Signed Part II ISBE B-44340.pdf

Sole Source Justification Form

Version 7.01 Page 1 of 6

Bulletin Reference Number 25-586SBE-CHFED-B-44340

Requesting Agency/University Illinois State Board of Education

Sole Source Justification Form - Part I Section I - General Information

Department/Bureau/Section: Nutrition

Need Identified Date: Jun 5, 2024 Supply/Service Need By Date: Oct 1, 2024

Project Title: Brighton Training Modules

Vendor: Brighton Training Group

Provide a description of the supplies or services required: Community Nutrition Program (CNP) training modules. Modules are required trainings by participants in the CNP's.

Value: Actual Value of Initial Term, this Change Order or Amendment: 102,500

Will this Sole Source amend a Professional or Artistic Services contract? Yes No

*Sole Source may not be used for amendments for Professional or Artistic Services if the amendment would increase the value by more than 5% of the initial award or extend the term by more than 60 days.

Type: New Sole Source

Section II - Proposed Term

One-Time Purchase Term Contract

Estimated Contract Begin Date: 10/1/2024

Estimated Contract End Date: 9/30/2025

Number of Potential Renewals: 0

Length of Each Renewal in Months: 0

Total Value of All Renewals: 0

If a Term Contract, does the term, including renewals, exceed 12 months? Yes No

Section III - Funding Source Select the type of funding to be used (Check all that apply): State Appropriate Funds Federal Funds Other (Explain):

Section IV - Sole Source Justification

This purchase is economically only available from a single source primarily because it is: (If "Other" explain in one sentence)

Items are Copyrighted or Patented and the Items are Only Available from the Holder

Are there secondary justification(s) for this sole source? Yes No

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Bulletin Reference Number 25-586SBE-CHFED-B-44340

Requesting Agency/University Illinois State Board of Education

Section V - Purchase History

Has the Agency or University Purchased these supplies or services in the past? Yes No

Term Term From Term To Value Description Contract Number Type

1 10/1/2021 9/30/2022 101,000 Brighton Training Modules P-31088 Small Purchase

2 10/1/2022 09/30/2023 191,000 Brighton Training Module license renewal P-43029 Sole Source

3 10/1/2023 09/30/2024 211,250 Brighton Training Module license renewal P-58248 Sole Source

If more than 10, or if other comments, explain:

Section VI - Business Rationale

1. Provide a detailed explanation of the need for the supplies or services:

Bright Track compliance training system licenses to be used for state education agencies and sponsors participating in the United States Department of Agriculture's (USDA) child nutrition programs (or CNP's) including the Child and Adult Care Food Program (CACFP), Summer Food Service Program (SFSP), National School Lunch Program (NSLP), National School Breakfast (NSB), and others.

The licensing for the Training System includes a wide selection of interactive online training services for CACFP and other child nutrition training courses. State agencies administering the child nutrition program(s) subscribe to the training system which offers course development, delivery, and tracking.

2. Provide a list and describe in detail the specifications required to satisfy the need:

• Traceable training system allows ISBE Nutrition staff to verify completion or check status to ensure required trainings are completed.

• USDA-regulated standards incorporated: training modules are already pre-populated based on USDA requirements and standards

• Customizable training: each training course is customizable and can be adjusted to meet Illinois State requirements and standards

• Specific, broken down modules: individualized modules to direct Sponsors to that need additional direction on specific subjects

• Updates: vendor updates trainings as USDA implements new standards, etc.

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Bulletin Reference Number 25-586SBE-CHFED-B-44340

Requesting Agency/University Illinois State Board of Education

3. Provide detail explaining the justification selected in Section IV to explain why the requested supplies or services are the only ones available that can satisfy the agency or university requirements?

An Internet search was conducted by the Nutrition Department and no other alternatives that met USDA 's specific requirements were identified. Brighton Training Group certifies that Bright Track is a sole source product, created, distributed and sold exclusively by Brighton Training Group (BTG). No other company makes a similar or competing product. This product must be purchased directly by state agencies from Brighton Training Group at the listed address on their website. There are no dealers or agents authorized to represent this product.

Contractors comparison overview:

1. Brighton Training Group (BTG): Private company established with the purpose of hosting a library of proprietary online federal child nutrition program (CNP) courses and a specialized course management software system for CNP oversight agencies. BTG has a library of 70 interactive, ADA-accessible, self-paced CACFP online courses that can be viewed in English and Spanish. BTG hosts a proprietary online training platform for each individual state agency (SA) that contracts with them. This platform allows SAs to track course completion status by each agency to enable the CACFP Branch to demonstrate compliance with federal and state-mandated training and oversight requirements. BTG courses are tailored to meet the training needs of all CACFP Operators: child care centers, adult day care centers, emergency shelters, at-risk afterschool programs, and sponsoring organizations. BTG currently contracts with 17 other SAs to meet their CACFP training requirements, which promotes consistency in federal guidance.

2. Institute of Child Nutrition (ICN): Federally-funded agency that provides resources, online training, virtual live training, and in-person training to child nutrition program operators. The ICN specializes in School Nutrition Programs (SNP) but has a small library of 20 CACFP courses. SAs do not contract directly with the ICN and cannot track completion of courses by CACFP Operators.

3. Providers Choice (PC): Sponsoring organization in MN, which means they are responsible for the administration of the CACFP on behalf of providers (family child care homes [who are not allowed to contract directly with the SA] or other institutions); they do not specialize in hosting a training and tracking platform. Sponsoring organizations are required to train their providers, not the SA, which is why PC has CACFP trainings on their website. PC does not host a platform that provides training to all CACFP Operators that can be tracked and recorded by SAs nationwide; rather, they handle the administration of the CACFP for providers in MN only.

4. CORE: Series of nine courses developed as train-the trainer modules for SA staff and sponsoring organizations only. These courses are not applicable to child care centers, adult day care centers, emergency shelters, or at-risk afterschool programs. Courses were developed through a federally-funded contract awarded to MH Miles (an accounting firm) who subcontracted a portion of content development to another company with CACFP expertise and they subcontracted the entire course design, online platform, and mobile app to BTG. Three CORE courses are available on-demand for free on a BTG training platform; the other six courses are only available on-demand by contracting with BTG.

4. What are the unique features of the supplies or services that are not available in any other product or by any other vendor? Provide specific quantifiable factors/qualifications:

Brighton's courses are designed to meet USDA requirements, including those for professional standards as mandated by section 306 of the Healthy, Hunger Free Kids Act of 2010 (HHFKA), and can be completed at the participant’s convenience, replacing the need for costly and time consuming live training sessions. This training system assists state agencies in complying with the USDA requirements for providing annual training to its sponsors and providers, as well as the requirements established by Section 7(g)(2)(A) of the CNA which requires that each school food authority must ensure that an individual conducting or overseeing administrative procedures receives training annually. This program also assists state agencies in meeting the requirements of Section 306 of the HHFKA which requires the establishment of a mandatory education, training, and certification program for all school nutrition directors responsible for the management of a school food authority. The program must include minimum educational and periodic training requirements necessary to successfully manage the school meals programs, as well as the ability to demonstrate competence in the areas covered by the training. Brighton Training Group offers the nation’s only USDA compliant training system designed to completely automate a state agency’s child nutrition provider training requirements. They are the only Training Group with over 100 years of Child Nutrition Experience and was created solely for the purpose to automate the training for USDA Federal Child Nutrition Programs by these Child Nutrition experts. Used by state agencies and providers, this training system meets federal child nutrition requirements while significantly reducing the state’s cost for developing, delivering and tracking their annual training workshops. The Bright Track compliance training system goes beyond that of other online training solutions by requiring participants to demonstrate a level of competency through online assessments. There is no comparable product for this market segment for the price, quality of goods, and timeliness of delivery.

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Bulletin Reference Number 25-586SBE-CHFED-B-44340

Requesting Agency/University Illinois State Board of Education

5. Has the Agency or University considered alternative supplies or services to satisfy their need? Yes No

5a. If no, why weren't alternatives evaluated?

There is currently no other USDA specific requirement-based trainings for Sponsors provided by other vendors.

6. Are there resellers or distributors?

Yes No N/A

7. What efforts were made to get the best possible price (i.e. did the agency/university negotiate) and how did you determine the price for this purchase is considered fair and reasonable?

ISBE’s Nutrition Department negotiated with Bright Track to secure a quote of training modules. The price is the standard offering for Brighton per each course and price is not negotiable, only negotiable part is which course listings to purchase. There are no other vendors that provide these exact modules, so there are no other pricing structures to compare to.

8. Will this purchase obligate the State to this vendor for future purchases such as maintenance, licensing or continuing need?

Yes No

9. What will be the financial or other impact to the State if this sole source is not approved and a competitive bid is required?

USDA requires that sponsors be trained prior to approval and annually thereafter. The Nutrition Department does not have the manpower to host in-person new sponsor trainings for each new sponsor that applies, along with the already existing sponsors. With the online trainings, sponsoring organizations can take the trainings at their own convenience to ensure compliance with USDA’s training regulations. ISBE would be unable to provide valuable training to both ISBE employees as well as sponsors participating in the CACFP & SFSP programs if this were denied.

10. Is there any additional information you would like to add to justify this sole source?

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Bulletin Reference Number 25-586SBE-CHFED-B-44340

Requesting Agency/University Illinois State Board of Education

Section VII

Requesting Department Representative

Requesting Department Signature Required

I know and understand the contents of this Sole Source Justification and attest that all statements are true and correct and the fairness and reasonableness of the price was adequately confirmed.

Date Aug 16, 2024

Printed Name Mark Haller E-mail Address mhaller@isbe.net

Phone Number 217-782-2491

State Agency Bureau/Division Head or University Purchasing Director Approval and Signature Required

I know and understand the contents of this Sole Source Justification and attest that all statements are true and correct and the fairness and reasonableness of the price was adequately confirmed. (All prior form fields will lock once this e-signature is completed)

E-mail Address

Phone Number Date

Printed Name

Agency Bureau/Division Head or University Purchasing Director and Not a Designee

SPO Approval and Signature Required

I have reviewed and understand the contents of this Sole Source Justification and agree with the State Agency or University determination.

I have reviewed and understand the contents of this Sole Source Justification and do not agree with the State Agency or University determination. As a result, the State Agency or University must explore other sourcing methods to satisfy their need.

State Purchasing Officer Signature Phone Number 217-299-0935 Date Aug 19, 2024

Printed Name Colene Underwood E-mail Address Colene.Underwood@Illinois.gov

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Bulletin Reference Number 25-586SBE-CHFED-B-44340

Requesting Agency/University Illinois State Board of Education

Sole Source Justification Form - Part II Section I - General Information

Project Title Brighton Training Modules

Vendor Brighton Training Group

Initial Date of Procurement Bulletin Posting Aug 20, 2024

Was a Sole Source hearing held per 30 ILCS 500/20-25?

Yes - Complete Section II and III below (Section II will only be visible when this option is selected)

No - Section II not required, go to Section III below Section III - CPO Approval and Signature Required

Based on my review, I authorize the Agency/University to proceed in accordance with the published Notice referenced above.

Based upon my review, I authorize the Agency/University to proceed with the following Changes.

Based on my review, the Agency/University is not authorized to proceed with this sole source as presented and my recommendation is that it be cancelled.

Other

CPO Signature CPO Phone (217)558-2231

Printed Name Ellen H. Daley Date Sep 4, 2024

CPO E-mail ellen.h.daley@illinois.gov

Version 7.01 Page of Sole Source Justification Form - Part I Section I - General Information Will this Sole Source amend a Professional or Artistic Services contract?

If yes, what was the original contract value?

*Sole Source may not be used for amendments for Professional or Artistic Services if the amendment would increase the value by more than 5% of the initial award or extend the term by more than 60 days.

Section II - Proposed Term If a Term Contract, does the term, including renewals, exceed 12 months?

If yes, provide a detailed justification including any economic benefit received for agreeing to a multi-year term:

Section III - Funding Source Select the type of funding to be used (Check all that apply):

Section IV - Sole Source Justification Are there secondary justification(s) for this sole source?

Section V - Purchase History Has the Agency or University Purchased these supplies or services in the past?

Term Term From Term To Value Description Contract Number Type Section VI - Business Rationale

1. Provide a detailed explanation of the need for the supplies or services:

2. Provide a list and describe in detail the specifications required to satisfy the need:

3. Provide detail explaining the justification selected in Section IV to explain why the requested supplies or services are the only ones available that can satisfy the agency or university requirements?

4. What are the unique features of the supplies or services that are not available in any other product or by any other vendor? Provide specific quantifiable factors/qualifications:

5. Has the Agency or University considered alternative supplies or services to satisfy their need?

5a. If yes, name the alternative vendors whose supplies or services were evaluated:

5b. If yes, what were the alternatives for each vendor and why were they unacceptable? Be specific with regard to features, characteristics, requirements, capabilities and compatibility:

5c. Explain how the market evaluation was conducted?

*This evaluation is to determine available options within a market. If the evaluation is to determine quality or best suited option, this is not the appropriate source selection. Under no circumstances shall the evaluation consist of testing alternative options. These activities must be conducted in a competitive transparent environment (i.e. IFB or RFP).

5a. If no, why weren't alternatives evaluated?

6. Are there resellers or distributors?

7. What efforts were made to get the best possible price (i.e. did the agency/university negotiate) and how did you determine the price for this purchase is considered fair and reasonable?

8. Will this purchase obligate the State to this vendor for future purchases such as maintenance, licensing or continuing need?

8a. If yes, please provide details regarding future obligations and/or needs:

9. What will be the financial or other impact to the State if this sole source is not approved and a competitive bid is required?

10. Is there any additional information you would like to add to justify this sole source?

Section VII Requesting Department Signature Required I know and understand the contents of this Sole Source Justification and attest that all statements are true and correct and the fairness and reasonableness of the price was adequately confirmed.

State Agency Bureau/Division Head or University Purchasing Director Approval and Signature Required I know and understand the contents of this Sole Source Justification and attest that all statements are true and correct and the fairness and reasonableness of the price was adequately confirmed. (All prior form fields will lock once this e-signature is completed) SPO Approval and Signature Required Sole Source Justification Form - Part II Section I - General Information Was a Sole Source hearing held per 30 ILCS 500/20-25?

Section II - Sole Source Hearing Details The State posted to the Illinois Procurement Bulletin a description of the State's need, the justification for the sole source decision, and information regarding the opportunity to submit comments and testify at a public hearing. Notice of the hearing was also posted outside of the hearing room 48 hours prior to the hearing.

The public hearing was conducted for the purpose of receiving testimony regarding the sole source determination. The Hearing Officer recommends the following:

The following relevant documents are attached:

Section III - CPO Approval and Signature Required 9.0.0.2.20101008.1.734229 ellen.h.daley@illinois.gov

• USDA-regulated standards incorporated: training modules are already pre-populated based on USDA requirements and standards

• Customizable training: each training course is customizable and can be adjusted to meet Illinois State requirements and standards

• Specific, broken down modules: individualized modules to direct Sponsors to that need additional direction on specific subjects

• Updates: vendor updates trainings as USDA implements new standards, etc.

Q3Answer: An Internet search was conducted by the Nutrition Department and no other alternatives that met USDA 's specific requirements were identified. Brighton Training Group certifies that Bright Track is a sole source product, created, distributed and sold exclusively by Brighton Training Group (BTG). No other company makes a similar or competing product. This product must be purchased directly by state agencies from Brighton Training Group at the listed address on their website. There are no dealers or agents authorized to represent this product.

Contractors comparison overview:

1. Brighton Training Group (BTG): Private company established with the purpose of hosting a library of proprietary online federal child nutrition program (CNP) courses and a specialized course management software system for CNP oversight agencies. BTG has a library of 70 interactive, ADA-accessible, self-paced CACFP online courses that can be viewed in English and Spanish. BTG hosts a proprietary online training platform for each individual state agency (SA) that contracts with them. This platform allows SAs to track course completion status by each agency to enable the CACFP Branch to demonstrate compliance with federal and state-mandated training and oversight requirements. BTG courses are tailored to meet the training needs of all CACFP Operators: child care centers, adult day care centers, emergency shelters, at-risk afterschool programs, and sponsoring organizations. BTG currently contracts with 17 other SAs to meet their CACFP training requirements, which promotes consistency in federal guidance.

2. Institute of Child Nutrition (ICN): Federally-funded agency that provides resources, online training, virtual live training, and in-person training to child nutrition program operators. The ICN specializes in School Nutrition Programs (SNP) but has a small library of 20 CACFP courses. SAs do not contract directly with the ICN and cannot track completion of courses by CACFP Operators.

3. Providers Choice (PC): Sponsoring organization in MN, which means they are responsible for the administration of the CACFP on behalf of providers (family child care homes [who are not allowed to contract directly with the SA] or other institutions); they do not specialize in hosting a training and tracking platform. Sponsoring organizations are required to train their providers, not the SA, which is why PC has CACFP trainings on their website. PC does not host a platform that provides training to all CACFP Operators that can be tracked and recorded by SAs nationwide; rather, they handle the administration of the CACFP for providers in MN only.

4. CORE: Series of nine courses developed as train-the trainer modules for SA staff and sponsoring organizations only. These courses are not applicable to child care centers, adult day care centers, emergency shelters, or at-risk afterschool programs. Courses were developed through a federally-funded contract awarded to MH Miles (an accounting firm) who subcontracted a portion of content development to another company with CACFP expertise and they subcontracted the entire course design, online platform, and mobile app to BTG. Three CORE courses are available on-demand for free on a BTG training platform; the other six courses are only available on-demand by contracting with BTG.