Redacted JandA.pdf

CUI//SP-PROCURE//FEDCON

Control Number: JA-26-Adel-0164

JUNE 2025

JUSTIFICATION REVIEW DOCUMENT

FAR Part 6 Justification and Approval for Other than Full and Open Competition

Program/Equipment: Multilingual Computing and Analysis Scientific Research, Development, Testing, Analysis and Data Generation Support Services

Authority: Title 10 U.S.C 3204(a)(5) as implemented by FAR 6.103-5(b)(1) “Authorized or required by statute.” Refer to FAR Part 6.103-5(c)(1) and FAR Part 19.106-3(a) Service Disabled Veteran Owned Small Business Program – Sole Source Awards

Amount:

Reviews: I have reviewed this justification and find it adequate to support other than full and open competition.

6/3/2026

X

Legal Counsel

Signed by: USA

JUNE 2025

FAR Part 6 Justification and Approval for Other than Full and Open Competition

1. Requiring Activity:

Adelphi, Maryland 20783-1138

2. Contracting Activity:

Army Contracting Command – Aberdeen Proving Ground (ACC-APG)

Adelphi Contracting Division 2800 Powder Mill Road

Adelphi, Maryland 20783-1138

3. Description of Action: The requests an Indefinite-Delivery, Indefinite-Quantity (ID/IQ) contract with Advanced Resource Technologies, INC. (ARTI), CAGE: 0E9T1, 1650 King Street Suite 350, Alexandria, Virginia, 22314-2747, United States.

The Government projects award for June 2026 and it is anticipated that Research, Development, Test, and Evaluation (RDT&E) funds will be used for orders placed under the contract.

4. Description of Supplies/Services: The purpose of this procurement is to provide linguistic expertise to conduct four (4) basic types of Research and Development (R&D) work in support of the (BIS); the four (4) basic categories are as follows:

1) Linguistic data development, processing and refinement to enable Natural Language Processing (NLP) and NLP-based technology R&D

2) Computational Linguistics and Computer Science research support

3) Hardware and Software test and evaluation

4) Computer system and application programming, computer system administration;

software design, development, integration, testing, and evaluation

The objective of this effort is to obtain: scientific research, development, experimentation, testing, analysis and linguistics-based data generation support in achieving cutting edge research; novel technological solutions for Army NLP, information processing and knowledge management challenges; and to fully support the wide variety of projects and programs that make up the ARL Multilingual Computing and Analysis mission. Native speakers of low-density languages are required for ARL

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projects, such as Afghan Dari, Pashto, Iraqi Kurdish, and African-accented French, all from specific communities.

ARTI will be providing R&D services through individually issued task orders that support the above-mentioned R&D initiatives.

Ordering Period: Five (5) Years Total Value: $5,000,000.00

5. Authority Cited: Title 10 U.S.C 3204(a)(5) as implemented by FAR 6.103-5(b)(1) “Authorized or required by statute.” Refer to FAR Part 6.103-5(c)(1) and FAR Part 19.106-3(a) Service Disabled Veteran Owned Small Business Program – Sole Source Awards

6. Reason for Authority Cited:

a. Background: As described in FAR 6.103-5(b)(1), full and open competition need not be provided when a statute expressly authorizes or requires that the acquisition be made through another agency or from a specified source, or the agency’s need is for a brand name commercial item for authorized resale. This action meets the following regulation requirements and will be awarded to a Small Disadvantaged Veteran Owned Small Business (SDVOSB) concern on a sole-source basis in accordance with (IAW) FAR 19.106-3(a).

FAR Part 6.103-5 specifically states that the 6.103-5(b) “Authorized or required by statute” authority may be used: “(1) . . . when statutes, such as the following, expressly authorize or require that acquisition be made from a specified source or through another agency:”, and (c)(1) Sole-source awards of certain socio-economic small business concerns (see 15 U.S.C. chapter 14A) ARTI is a Small Disadvantaged Veteran-Owned Small Business (SDVOSB) that is eligible for sole source contract award under the cited authority. ARTI is currently the incumbent for the existing IDIQ contract (W911QX-20-D- 0012) which provides Multilingual Translation Services for BIS. Per the discussion that follows, ARTI is the only SDVOSB source capable of providing both linguistic expertise and computer science services.

BIS of ARL’s MISD requires scientific research, development, testing, analysis and data generation support to continue and extend efforts for the development, integration and customization of language technologies, including Optical Character Recognition (OCR), Machine Translation (MT), Speech Synthesis and Automatic Speech Recognition (ASR) for the U.S. Army and various ARL customers. A unique aspect of the support required is that the Contractor must provide personnel who are highly proficient in low density languages of military interest and who are also capable of performing software and system development tasks associated with research and testing.

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b. Alternatives: Over time, ARTI has developed a recruiting capacity which is highly successful in providing the type of technical Subject Matter Experts (SMEs) with the right foreign language backgrounds required to successfully support ARL requirements. Native speakers of low-density languages required for BIS projects, such as Afghan Dari, Pashto, Iraqi Kurdish, and African-accented French from specific communities, are often persons who have immigrated and who need some support to understand U.S. business requirements and work habits. While other businesses, both large and small, provide either technical research support or language expertise commensurate with those required, those businesses do not routinely provide personnel who possess both types of skill sets.

Language technology research and development work by the BIS makes extensive use of a unique human-in-the-loop method invented at ARL. Also described as a knowledge management approach with machine learning, this methodology is particularly well suited to technical language of the type used for training, mentoring and exchanging operational information with coalition partners. The methodology requires the use of very short software development cycles using statistical methods to capture, or learn terms, phrase structure and other linguistic information at an accelerated cadence compared to commercial methods. The role of the human expert in this methodology is very different from that of a traditional translator; every word, phrase and sentence produced has as its primary purpose the development of new software benefiting from the capture and reuse of expert human knowledge. Learning this mindset is not trivial, but ARTI personnel have, through their own operational structure and experience developed expertise which has evolved over years of work with BIS, therefore requiring limited to no onboarding training that would otherwise be required for an alternative vendor. ARTI uses local Team Leads to instruct their employees on the method. The same Team Leads perform editing and quality checks to ensure that the data generation and software development aspects of the languages receive the appropriate attention. ARTI is unique in its ability to perform within this framework without a significant ramp-up period which eliminates any schedule risks that would otherwise result in restricted and delayed research efforts in support of BIS projects. This directly benefits our customers by avoiding costly delays and ensuring timely project completion. This highly specialized work exists at the intersection of linguistics, computer science, the military domain, and cutting-edge research in areas like Artificial Intelligence (AI) and Machine Learning (ML). The integrated nature of the work prevents it from being compartmentalized, inevitably requiring personnel to possess expertise in each of these areas. However, professionals with this unique blend of skills are scarce in this field.

Should a contractor's personnel possess only a subset of these required skills, a significant training period, potentially lasting several months, would be necessary. Such a delay would disrupt ARL’s ability to perform ongoing customer-funded work, such as the Universal Translator – Maritime (ULTRA-MAR) project sponsored by the Office of Naval Research.

In addition to language experts with technical skills needed for scientific research support, an important aspect of these non-commercial R&D services required is bilingual subject matter expertise in narrow domains of military interest including, for example, training medical doctors for coalition partners such as the Afghan Army. R&D efforts on behalf of the Combined Forces Theater Surgeon General for the Resolute Support mission in Afghanistan require access to bilingual SMEs for which the task at hand means an Afghan medical doctor with good knowledge of technical English and who writes medical Pashto with native proficiency. ARTI is highly successful in finding such persons, recruiting them, retaining them and thereby providing BIS with the required experts necessary to fulfill the requirements in support of the aforementioned effort. There is a particular style of employer-employee relations needed to overcome cross-cultural barriers and misunderstandings that frequently surface in this work environment with ARTI personnel working with, but not for the Government personnel.

ARTI management benefits from the successful completion of many urgent tasks requiring the technical skills of persons coming from very different cultures and language backgrounds. With this twin emphasis on computer science and bilingual technical expertise, ARTI is unique in being the only SDVOSB source ready to provide the required services.

c. Impact if not approved: If the Justification and Approval is not approved, delays will ensue that will impact the safety and threaten the lives of U.S. soldiers and coalition partners. A contractor other than ARTI would require a significant training period, potentially lasting several months, which would disrupt ARL’s ability to perform ongoing customer-funded work. Specific projects supported by this effort include the Algorithmic Warfare Cross-Functional Team’s Captured Enemy Materials effort, which uses artificial intelligence technologies to accelerate human processing of perishable information contained in captured devices. Another key project supported by this effort that will be impacted by delays is a set of ongoing agreements to provide low-cost speech translation devices for use by small military teams operating on a short-term basis in Africa while conducting training missions. These teams need an expanded capacity to communicate with their African counterparts and with local nationals who speak accented versions of world languages, such as central African-accented French and north African Arabic. Delays in providing the services required by this contract impede the communication capabilities of U.S. military teams, resulting in more misunderstandings, reduced safety, and impaired operational efficiency.

7. Efforts to Obtain Competition: The Contracting Officer will publish the notices required by FAR 5.201 and any bids or proposals received shall be considered.

a. Effective competition: Effective competition is not anticipated for this acquisition. The intended awardee is the incumbent contractor with a proven record of successfully self-performing the vast majority of historical contractual requirements, making them uniquely qualified to continue performance without risk to the program.

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b. Subcontracting competition: A subcontracting plan is not required in this case because the contractor qualifies as an SDVOSB, and the requirement to submit such a plan applies to other than small business concerns. Nevertheless, the Contracting Officer shall include FAR 52.244-5, Competition in Subcontracting, which requires that contractors select subcontractors (including suppliers) on a competitive basis to the maximum practical extent consistent with the objectives and requirements of the contract.

8. Actions to Increase Competition: Prior to the next procurement of these services, the Government will conduct updated market research, including a sources sought notice and review of current SDVOSB and small business capabilities, to determine whether competition is feasible. The Government will specifically reassess the minimum mission and safety requirements, evaluate whether any proprietary or unique capability assumptions remain valid, and structure the requirement, to the maximum extent practicable, to remove unnecessary barriers to competition while meeting the Government’s needs.

A Sources Sought Notice was posted on SAM.gov on 13 March 2026 for ten (10) business days. The Government received capability statements from six (6) small businesses, including the incumbent contractor. A technical evaluation of the submissions determined that five (5) of the respondents did not demonstrate the capability to meet the Government’s minimum requirements. Specifically, their proposed solutions significantly deviated from the Performance Work Statement (PWS). Awarding to a vendor with an inadequate technical approach would mandate an extensive ramp-up period and steep learning curve. This poses an unacceptable risk of failure for customer-funded projects and would adversely impact ongoing military operations.

Consequently, the Government determined that only one (1) responding vendor possesses the minimum capability to meet mission requirements. The incumbent contractor, ARTI, an SDVOSB, submitted a capability statement that fully aligned with the PWS. As a result, ARTI, Inc., is the only SDVOSB capable of meeting the Government’s minimum requirements for this action.

9. Market Research: Market research and evaluation was conducted between September and December 2025 by a Subject Matter Expert (SME), with nearly 20 years of experience in foreign language technology development and technical translations for security assistance.

In their capacity, the SME maintains continuous engagement with the foremost language technology experts within the Army and the wider DoD community. The expert insights obtained from these discussions support the SME’s assessment of the market:

the nature of the services is so specialized that there are no known contractors, regardless of socioeconomic status, capable of providing the totality of the requirements mentioned in Section 5. While various contractors can perform certain components, such as foreign language support or software development, experimentation, data development for machine learning, and software test & evaluation, the requirements are

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deeply synergistic. Attempting to carve out these elements would negatively affect these interdependencies, introducing significant performance risks and inefficiencies.

