SSJF Pt I B-53999 JPMC SS Official State Newspaper.pdf

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JPMC SS - Official State Newspaper
Solicitation number
27-416CMS-BOSS4-B-53999
Issued by
Illinois

About this file

This is a Sole Source Justification Form filed by Central Management Services (CMS) for the State of Illinois to establish a three-year master contract with the Illinois Press Association (IPA) for newspaper publication and public notice placement services. The project, titled "JPMC SS - Official State Newspaper," is designed to provide governmental units and qualified not-for-profit agencies with centralized access to newspaper advertising and public notice placement across Illinois. The contract will be available on an as-needed basis and covers the placement of public notices as display advertisements in newspapers statewide. The contract term runs from October 27, 2026, through October 26, 2029, with no renewal options. The need was identified on October 27, 2025, with the deadline for public hearing comments set for Friday, September 18, 2026, at 4:00 p.m. Central Standard Time.

The estimated value of the initial three-year contract term is $450,000, representing state funds with no federal or other funding sources. The IPA maintains an exclusive distribution and verification infrastructure across 375+ member publications covering all 102 Illinois counties, making it the sole vendor capable of simultaneously placing and legally certifying notices in hyper-local rural newspapers statewide. The pricing is governed by the Legal Advertising Rate Act (715 ILCS 15/1), which establishes a statutory minimum of 20 cents per column line and caps rates at the lowest classified rate paid by commercial users, ensuring fair and reasonable pricing. The contract directly supports state agencies' strict statutory mandates under the Notice by Publication Act (715 ILCS 5/1) and the Newspaper Legal Notice Act (715 ILCS 10/) to publish public notices, legal advertisements, and procurement opportunities within affected local jurisdictions. The IPA also operates and funds the publicnoticeillinois.com centralized digital repository at no additional cost to the state, providing a searchable archive with smart-search capabilities and automated notifications for public transparency.

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Sole Source Justification Form 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

BulletinNum: 27-416CMS-BOSS4-R-328638
Requesting: Central Management Services
CurrentPage:
PageCount:
Department: Central Management Services
NeedIdentifiedDate: 2025-10-27
NeedbyDate: 2026-10-27
ProjectTitle: JPMC SS - Official State Newspaper
ProjectTitle: JPMC SS - Official State Newspaper
Vendor: Illinois Press Association
Vendor: Illinois Press Association
Description: Placement of public notices as display advertisement in newspaper.
ValueIs: Estimated
ValueofInitialTerm: 450000.00000000
P-Ayes:
P-Ano:
P-AValue:
ThisIsA: New Sole Source
One-Time:
Term:
BeginDate: 2026-10-27
EndDate: 2029-10-26
NumberofRenewals: 0.00000000
RenewalLength: 0.00000000
RenewalValue: 0.00000000
ExceedingYes:
ExceedingNo:
TextField3: Awarding a three-year contract term represents a legally sound and responsible procurement strategy consistent with the Illinois Procurement Code (30 ILCS 500/20-60). The justification for exceeding a 12-month term is based entirely on market stability and singular vendor capability. While there have been two separate procurements totaling two years in which the CPO has individually approved, the CPO has not reviewed or authorized a multi-year sole source procurement for this three-year term.

1. Sole Source Status Per Section 1.2025 of the Illinois Procurement Rules, a sole source procurement is justified because these mandatory statewide public notice services are available from only a single supplier. The Illinois Press Association (IPA) maintains an exclusive distribution and verification infrastructure across its 375+ member publications. Because no other vendor or broker in the marketplace has the capability to simultaneously place and legally certify notices in hyper-local rural newspapers statewide, the vendor landscape is entirely static.

2. Absence of Market Competition or Price Fluctuations because the IPA holds a unique, non-proprietary monopoly over this specific rural network, the State gains no economic advantage by forcing an annual procurement cycle. Conducting the exact same procurement process every 12 months cannot yield alternative bidders, introduce market competition, or result in lower pricing. The services, statutory mandates under 715 ILCS 5/1, and the vendor's exclusive capabilities will remain entirely unchanged throughout the proposed three-year period.

3. Operational Continuity and Prior CPO Authorization. The primary benefit to the State for a multi-year designation is contract continuity and the elimination of unnecessary transactional friction for an unchanging requirement. The CPO has granted two individual procurements totaling two years. Securing a three-year contract ensures that the agency remains in continuous statutory compliance with its public notice mandates without facing annual operational interruptions.

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Q1Answer: To establish a master contract to allow all governmental units and qualified not-for-profit agencies to purchase newspaper advertisements and announcements on an as needed basis for the life of the contract. State agencies across Illinois have a strict statutory mandate to publish a wide variety of official public notices, legal advertisements, and procurement opportunities within the specific local jurisdictions and counties impacted by state actions. These postings include, but are not limited to, agricultural land leases, environmental notices, public hearings, and localized regulatory disclosures. The primary operational need is a comprehensive, centralized mechanism to distribute, publish, and legally verify these public notices across localized community newspapers statewide. This service directly impacts end users and public constituents by ensuring transparency, promoting fair public participation, and providing local communities with direct, accessible notification of state activities within their immediate geographic areas. Furthermore, these public notices must be legally ironclad to withstand potential litigation, administrative challenges, or formal disputes regarding state processes. Therefore, the service must include the generation and execution of a uniform certificate of publication pursuant to 715 ILCS 5/1. This certificate serves as a sworn affidavit and critical legal evidence to courts and units of local government establishing that the required statutory notice was executed accurately and timely. Without a streamlined, verifiable mechanism to manage these localized notices and secure these binding affidavits, state agencies cannot legally fulfill their public notice mandates, which would halt critical operations and compromise regulatory compliance.
Q2Answer: To satisfy the State’s ongoing statutory public notice mandates, any utilized print and digital network must meet the following mandatory technical, structural, and operational specifications:

Statewide Print Infrastructure and Local Jurisdictional Reach: The vendor must possess a unified, statewide distribution network consisting of more than 375 verified daily and weekly newspapers. The network must have the specific operational infrastructure to simultaneously place, track, and manage public notices within every individual rural and urban county jurisdiction across all of Illinois.

Statutory Compliance Maintenance: For the duration of the contract term, the complete newspaper distribution network must strictly fulfill all structural criteria established by the Notice by Publication Act (715 ILCS 5/) and the Newspaper Legal Notice Act (715 ILCS 10/).

Legal Affidavit Authority: The vendor must have the administrative and organizational authority to execute and guarantee uniform certificates of publication across all member newspapers in accordance with 715 ILCS 5/1. This certificate must serve as a legally binding, sworn affidavit that can withstand legal scrutiny and provide evidence of compliance to courts and units of local government.

Physical Layout Thresholds: Each utilizing print publication within the network must consist of no less than 4 pages of printed matter and maintain a minimum of 100 square inches of printed space per page.

Production Standards: All print editions must be produced utilizing conventional, recognized printing processes, specifically limited to letterpress, lithography, or gravure.

Editorial Content Minimums: The publications must annually average at least 25% non-advertising news content per issue, or alternatively maintain an annual average of at least 1,000 column inches of news content per issue.

Continuous Publication Verification: The newspapers must demonstrate continuous publication at regular intervals of at least once per week, completing a minimum of 50 issues per calendar year. This operational baseline must have been active for at least one full year prior to contract execution. Any title successor, merger, or consolidation must validate continuity under 715 ILCS 5/5(e) and 715 ILCS 10/1(e).

Circulation Integrity: The vendor must distribute all mandated public notices across the total circulation of every edition published on the designated publication date.

Centralized Digital Repository Integration: At no additional operational cost to the State, participating governmental units, or qualified not-for-profit agencies, the network must automatically cross-publish all print notices to a singular, free-access, searchable statewide public notice website. This digital archive must provide users with smart-search capabilities, automated email notifications, and daily search result tracking to maximize public transparency.

Printer Liability Protection: In accordance with the Notice by Publication Act, the system must ensure that all legal notices remain valid for all statutory purposes if any web-placement errors on the centralized statewide repository are determined to be the exclusive fault of the printer.

Q3Answer: The agency has selected "Media for Advertising" because a synchronized print and digital newspaper network is the only service type capable of satisfying the State's statutory local notice mandates. Under Illinois procurement and public notice laws, a Sole Source exists because the required service area encompasses the entire State of Illinois, down to the most remote municipal jurisdictions. Major regional publications or standard commercial advertising brokers do not have the logistical reach or legal standing to publish notices inside hyper-local community papers across all 102 counties. For example, large-scale metropolitan dailies cannot publish official notices within local township or rural community papers. To satisfy the State's legal criteria, the service type must provide a singular, aggregated distribution mechanism that feeds directly into hundreds of localized print operations simultaneously. Additionally, the service type must inherently carry the legal framework required to issue valid, court-accepted certificates of publication. No alternative marketing, digital advertising, or standard media brokerage service type can legally or operationally replicate this comprehensive local print saturation. Consequently, utilizing a centralized, statewide print-media distribution and digital archiving network is the only available service type that fulfills the agency's strict legal obligations.
Q4Answer: The Illinois Press Association (IPA) possesses the following unique capabilities and quantifiable qualifications that are entirely absent from any other market vendor or commercial broker:

Exclusive 102-County Distribution Infrastructure: The IPA maintains a unique, non-proprietary monopoly over a unified distribution network representing more than 375 daily and weekly newspapers across all 102 counties in Illinois. No other vendor or media placement broker possesses the logistical infrastructure to place, track, and manage public notices simultaneously across this complete statewide network of local print operations.

Unified Statutory Affidavit Authority: Under 715 ILCS 5/1, public notices require a uniform certificate of publication to serve as a legally binding sworn affidavit for courts and local government units. The IPA is the only entity with the administrative authority to execute, aggregate, and legally guarantee these uniform certificates across its entire 375+ member network under a single, centralized contract.

Centralized Taxpayer-Free Repository: The IPA exclusively owns, funds, and operates the statewide digital repository publicnoticeillinois.com (PNI). No other vendor has access to, or operational control over, this mandated centralized database, which automatically indexes and cross-publishes every print notice at zero additional cost to the State or its taxpayers. Because alternative brokers would be forced to individualize contracts, billing, and affidavit tracking across hundreds of independent publishers—a process that cannot guarantee uniform legal compliance—the IPA is uniquely qualified as the only vendor capable of fulfilling this statewide scope.

altYes:
altNo:
Q5aAnswer: The agency did not consider alternative supplies or services because substituting print and digital newspaper distribution with alternative media types is legally impossible under Illinois law. Pursuant to the Newspaper Legal Notice Act (715 ILCS 10/) and the Notice by Publication Act (715 ILCS 5/), public notices must be published in a verified local newspaper of general circulation that meets strict layout, production, and editorial thresholds. Alternative notification methods—such as social media postings, digital banner advertisements, television broadcasts, or independent agency websites—do not carry the statutory authority required to satisfy these visibility laws. Furthermore, alternative services cannot generate the legally binding sworn affidavits of publication required under 715 ILCS 5/1 to protect the State against litigation. Because any alternative service type would result in immediate statutory non-compliance, newspapers remain the only legally viable medium, and no alternative methods could be considered.
Q5bAnswer:
Q5cAnswer:
Q6Yes:
Q6No:
Q6NA:
Q7Answer: Because this procurement involves a verified True Sole Source vendor, standard commercial open-market price negotiations are limited by state law. Price reasonableness is strictly established and controlled by the Legal Advertising Rate Act (715 ILCS 15/1), which establishes a clear statutory ceiling for all legal public notices in Illinois. Pursuant to 715 ILCS 15/1, the minimum statutory charge is fixed at 20 cents per column line for each insertion. Crucially, the law dictates that the maximum rate charged to the State cannot exceed the lowest classified rate paid by commercial users for comparable space in whichever newspaper the notice appears. This statutory cap explicitly forces the inclusion of all cash discounts, multiple insertion discounts, and standard volume benefits extended to regular commercial customers. The Illinois Press Association acts as a centralized administrator and must strictly adhere to these statutory limits across its entire 375+ member network. Total expenditures are strictly volume-dependent, calculated based on precise character-per-line metrics, column dimensions, and the statutory frequency requirements of each individual notice. Because the pricing structure is tied directly to the lowest commercial rates by legislative mandate, the State is legally guaranteed the lowest possible market pricing. Therefore, the agency has determined the pricing under this contract to be inherently fair, reasonable, and fully protective of public funds.
Q8y:
Q8n:
Q8aAnswer:
Q9Answer: If this True Sole Source procurement is not approved and a competitive bid is required, the primary impact to the State of Illinois will be immediate statutory non-compliance and severe operational disruption across multiple state agencies. Pursuant to the Notice by Publication Act (715 ILCS 5/) and the Newspaper Legal Notice Act (715 ILCS 10/), state agencies have strict legal mandates to notify the public of public hearings, administrative rule-making, environmental permits, asset leases, and regulatory disclosures within the specific local jurisdictions affected by state actions. Because no other commercial vendor or media broker possesses a unified network capable of publishing notices across all daily and weekly rural newspapers statewide, forcing a competitive solicitation will fail to yield alternative qualified bidders. Consequently, the mandatory public notice process would stall, placing the State in direct violation of statutory visibility laws. This legal failure would halt critical state operations, delay the execution of essential public programs, and expose the State to immediate regulatory penalties, administrative challenges, and severe litigation risks regarding the validity of unadvertised state actions.
Q10Answer: The Illinois Press Association represents a centralized infrastructure that cannot be duplicated by any other vendor or media network in the marketplace. While individual newspapers exist, the distinct advantage of this network is its ability to serve as a singular gateway to the entire state of Illinois, providing simultaneous and comprehensive circulation across all 102 counties. No alternative broker, digital platform, or publication group possesses the operational or legal mechanism required to aggregate local print insertions, execute centralized billing, and guarantee statutory compliance for hundreds of hyper-local jurisdictions under one procurement vehicle. Attempting to manage this scope through any other means would require individual state agencies to execute and monitor hundreds of separate contracts with individual community publishers. This would compromise legal consistency, risk immediate statutory non-compliance, and create an impossible administrative barrier. Furthermore, the Illinois Press Association funds and maintains the centralized PublicNoticeIllinois.com digital repository at no additional cost to state agencies or taxpayers. This archive provides a level of public access and transparency that is unavailable through any other single commercial source, further solidifying that this network is the only viable method for the State to fulfill its transparency and public visibility requirements.
SignatureField1:
TextField63: Jesse L. Jones
TextField63: jesse.l.jones@illinois.gov
TextField63: ron.wilson@illinois.gov
TextField63: Ron Wilson
TextField64:
TextField65: 217/557-2412
Approve:
denied:
Comments:
Phone: 217-299-4919
Date: 2026-09-08
PN: John H.H. Demien, CPPB
Email: john.demien@illinois.gov
InitialPostingDate: 2026-09-08
HearingYes:
HearingNo:
HearingDate:
HearingTime:
HearingLocation:
No: 0
Members: 0
recommends:
WrittenComments: 0
DecisionMemo: 0
HearingMinutes: 0
Other: 0
OtherComments:
HearingOfficerSignature:
Authorize:
AuthorizeWChanges:
Cancel:
CPOComments:
CPOSignature:
CPOTelephone:
CPOPrintedName:
CPOEmail:

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