as the Contracting Officer’s approval.