After extensive market research, it was determined that ARTI is the only SDVOSB that can offer both the bilingual SMEs and computer sciences services needed to meet the Government’s minimum requirements in accordance with the requirements detailed in paragraph 5 above.

A Synopsis Justification & Approval and Request for Information (RFI) will be posted on SAM.gov for five (5) business days.

10. Interested Sources: As of 03 June 2026, no other sources have written to express interest.

11. Other Facts:

a. Procurement history.

(1) Contract Number and Date:

W911QX-11-D-0012, awarded on 29 September 2011

(2) Competitive Status:

Other than Full and Open

(3) Authority Cited:

10 U.S.C. 2304(c)(1) as implemented by FAR 6.302-1(a)(2)(ii) – Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.

(4) Explanation of Change in Competitive Status:

Not Applicable. Based on available records and institutional knowledge, W911QX-11-D-0012 is understood to be the first contract awarded to ARTI in support of BISB’s multilingual computing efforts. As such, there is no prior competitive status from which to report a change.

(5) Explanation of Any Unusual Patterns:

Not Applicable.

(6) Explanation of Protests Received:

W911QX-16-D-0021, awarded on 25 August 2016

(2) Competitive Status:

Other than Full and Open

(3) Authority Cited:

10 U.S.C. 2304(c)(5) as implemented by FAR Part 6.302-5 – Authorized or Required by Statute. Refer to FAR Part 6.302-5 (b)(6) -- Sole source awards under the Veterans Benefits Act of 2003 (15 U.S.C. 657f).

(4) Explanation of Change in Competitive Status:

Not Applicable. The predecessor to W911QX-16-D-0021 was also awarded on an Other Than Full and Open basis.

(5) Explanation of Any Unusual Patterns:

(6) Explanation of Protests Received:

W911QX-20-D-0012, awarded on 25 September 2020

(2) Competitive Status:

Other than Full and Open

(3) Authority Cited:

10 U.S.C. 2304(c)(5) as implemented by FAR Part 6.302-5 – Authorized or Required by Statute, further implemented by FAR Part 6.302-5 (b)(6) -- Sole source awards under the Veterans Benefits Act of 2003 (15 U.S.C. 657f).

(4) Explanation of Change in Competitive Status:

(5) Explanation of Any Unusual Patterns:

This action represents the third (3rd) consecutive sole-source award to the same contractor; this pattern highlights the contractor’s unique capabilities in successfully supporting and expanding ongoing R&D efforts and also its unique position as a SDVOSB operating in this space.

(6) Explanation of Protests Received:

b. Other facts. Not Applicable

12. Technical Certification: I certify that the supporting data under my cognizance, which are included in the justification, are accurate and complete to the best of my knowledge and belief.

Lead Research Scientist

13. Requirements Certification: I certify that the supporting data under my cognizance, which are included in the justification, are accurate and complete to the best of my knowledge and belief.

Contracting Officer

Signed by:

14. Fair and Reasonable Cost Determination: I hereby determine that the anticipated price/cost to the Government for this contract action will be fair and reasonable. This determination will be made using cost analysis, independent Government estimate, in accordance with FAR 15.403-4(a)(1). As part of the basis, certified cost or pricing data will or will not be required.

Contracting Officer

Signed by:

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

JUNE 2025

6/3/2026

X

Contracting Officer

Signed by:

Approval

Based on the foregoing justification, I hereby approve the procurement of Multilingual Computing and Analysis Scientific Research, Development, Testing, Analysis and Data Generation Support Services on an other than full and open competition basis pursuant to the authority of Title 10 U.S.C 3204(a)(5) as implemented by FAR 6.103-5(c)(1) Sole source awards of certain socio-economic small business concerns. The estimated value of the new Indefinite-Delivery/Indefinite-Quantity (IDIQ) contract is $5,000,000.00 for a five-year (base and four one-year options to include FAR 52.217-8) period of performance from 05 April 2026 to 04 April 2032. The approval is subject to availability of funds, and provided that the supplies and/or services herein described have otherwise been authorized for this acquisition.

Contracting Officer

Signed by: