07-01-16

Request for One Time Exemption from Competition from

Idaho Division of Purchasing (DOP)

Agency Purchasing Representative: JP Brady

E-mail/Phone: JP.Brady@dhw.idaho.gov 208-334-5999

Name of Agency: Health & Welfare (Department)

Request for the Purchase of: Safety Paper

Cost (attach quote): $71,456.00

IDAPA 38.05.01.042.05 provides that the administrator may exempt an acquisition from competitive procurement if the administrator determines that bidding is impractical, disadvantageous or unreasonable under the circumstances.

Examples include but are not limited to: special market conditions; property requiring special contracting procedures due to uniqueness; and services for which competitive solicitation procedures are impractical.

Background The Department’s Idaho Bureau of Vital Records is responsible for registering, safeguarding, correcting and issuing certified copies of birth, death, marriage, and divorce records. Issuing certified vital records is a core function and an essential public service relied upon by Idaho residents for school enrollment, government benefits, Real ID and passport applications, estate administration, and other vital legal processes.

The Bureau’s Customer Service Unit prints and issues these records daily and requires approximately 4,000 sheets of safety paper per week. This paper is highly specialized and incorporates intaglio features, serialization, and other embedded security elements. Reliable paper performance is necessary to provide our customers’ the certificates they need and to maintain operational efficiency. Any disruption in paper quality or availability directly affects the bureau’s ability to issue certified copies of vital records and results in our citizens not having the vital records they need for their purposes. We must have a highly reliable supply of paper to ensure that we can meet our customers’ needs.

Description Since becoming the State’s contracted supplier for vital records safety paper in May 2024, BCA has exhibited a repeated pattern of manufacturing defects, supply issues, and insufficient corrective actions. These failures have compromised Idaho’s ability to produce secure certificates and have created substantial operational, compliance, and service risks. Key issues include:

Note: the contract began on May 13, 2024

1. Intaglio Border Defect (Feb–Apr 2025)

• Inconsistent border spacing and drifting intaglio lines found across reams; outside contract specifications.

• BCA submitted a corrective action report and committed to providing 50,000 replacement sheets.

2. Intaglio Ink Offsetting & Supply-Driven Delays (May–Jun 2025)

• Ink offsetting was discovered at the production plant due to incomplete curing during rewinding.

• Root cause traced to upstream ink variation.

mailto:JP.Brady@dhw.idaho.gov https://adminrules.idaho.gov/rules/current/38/380501.pdf

• Replacement ink production delayed by raw material shortages; insufficient quantities prevented timely production.

• Resulted in delays to the promised 50,000-sheet replacement order.

3. Defects in the 50,000-Sheet Replacement Order (Dec 2025 – Jan 2026)

• Severe print failures: creasing, misfeeds, jams, skewed prints, and one printer disabled.

• Issues disappeared when older paper was used, confirming defects were isolated to BCA stock.

• Approximately 25% of certificates required reprints; satellite offices experienced identical failures.

• Additional creasing reported in specific serialized ranges.

• Staff forced to print in small batches to monitor quality, reducing production capacity.

4. Inadequate Corrective Action Report (Feb 2026)

• BCA reported no defects found and recommended the bureau change its paper handling procedures.

• Bureau testing confirmed defects occurred only with BCA paper, contradicting BCA’s conclusions.

5. Independent Third-Party Testing Confirms Defects (Feb–Mar 2026) A certified laboratory analyzed multiple samples and found measurable specification failures:

• Paper thickness below minimum requirement.

• Excessively high porosity.

• Laboratory concluded that the porosity levels likely caused the wrinkling and creasing observed.

These results contradicted BCA’s February 2026 corrective action report and confirmed that the replacement shipment was out of specification.

6. Production Delays and Equipment Failures (May–Aug 2026)

• Production stalled due to parts held in customs.

• August 6, 2026: Intaglio plate broke during printing, halting production.

• Shipment delayed into late August, placing Idaho’s inventory at risk of depletion.

7. Continued Defects in New Replacement Stock (Aug 2026)

• Testing of newly delivered replacement paper showed inconsistent performance.

• Creasing issues significant enough to require testing by the ream.

8. Operational and Compliance Risks

• Staff forced to open sealed boxes for testing, compromising Standard bureau operating procedures.

• Substandard paper risks rejection of Idaho-issued certificates by other states or federal agencies.

• Repeated failures increased waste, reprinting orders, staff downtime, increased staff time for testing a higher percentage of paper and customer service delays.

Justification BCA has demonstrated ongoing, multi-cycle failures in manufacturing, quality control, supply chain management, and corrective action responsiveness. These issues have directly impaired the bureau’s ability to issue vital records—documents essential to Idaho residents and required for numerous legal and governmental processes.

Given the documented history of defects, delays, and risks, competitive procurement is impractical at this time. The Department currently has just over 6 weeks of known, good quality paper on hand and a large supply of paper of unknown quality. The testing we have done suggests that we have a paper supply of inconsistent quality. Due to the critical nature of these documents to Idaho citizens, we cannot risk running out of paper. Therefore, the Department requests a one-time exemption from competition, for one (1) year, to obtain safety paper to meet State requirements and allow the Department enough time to end the contract with BCA and issue a new solicitation. The exemption will allow a continual supply of paper, protect the State’s operational continuity, and ensure Idaho citizens continue to receive vital records in a timely manner.

Agency Certification: The information provided above is true and accurate to the best of my knowledge, and supports the need for a direct procurement of the described goods or services, in the best interest of the State:

Agency Representative (signature): Date: 9/17/2026

Approved Additional conditions apply to this approval.

Rejected

DOP Administrator Signature:

DOP Administrator Printed Name:

Date: