S03 - JA Redacted for Solicitation - Micro Focus.pdf

Micro Focus/Open Text Testing Tool Suite Control Number: VA-25-00048241

JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY

1. Contracting Activity: Department of Veterans Affairs Office of Procurement, Acquisition, and Logistics Technology Acquisition Center 23 Christopher Drive

Eatontown, NJ 07724

2. Description of Action: The proposed action is for a firm-fixed-price (FFP) Delivery Order (DO) to be issued under the National Aeronautics and Space Administration (NASA) Solutions for Enterprise-Wide Procurement (SEWP) V Government-Wide Acquisition Contract (GWAC) for brand-name Micro Focus/Open Text Testing Tool Suite software maintenance and technical support services for existing brand name Micro Focus/Open Text perpetual licenses.

3. Description of the Supplies or Services:

In support of Department of Veterans Affairs (VA), Electronic Health Record Modernization (EHRM), the VA requires brand name maintenance and support for existing perpetual Micro Focus/Open Text Testing Tool Suite licenses. The Micro Focus/Open Text Testing tools suite forms the basis for our risk-based testing, as it is a central repository for all test activities, plans, schedules and test results and artifacts. It serves as a collaborative platform for all stakeholders involved in the testing and testing support process. VA requires software support inclusive of Phone-in assistance, Web-Based self-solve support and customer connection, 24 hours per day, seven (7) days a week, 365 days a year, Web and email support coverage and downloadable software patches and/or upgrades.

The requirement is for continued maintenance and support of existing VA owned perpetual licenses. No new licenses are being procured. The requirement is for a 12-month base period with two (2) 12-month option periods. The base period of performance will start on March 9, 2025 and end on March 8, 2026. The total estimated value of the proposed effort including a base period and two 12-month options is estimated to be .

4. Statutory Authority: Pursuant to Federal Acquisition Regulation (FAR) 16.505(a)(4), the following 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 FAR 16.505(b)(2)(i)(B), entitled “Only one awardee is capable of 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 VA owned Micro Focus/Open Text Test Suite perpetual licenses form an integral component of EHRM software testing capability. The suite includes LoadRunner Remote Access, Unified Functional Testing (UFT), Application Lifecycle Management (ALM), which are critical to validating and verifying software systems that support VA operations.

The required support is based on proprietary software, specific to the Original Equipment Manufacturer (OEM). Due to the proprietary nature of the Micro Focus/Open Text Test Suite, ongoing software maintenance, support, and updates can only be executed by Micro Focus/Open Text or an authorized reseller.

Micro Focus/Open Text software includes proprietary encryption mechanisms, authentication protocols, and security patches that only the OEM can update to ensure ongoing compliance with federal cybersecurity policies. Third-party intervention would invalidate certification and accreditation (C&A) approvals, introducing security risks that compromise the integrity of VA’s testing environment.

Based upon market research, as described in Section 8 of this justification, it was determined that there is competition among Service-Disabled Veteran-Owned Small Business (SDVOSB) authorized resellers.

Micro Focus/Open Text provides performance tuning, bug fixes, and compatibility updates to align with evolving VA enterprise applications. Because these updates require modifications to the core software engine and interaction with VA-specific configurations, only the OEM or an authorized reseller can ensure seamless integration with mission-critical systems. Third-party maintenance providers lack the specialized knowledge, proprietary diagnostic tools, and authorized access necessary to perform these optimizations without jeopardizing system stability.

For the reasons outlined above, software maintenance and support for the Micro Focus/Open Text Test Suite can only be performed by Micro Focus/OpenText or an authorized reseller. No third-party products can provide the proprietary updates, security patches, or compliance assurance required to maintain the integrity of VA’s Test and Evaluation function. Engaging a third-party provider could introduce significant risks to functionality and required capabilities, rendering it a non-viable alternative to OEM support. As such, a procurement for OEM-exclusive maintenance is required to ensure VA’s testing capabilities remain secure, compliant, and fully operational.

As stated earlier in this document Micro Focus/Open Text Testing tools suite forms the foundation for our risk-based testing. Application Lifecycle Management (ALM) is a key sub-component of the suite. In addition to ALM licenses within this suite, EHRM owns two other sets of ALM Global edition licenses. One set of ALM Global licenses provides expanded access to stakeholders across EHRM and the VA, and the third set of ALM Global licenses resides in the Oracle Enclave, in support of automated testing efforts there.

Switching to an alternate solution would create substantial duplicated cost and time.

The estimated duplicated cost of replacing the current Testing Tools Suite solution and infrastructure with a new platform is at least and it would take an estimated 3 months to obtain, develop, transition and implement any new solution.

These estimates are based on previous acquisition history of projects with similar size and scope. Without this product, there would be an increased risk of defects in the systems used to support Veterans, such as medical appointment scheduling, medical records maintenance and updates, prescriptions, and other areas. Defects in these areas could have substantial direct and indirect impacts on the overall quality of services provided to Veterans as well as direct individual negative impacts on health and safety.

6. Efforts to Obtain Competition: Market research was conducted, details of which are in Section 8 of this justification. Market research determined that limited competition is available among authorized resellers for required software license maintenance and support. In accordance with FAR 16.505(a)(4)(iii)(A)(1), this justification will be provided with the solicitation to all appropriate NASA SEWP V GWAC holders. Furthermore, in accordance with FAR 5.301, 16.505(b)(2)(ii)(D), and 16.505(a)(4)(iii), the award notice for this action will be synopsized on the SAM.gov Contract Opportunities website and this 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: A Request for Information (RFI) was posted on NASA SEWP on 1/8/2025 and resulted in six (6) market research quotes. Three (3) responses were received from SDVOSBs, one (1) Small Business, one (1) Women Owned Small Business and one (1) Other Than Small business. It was determined that there are numerous NASA SEWP V GWAC holders that are authorized resellers of the required software maintenance and technical support services under North American Industry Classification System code 541519.

Additionally, the Government’s technical experts conducted market research in February of 2024 by reviewing globally recognized research, analysis documentation, and considering several brand name products that provide similar functionality. The market for software testing and quality assurance tools includes several competitors offering test automation, performance testing, and application lifecycle management (ALM) solutions. While products such as Selenium, Tricentis Tosca, Apache JMeter, and SmartBear provide various testing functionalities, none offer the full suite of integrated capabilities, and direct vendor support requirements or provide current capability. Micro Focus Testing Tool Suite remains the only comprehensive solution that meets VA’s needs for automated functional testing, load testing, security testing, and enterprise test management.

Alternate products lack the proprietary integrations, and vendor-backed maintenance necessary to support VA’s mission-critical testing environment.

Many competing solutions focus on isolated testing capabilities, requiring multiple third-party tools to achieve the same level of functionality as the Micro

Focus/Open Text Test Suite. Selenium (Open Source) – Lacks enterprise support, and built-in test management; requires extensive scripting and third-party integrations. Tricentis Tosca – Uses a proprietary model-based approach but lacks native integration with VA’s legacy and cloud-based systems; and will require vendor-specific training. Apache JMeter – Focuses on performance testing only; lacks comprehensive test automation, security testing, and ALM capabilities. SmartBear TestComplete – Provides GUI testing but lacks enterprise-grade security controls and integration with VA’s CI/CD pipelines. IBM Rational Test Suite – Legacy system with incompatibility with VA’s modern cloud infrastructure and Agile development workflows.

Given the limitations described in paragraph 5, only Micro Focus/Open Text, or an authorized reseller are viable solutions to provide maintenance and support for VA’s existing Testing Tool Suite applications.

Additional market Research was conducted by the Contract Specialist in February of 2025 using the NASA SEWP Provider Lookup Tool, which found 118 Micro Focus resellers. Market research conducted utilizing the NASA SEWP Lookup Tool identified 34 SDVOSBs that are Micro Focus/Open Text resellers.

Based on the results of the Provider Lookup Tool set forth above, there is a reasonable expectation that two or more SDVOSBs can provide the required brand name maintenance and support for existing perpetual Micro Focus/Open Text Test Suite licenses.

9. Other Facts: None.

Advocate for Competition Approval In my role as procuring activity Advocate for Competition, based on the foregoing justification, I hereby approve the acquisition of Micro Focus/Open Text Testing Tool Suite software maintenance and technical support services for existing perpetual licenses 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.